ML20056F079
| ML20056F079 | |
| Person / Time | |
|---|---|
| Issue date: | 08/02/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Remick NRC COMMISSION (OCM) |
| Shared Package | |
| ML20056F080 | List: |
| References | |
| NUDOCS 9308260032 | |
| Download: ML20056F079 (10) | |
Text
,
August 2o 1993 MEMORANDUM FOR: Commissioner Remick i
FROM:
James M. Taylor
~
Executive Director for Operations i
SUBJECT:
SECY-93-087:
POLICY, TECHNICAL, AND LICENSING ISSUES PER-TAINING TO EVOLUTIONARY AND ADVANCED LIGHT-WATER REACTOR DESIGNS t
In your memorandum of July 12, 1993, you requested that the staff provide additional information on two items in the subject Commission paper for which the staff did not request a Commission decision. The two items were the reliability assurance program (RAP) and the simplification of offsite emer-t gency planning requirements.
l I
With regard to the first item, the staff still intends to provide a position to the Commission on Operational RAP (0-RAP); however, it has developed its i
position on the design RAP (D-RAP) at this time in order to address on-going reviews of standardized designs. The staff's response to your questions on the RAPS is given in Enclosure I.
However, please be aware that the D-RAP staff position has not received OGC concurrence and is the subject of on-going discussions. The D-RAP will also be discussed in a Commission paper on the regulatory treatment of non-safety systems for passive designs which is now in concurrence review.
The staff's response to your questions on emergency planning is given in mptters lease let me know.
i If you need any additional information on thes rig 2r,al sign,dby l
/u Jamss H. Snie;ek
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.. James M. Taylor 1
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. Executive Director l
for Operations l
Enclosures:
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As stated cc w/ enclosures:
The Chairman l
Commissioner Rogers Commissioner de Planque i
SECY OGC l
OCA 9308260032 930002 PDR ORO NE E OPA CONTACT:
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4 SlAFF RESPONSE TO COMMISSIONER REMICK'S QUESTIONS ON RELIABILITY ASSURANCE PROGRAMS l
Backaround The concept of a systems reliability program to ensure that the reliability of components and systems important to safety would remain at a suffleient level was included in NUREG-1070, "NRC Po.licy on Future Reactor Designs." To ensure that reliability objectives are met and to prevent degradation of reliability during operation, the Nuclear Regulatory Commission (NRC) envisioned that the i
probabilistic risk assessment (PRA), performed at the design stage, would be used as a tool in making detailed design decisions affecting procurement, testing, and the formulation of operations and maintenance procedures.
In SECY-89-013, " Design Requirements Related to the Evolutionary Advanced Light _
Water Reactor (ALWR)," the staff stated that the reliability assurance program (RAP) would be-required for design certification to ensure that the design reliability of safety-significant structures, systems, and components (SSCs) is maintained over the life of a plant.
H The advanced light water reactor (ALWR) RAP would apply to those plant SSCs I
that are risk significant (or significant contributors to plant safety) as j
determined by the design certification PRA. The purposes of the RAP are to (1) ensure that an ALWR is designed, constructed, and operated in a manner j
that is consistent with the design assumptions for these risk-significant SSCs; (2) prevent the reliability of these risk-significant SSCs from degrad-ing during plant operations; (3) minimize the frequency of transients that i
challenge ALWR SSCs; and (4) help ensure that these SSCs function reliably when challenged.
The staff views the RAP for ALWRs as a two-stage' program. The first stage 5
applies to the design phase of the plant life cycle and has been referred to as the " design reliability assurance program (D-RAP)." The second stage applies to the construction and operations phases of the plant life cycle, and i
has been referred to as the " operational reliability assurance program i
(0-RAP)." An applicant for design certification would be required to estab-i lish the scope, purpose, objective, and essential elements of an effective RAP i
and would implement those portions of the D-RAP that apply to design certifi-cation. A combined license (COL) applicant would augment the design certifi-cation D-RAP with site-specific design information, including information for j
the procurement process, and would implement the balance of the D-RAP. The COL applicant would also establish and implement the 0-RAP.
The 0-RAP can be thought of as an inclusive program that integrates aspects of f
existing programs (e.g., maintenance, surveillance testing, inservice inspec--
_i tion, inservice testing, and quality assurance (QA)) to achieve its objective.
