ML20056H602
| ML20056H602 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rogers, Selin I, The Chairman NRC COMMISSION (OCM) |
| References | |
| NUDOCS 9309100176 | |
| Download: ML20056H602 (28) | |
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g UNITED STATES E
NUCLEAR REGULATORY COMMISSION
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'"j WASHINGTON, D.C. 205554001
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MEMORANDUM T0:
The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
STAFF REQUIREMENTS - BRIEFING ON PROGRESS OF DESIGN CERTIFI-CATION REVIEW AND IMPLEMENTATION, JUNE 2, 1993 (M930602A)
This memorandum responds to the staff requirements memorandum (SRM) of June 24, 1993, in which the Commission asked for additional information on the status of the staff's design certification review of standardized light water reactor designs.
The Commission requested that the staff submit further information on the progress of passive plant testing at the Oregon State University (OSU) low-pressure integral test facility. Westinghouse, OSU, and their subcontrac-tors are in the final stages of facility construction. Current plans call for hot and cold facility shakedown tests to begin in September 1993, and matrix testing activities in support of the AP600 application to begin in Octo-ber 1993. Hatrix testing activities are expected to continue at the OSU facility through January 1994. On July 2, 1993, OSU informed the Commission by letter (Enclosure 1) that the AP600 project might be adversely affected due to OSU's inability to pay the Nuclear Regulatory Commission (NRC) licensing and operating fees. The staff expects that OSU will apply for a licensing fee 1
exemption under 10 CFR 171.11.
The Commission requested that the staff provide details pertaining to the guidance to vendors on design control document (DCD) preparation. The staff is developing guidance on the form and content of a DCD. DCD guidance issues such as the treatment of proprietary.information and secondary references that meet the requirements for publication in the Federal Reaister are being i
resolved between the Office of Nuclear Reactor Regulation. (NRR), the Office of the General Counsel, and the Office of the Federal Register. The staff intends to send a letter to the vendors discussing these issues as a basis for future discussions.
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The Commissioners The Commission requested that the staff submit a description of the code validation and data usage planned for the passive plant testing programs. The staff is developing this response and will submit the requested information to the Commission in the near future.
The Commission requested that the staff submit a copy of the safety evaluation report (SER) chapter dealing with reliability and maintenance.
contains Section 1.6, " Reliability and Availability," and Section 1.8,
" Operability and Maintainability," of the staff's draft final SER on the Electric Power Research Institute's, " Advanced Light Water Reactor Utility Requirements Document - Passive Plant Designs."
Oryndst;nt;i.3 55'J U. Isr/it?
James M. Taylor Executive Director for Operations
Enclosures:
DISTRIBUTION:
As stated Central File PDR EDO R/F JTaylor, 17G21 JSniezek, 17G21 HThompson, 17G21 cc w/ enclosures:
JBl aha, 17G21 TMurley/FMiraglia,12G18 SECY WRussell, 12G18 JPartlow, 12G18 TGody, 12G18 OGC DCrutchfield RBorchardt JNWilson OCA TEssig PShea FHasselberg OPA TGody, Jr.,17G21 BToms PMagnanelli i
NRR Mailroom, 12G18 EDO 9300102 PDST R/F
- SEE PREVIOUS CONCURRENCE OFC:
PM:PDST LA:PDST TECH EDITOR (A)SC:PDST NAME: FHasselberg: pg*
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i DATE: 07/IS/g g 11195 08////93 07/13/93 07/15/93 i
EDO [ DOCUMENT NAME:
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(A)D:PDST i-NAME: JNWilson*
D ru chfield g TEHurley JMT ylor COMMEMO.FWH DATE: 08/10/93 08/[P/93 08//f/93 08 / '/93 1
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,gt;,,fg3yi:07 C503 737 0460 RADIATION CENTER Id OO2 2
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July 2,1993 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
Attention: Docketing and Service Branch
Subject:
FY 1993 Exemption of Non-Profit EducationalInstitutions from Operating and Ocense Fees Ontcog
Dear Sir:
San q,
On June 30,1993, I submitted comments on behalf of Oregon State University (OSU) relating to the NRC's intention to drop the exemption of non-profit educationalinstitutions from NRC FY 1993 licensing and operating fees.
In my earlier comments, I focused primarily on the impact such a change beation cemr Alm would have on the OSU research reactor. While the effect on this facility ccm% Dmo clearly carries the broadest and most serious ramifications, there are other N2 N associated impacts of great importance to OSU and to others which will occur if the reactor has to be shut down. Among these, our staff is most concerned about the difficulties we anticipate will be encountered by the Westinghouse AP-600 project.
At Oregon State University the research reactor is part of a larger institutional facility known as the Radiation Center. In addition to the reactor, which is the largest facility located within the Center, there are a number of other facilities such as radioisotope laboratories, two cobalt-60 irradiators, en x-ray laboratory, instrument calibration facilities,12 gamma ray spectroscopy systems, teaching facilities, and the previously mentioned AP-600 project.
The Radiation Center in the collective sense functions to support and enhance the scientific and technical capabilities of the individual facilities and programs located with its physical boundaries and administrative jurisdiction. However, without the reactor, which is the focal point of the program, the Radiation Center is not a viable facifity. Most of the work conducted at the Radiation Center, and much of the teaching and research conducted by the Department of Nuclear Engineering, evo!ves around the operation of the reactor, and therefore should the reactor be shut down there wit! clearly be a domino effect 7 p, on the other activities located at the Radiation Center.
m.m.zur ru As mentioned above, we are concemed that our likely inability to pay a m.m.cmo
$65.000 annual operating fee will necessitate closing the reactor, which in turn will significantly interfere with the progress of the Westinghouse AP-600 project. The reason for this stems from the reliance of Ibe AP-600 project l
upon administrative, accounting. physical plant, security, and other related j
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07/02<93 17:08 3503 737 0480 RADI ATION CESTER
@ 003 Secretary USt4RC July 2.1993 types cf support provided by the Radiation Center, and upon the professionalinteractions and technical resources of the Nuc! car Engineering department which is located within the Radiation Center and which wi!! also be significantly hurt by the loss of the reactor. To document this, I have attached a cepy of the letter submitted to the NRC by the OSU Nuclear Engineering department head expressing his concerns regarding the intended new fees and their impact upon the OSU reactor and his department.
The Radiation Center has worked very hard to develop and ensure the success of the AP600 project, and we are very pleased with the progress we have made to date.
However, in evaluating the impacts of the proposed new fees we feel that it is only fair to call attention to the fact that the AP-600 program will bjlt neoativelv impacted by the closure of the OSU reactor, if that becomes necessary.
We view this situation as a tragic scenario created by circumstances which are a clear to us and which, quite honestly, seem unnecessary and unproductive. Therefore, I would i
again offer my pfes for reconsideration of the Commission's plan to impose license fees on non-profit educational institutions.
e Thank you for your consideration of these additional comments. I would be pleased to provide further information which might be helpful to you in evaluating the impact of NRC fees on our program.
Yours sincerely, h%r A. G. Jothson Director dt.sgVret93 fees-1.e me Ivan Selin, Chairman, USNRC, Wash:ngton, DC 20555 cc:
Kenneth C. Rogers, Commissioner. USNRC, Washington, DC 20555 i
James R. Cuniss, Commissioner, USNRC, Washington, DC 20555 Fonest J. Remick, Commissioner, USNRC, Washington, DC 20555 Gail de Planque, Commissioner, USNRC, Washington, DC 20555 William G. Vernetson. Chairman, TRTR David Stewart-Smith, Oregon Dept. of Energy George Keller, Vice President for Research, Graduate Studies, and international Programs Alan H. Robinson, Head. Dept. of Nuclear Engineering
'l Brian Dodd. Reactor Administrator Jack Higginbotham, Sr. Health Physicist l
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DRAFT 6
RELIABILITY AND AVAILABILITY Section 6 of Chapter 1 of the passive Requirements Document gives reliability l
and availability requirements for a design reliability assurance program
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(D-RAP). The EPRI D-RAP encompa,sses structures, systems, and components j
(SSCs) whose reliability has a significant effect on core damage frequency or l
whose reliability has a significant effect on challenges to emergency core cooling systems or plant availability for power production.
- Section 6.1
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addresses design reliability assurance program (D-RAP) goals and objectives.
Section 6.2 includes the basic program elements of the D-RAP. Section 6.3
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addresses the D-RAP performance standards. Section 6.4 discusses the aspects
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of systems design.
Review Criteria i
The need for a safety-oriented reliability effort for the nuclear industry was l
identified by the NRC in the Three Mile Island (TMI) Action Plan (NUREG-0660)
Item II.C.4.