'i s
The 0-RAP would apply to the construction and operation phases of plant life, l
would be built on the information from the D-RAP, and would mostly be based on the requirements of 10 CFR 50.65, the maintenance rule. To ensure regulatory coherence between the RAP and the maintenance rule, performance goals and
~
, criteria for risk-significant SSCs established for the implementation of the maintenance rule would fall under the umbrella of the 0-RAP. The COL appli-cant would establish performance and condition monitoring requirements for maintaining the reliability of risk-significant SSCs and would provide a feedback mechanism for periodically reevaluating risk significance based on actual equipment, train, or system performance.
Staff Position on the RAP The staff's position is that a high-level commitment to a RAP applicable to design certification should be required. The standard safety analysis report i
(SSAR) should include the details of the D-RAP, including the conceptual framework, program structure, and essential elements.
The SSAR for the D-RAP should also (1) identify and prioritize a list of risk-significant SSCs on the basis of the design certification PRA and other sources; (2) ensure that the vendor's design organization determines that significant design assumptions, such as equipment
' liability and unavailability, are realistic and achiev-able; (3) include...iormation that is needed to be developed for the procure-ment process for obtaining equipment that satisfies the design reliability assumptions; and (4) serve as a means of conveying these design assumptions to the COL applicant for consideration in the 0-RAP. A COL applicant would augment the design certification D-RAP with site-specific design information, including information for the procurement process generated as the detailed design process proceeds, and would implement the balance of the D-RAP. The COL applicant would also develop and implement the 0-RAP. The staff would review the COL applicant's D-RAP and 0-RAP as part of the COL application.
When SECY-93-087 was being drafted, the staff was interacting with industry on the regulatory treatment cf non-safety systems (RTt SS) for passive ALWRs.
Although the staff did not plan to change its position on the RAP, its position could have changed for passive ALWRs pending the resolution of RTNSS.
Therefore, the staff chose to refer to the position on the RAP in SECY-93-087 as interim rather than final and did not seek Commission approval at that time.
The resolution of RTNSS requires no changes to the staff position on RAP for passive ALWRs.
In the draft Commission paper on RTNSS, the staff recommends-approval of its position that the application for design certification submitted in accordance with 10 CFR 52.47 include a commitment to a RAP and the details of the KAP be included in the SSAR.
BLdustry Positions on RAP In the Electric Power Research Institute (EPRI) Utility Requirements Documents (URD) for evolutionary and passive plants, Chapter 1, Section 6, " Reliability and Availability," the D-RAP goals and objectives are stated as assure design reliability of structures, systems, and compo-nents (SSC) whose reliability has a significant effect on core damage frequency
' assure that sufficient plant reliability is designed into the
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plant to achieve overall availability goals provide enhanced defense-in-depth via design reliability that minimizes challenges to safety systems provide information to be 'used by a future owner / operator for on-going plant reliability assurance activities assure the original bases and design assumptions are satisfied
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and that safety margins are met.
The staff has found the EPRI D-RAP goals and objectives to be consistent with its position on the RAP.
GE Nuclear Energy (GE) submitted a RAP for the advanced boiling water reactor (ABWR) in SSAR Chapter 17, Section 17.3.
The staff found that the GE SSAR RAP (Tier 2) was consistent with its position on the RAP and that it was accept-abl e.
GE also submitted as part of the ABWR inspections, tests, analyses, and acceptance criteria (ITAAC), Section 3.5, " Reliability Assurance Program," a non-system generic Tier I requirement (design description) with no associated i
In its initial review of the ABWR Tier 1 RAP, the staff has found it acceptable.
ABB-Combustion Engineering (ABB-CE) submitted a RAP as part of System 80+ SSAR Chapter 17, Section 17.3.
The staff has reached agreement with ABB-CE on this Tier 2 information in that it is consistent with the staff position on the RAP. However, in a letter of May 27, 1993, ABB-CE stated that it objected to making D-RAP generic Tier 1 material. ABB-CE further stated that if a commitment to the RAP was placed in Tier 1, it will lead to the need for a demonstrable acceptance criterion.