Subsequently, initial NRC research in the area of reliability I
assurance began in the early 1980s. The results of this research showed that l
an operational reliability program based on a feedback process, of monitoring performance, identifying problems, taking corrective action, and verifying effectiveness of the actions was needed and that other NRC initiatives (e.g.,
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maintenance inspection, performance indicators, aging programs, and. technical
-1 specification (TS) improvement) would address this need. The NRC concluded i
from this research that an operational reliability program could be 3
implemented most effectively in performance-based, non-prescriptive regulation, where NRC mandates the level of safety performance to be achieved.
For example, licensees could be required to set availability / reliability il targets for selected systems and to measure performance compared to the targets. The TMI item was closed out in October 1988, without further action i
because of several NRC initiatives that effectively subsumed the operational l
reliability program effort. These initiatives included efforts to (I) improve maintenance and better manage the effects of aging, (2) improve technical DRAFT i
EPRI Passive Plant SER 1.6-1 July 1993 l
DRAFT specifications, (3) develop and use plant performance indicators, and i
(4) develop an operational reliability program as an acceptable means of meeting the station blackout rule (10 CFR 50.63).
NURLG-1070, *NRC Policy on Future Reactor Designs," included the concept of a systems reliability program to ensure that the reliability of components and systems important to safety would remain at a sufficient level. To ensure tlat reliability objectives are met and to prevent degradation of reliability during operation, the NRC envisicned that the 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 a few specific instances, the NRC is studying or has established reli-ability targets for systems and components.
For example, Standard Review Plan (SRP) Section 10.4.9 requires that an acceptable auxiliary feedwater system design should have an unreliability in the range of 10E-4 to 10E-5 per demand.
The resolution of Generic Issue B-56 involves efforts to determine, monitor, and maintain emergency diesel generator reliability levels. Additional regulatory bases for key elements of a RAP can be found in 10 CFR Part 50, Appendices A and B, and 10 CFR 50.65.
In SECY-89-13, " Design Requirements Related to the Evolutionary Advanced Light Water Reactors," dated January 19, 1989, the staff identified several issues for advanced light water reactors (ALWRs) that go beyond present acceptance criteria defined in the SRP. RAP, as one of these issues, was defined as a program to ensure that the design reliability of safety significant SSCs is maintained over the life of a plant.
In SECY-89-13, the staff infomed the Comission that RAP would be required for ALWR final design approval / design certification (FDA/DC).
In November 1989, potential applicants for design certification were informed by letter that "the NRC staff was considering matters that went beyond the current SRP... that [the NRC) expects these advanced reactor designs to embody." Reliability assurance was identified as one of these matters.
DRAFT EPRI Passive Plant SER 1.6-2 July 1993
DRAFT The RAP consists of two distinct parts:
(1) design RAP (D-RAP) and (2) opera-tional RAP (0-RAP). D-RAP involves a top-level program at the design stage that defines the scope, conceptual framework, and essential elements of an t
effective RAP. D-RAP also implements those aspects of the program that are applicable to the design process.
In addition, D-RAP identifies the relevant aspects of plant operation, maintenance, and performance monitoring for the risk-significant SSCs for the owner / operator's consideration in developing the site-specific 0-RAP. The 0-RAP tracks equipment reliability to demonstrate that a plant is being operated and maintained consistent with PRA assumptions so that overall risk is not unknowingly degraded and ensures regulatory coherence between the RAP and the maintenance rule (10 CFR 50.65).
The staff's position on RAP is that a designer's submittal for design certifi-cation pursuant to 10 CFR Part 52 would include, in part, the framework for a RAP and also would implement those elements of the RAP that would be appli-cable during the design phase [ Tier 1 Generic requirement).
In turn, the designer would provide the framework of a RAP to a combined operating license (COL) applicant. The COL applicant would augment the designer's RAP to reflect plant-specific information and implement those elements applicable during the construction and operation phases. The staff's evaluation was based on guidance contained in the supporting documentation for THI Item II.C.4 and SECY 89-013.
Scope of Evaluation Section 6 of Chapter 1 of Volume III of the EPRI passive Requirements Document addresses EPRI-proposed requirements for reliability and availability and provides the supporting rationale for each requirement.
In its evaluation, the staff considered the EPRI-proposed requirements as well as the accompany-ing rationale of the passive Requirements Document through Revision 4.
In making a safety determination, the staff applied the same acceptance criteria to both the EPRI-proposed requirements and the corresponding rationale.
If an i
EPRI-proposed requirement and its rationale were responsive to the staff's questions by including sufficient information to satisfy the applicable RAI and DSER items, and did not conflict with existing NRC requirements, the staff found that particular EPRI-proposed requirement and rationale acceptable.
i DRAFT EPRI Passive Plant SER 1.6-3 Duly 1993 l
DRAFT The passive Requirements Document primarily addresses D-RAP requirements; only a limited number of requirements in the passive Requirements Document apply to 0-RAP. The 0-RAP requirements will need to be provided by an individual applicant for a combined license.