In a subsequent letter dated June 29, 1993, ABB-CE reiterated its objection to the inclusion of the RAP as Tier 1 information because it regards the RAP as programmatic and, therefore, unnecessary. However, as part of that letter, ABB-CE submitted for staff review, ITAAC Section 3.3, " Design Reliability Assurance Program," a non-system generic Tier 1 requirement (design description) with no associated ITAAC.
In its letter of May 19, 1993, the Nuclear Management and Resources Council (NUMARC) stated that SECY-89-013 predated Commission issuance of the mainte-nance rule (10 CFR 50.65), implementation of which at future plants will encompass the indicated RAP requirements of the earlier SECY. However, NUMARC did agree with the staff that it is appropriate to characterize the RAP for i
ALWRs as consisting of two phases:
D-RAP and 0-RAP. NUMARC further stated that the industry views maintenance rule implementation as the framework for l
reliability assurance activities at future plants and noted that it does not agree with the NRC staff characterization of the 0-RAP as the " umbrella program" that integrates these activities.
In its letter of June 7, 1993, EPRI agreed with the NRC staff position that the RAP can be divided into D-RAP and 0-RAP phases. However, EPRI objected to including the D-RAP in Tier 1 and recommended that the staff close this r
i l
. portion of the RAP issue for both evolutionary and passive designs by endors-ing the current requirements in the URD. Regarding the 0-RAP, EPRI stated that for both evolutionary and passive designs, " life of the plant" relia-bility considerations will be adequately addressed via standardization activities consistent with the industry approach to implementation of the maintenance rule (10 CFR 50.65). EPRI noted that for passive designs, these activities will include performance.and condition monitoring and related requirements for SSCs identified as a result of the RTNSS process.
a Staff Rationale for a Hiah-Level Commitment to a RAP In SECY-93-087, the staff stated that a high-level commitment to a RAP applicable to design certification (D-RAP) should be required as a non-system generic Tier 1 requirement with no associated ITAAC.
The staff believes the RAP requires a high-level commitment to ensure that the aspects of existing programs are integrated and managed so that reliability considerations for risk-significant SSCs are maintained for the entire life of the plant.
Currently, the staff is reconsidering whether this high-level commitment should take the form of a Tier I requirement or as an " applicable regulation" in accordance with SECY-92-287A, " Form and Content of a Design Certification Rule."
Having a high-level commitment to a RAP would establish a performance-based regulatory basis for RAPS without restricting a designer's or licensee's t
ability to manage safety and risk.
Each COL applicant would establish a facility-specific 0-RAP that would satisfy applicable regulatory requirements while utilizing the design certification Tier 2 SSAR RAP as a regulatory guide for developing the details of the program.
Relationshio Between RAP and 10 CFR Part 50. Accendix B The RAP establishes the framework for integrating aspects of existing programs and regulations such as QA (10 CFR Part 50, Appendix B).
Both the RAP and QA are programs that span the ent're life of the plant. Appendix B considers safety-related SSCs and takes a graded approach based on safety-significance.
Likewise, the RAP considers all SSCs and takes a graded approach based on risk significance.
r To ensure regulatory coherence between the RAP and 10 CFR Part 50, Appendix B (for example, during equipment selection and procurement), the criteria for risk-significant SSCs established under the 0-RAP from D-RAP information would t
need to include consideration of Appendix B criteria for procurement control; control of purchased material; identification and control of materials, parts, and components; and handling, storage, and shipping.
Relationshio Between the RAP and the Maintenance Rule (10 CFR 50.65)
The RAP establishes the framework for integrating aspects of existing programs and regulations such as the maintenance rule. To ensure regulatory coherence between the RAP and 10 CFR 50.65, performance goals and criteria for risk-significant SSCs would be established under the 0-RAP, based on information from the D-RAP. Most of the 0-RAP would be based on the requirements of i
s
.. 10 CFR 50.65 and would provide a feedback mechanism for periodically reevalu-ating risk significance on the basis of actual equipment, train, or system performance. The licensee would establish performance and condition monitor-ing requirements for maintaining the reliability of risk-significant SSCs.
The staff and the Advisory Committee on Reactor Safeguards (ACRS) discussed the form and content of the ALWR RAP.
In its letter of October 15, 1992, on the proposed guidance for implementing the maintenance rule, the ACRS noted the similarity between the maintenance rule, the license renewal rule, and the RAP. The ACRS stated that the staff should issue consistent guidance on the elements of an acceptable program that will satisfy these three sets of requirements. The staff incorporated the ACRS comments in preparing its position on the RAP.
Relationship Between the RAP and the Utility Recuirements Document The staff found the EPRI D-RAP goals and objectives in the URDs for both evolutionary and passive designs to be consistent with its position on the RAP. The staff documented its review of the EPRI evolutionary plant URD RAP in NUREG-1242, "NRC Review of Electric Power Research Institute's Advanced Light Water Reactor Utility Requirements Document." The staff has resolved all issues pertaining to the passive plant URD and the final safety evaluation report is currently being reviewed by NRR management.
l As discussed above, EPRI agreed with the NRC staff position, as stated in SECY-93-087, that the RAP can be divided into two stages, D-RAP and 0-RAP, but objected to including the D-RAP in Tier 1.
l i
4
STAFF RESPONSE TO COMMISSIONER REMICK'S QUESTIONS ON THE SIMPLIFICATION OF 0FFSITE EMERGENCY PLANNING Schedule for Commission Paper on the Simplification of Emcraency Plannino Reouirements At this time, the staff's schedule for a Commission paper on the simplifica-tion of emergency planning requirements for advanced light water reactors (ALWRs) is primarily dependent on industry initiatives in this area which have not yet been submitted to the staff.
In its letter of May 3,1993, EPRI stated that Industry thoughts on the policy and regulatory aspects [of simpli-fied emergency planning requirements] are being formulated and coordinated with NPOC [ Nuclear Power Oversight Committee] and will be submitted at a later time....A subsequent step for the ALWR Program is to complete, and submit to [the] NRC, a revised ALWR Emergency Planning Optimization Issue paper. The changes to the Optimization Issue paper will be to update the design criteria in accordance with the enclosed URD revision and to provide input to
[the] NRC on policy and regulatory aspects of ALWR emergency planning including, for example, defining a proposed emergency planning concept. We are working to build an industry consensus on these policy aspects and hope that we can have further ALWR-NRC management interaction in the next few months.
We anticipate completing the Optimization Issue paper later this year.
After EPRI submits the Emergency Planning Optimization Issue paper and the staff has had an opportunity to review it, the staff will make a decision on the merits of the proposal.
If the staff agrees that the proposal has merit, it will determine the extent to which the industry proposal would necessitate changes in emergency planning policies and seek Commission guidance on whether and how to change current requirements.
Emeraency Plannina Reouirements for Evolutionary vs. Passive Desians The staff has not received any specific proposals for changing the emergency planning requirements associated with either evolutionary or passive designs.
The. simplified boiling water reactor (SBWR) and AP600 vendors have suggested that the passive designs, by their nature, would provide a basis for the simplification of emergency planning requirements.
Likewise, the advanced boiling water reactors (ABWR) and ABB-CE System 80+ vendors have stated that their designs also provide a basis for the simplification of emergency planning requirements. The staff will respond appropriately to whatever the industry proposes in this regard.
1
. Emeraency Plannina Reouirements vs. the Desian Certification Rule With regard to Commissioner Remick's question about the impact on design certification, the staff does not believe any specific design certification rule would need to be amended if NRC requirements for offsite emergency planning were changed. The only emergency planning-related~ requirements affecting standard designs are,thos'e stemming from the Three-Mile Island action items [10 CFR Part 50.34(f)], which require plants to have technical and operational support centers. The staff expects the requirement for these onsite facilities to be retained, regardless of possible future changes in offsite emergency planning requi.enents.
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DUE: 07/29/93 EDO CONTROL: 0003126 DOC DT: 07/12/93 FINAL REPLY:
Commissioner Remick
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Taylor FOR SIGNATURE OF:
Executive Director DESC:
ROUTING:
REQUEST FURTHER INFO ON SECY-93-087:
- POLICY, Taylor TECHNICAL, AND LICENSING ISSUES PERTAINING TO Sniezek EVOLUTIONARY AND ADVANCED LIGHT-WATER REACTOR Thompson (ALWR) DESIGNS B1aha DATE: 07/12/93 ASSIGNED TO:
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