The staff limited its evaluation to only those requirements that could affect plant safety.
For example, the staff did not evaluate the merits of economic considerations such as EPRI's plant availability and outage duration goals that are specified in the passive Requirements Document.
I' did, however, t
evaluate the general relationship between safety and economic requirements.
The staff's evaluation of EPRI's requirements resulted in two types of findings:
(1) requirements that are acceptable as written and (2) those that are acceptable, but a COL applicant will be required to provide additional information or guidance.
For requirements of the second type, the staff has provided clarification regarding what additional information a plant designer or a COL applicant should provide when making a submittal that references the passive Requirements Document.
EPRI developed virtually identical requirements for a RAP in Chapter 1, Section 6, of the evolutionary and passive Requirements Document (Volumes II and III, respectively). The staff has treated these proposed reliability assurance programs / requirements uniformly, resulting in comments and issues that are applicable to both. Simultaneous reviews of the RAP for both the evolutionary and passive plants ensure that open issues are uniformly resolved and that NRC comments are consistent for the two programs.
t On October 10, 1991, in separate correspondence, the staff transmitted its draft safety evaluation report (DSER) for the evolu= onary Requirements Document and a request for additional information (PM) for the passive Requirements Document. While specific questions differed somewhat, the information requested was basically the same. Subsequently, on January 9, 1992, EPRI replied to both letters with virtually identical revisions to Section 6 of Chapter 1 of the evolutionary and passive Requirements Document.
DRAFT EPRI Passive Plant SER 1.6-4 July 1993
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DRAFT i
In its RAI for the passive Requirements Document, the staff stated that the EPRI-proposed requirements should (1) describe the basic reliability framework of a RAP including the basic definitions, definition of program elements, and a description how the elements would be applied to the plant SSCs (RAI Question 1); (2) describe the guidance a designer would use to develop the basic framework of a RAP (RAI Q.2); (3) describe how RAP goals, targets, and requirements link to the more specific parts of the program described in other parts of the EPRI document (RAI Q 3); (4) provide clarification of the requinment to develoo a RAP for safety-related risk-critical SSCs and to Jg;% ment a RAP for non-safety-related risk-critical SSCs (RAI Q 4); (5) i describe how RAP addresses plant aging concerns (RAI Q 5); (6) providt etails d
on an approach for providing feedback to the designer when actual plad.
perform..we data consistently differs from the designers PRA/ RAP assumptions 4
(RAI Q 6); (7) provide information on how a dc ;gner might establish a RAP and how it might function throughout plant life ILI Q 7); (8) provide information on the interfaces between RAP and the wjsr programs (RAI Q 8); and i
(9) describe how a RAP will aid in achieving and maintaining reliability for l
SSCs important to safety (RAI Q 9).
In its response of January 9,1992, EPRI updated Section 6 of Chapter 1 of the passive Requirements Document to address l
the staff's RAI questions.
In its lettet, of April 24, 1992, the staff transmitted its DSER for Vol-ume III of the passive Requirements Document, stating that the EPRI-proposed requirements for RAP should (1) contain and define the basic framework (scope, purpose, and objective), the program elements, and describe how the elements f
would be applied to the plant structures, systems, and equipment (DSER Open Issue P.I.0-12); (2) contain overall reliability and availability design goals j
based o. safety requirements that have associated with them core-damage freqma les or probabilities (DSER Open Issue P.I.0-13); (3) contain reliabil-
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ity engmeering techniques used during the design phase to ensure that overall design reliability and availability goals are met (DSER Open Issue P.I.0-14);
(4) specify the connection of the system requirements to overall safety, reliability, and availability goals (DSER Open Issue P.I.0-15); and (5) specify the rational for the designer to develop a reliability program for DRAFT EPRI Passive Plc ; SER 1.6-5 July 1993
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DRAFT 1
safety-related systems and to imolement a reliability program for non-safety-related systems (DSER Open Issue P.I.0-16).
These open issues superseded the J
RAI questions raised by the staff on October 10, 1991.
The staff also stated in its DSER that by themselves the EPRI reliability and i
availability requirements do not provide sufficient information for the staff to determine if the ALWR design referencing these requirements will adequately incorporate RAP considerations in a manner that will ensure plant safety and reliability (DSER Vendor Item P.I.V-61).
f HUREG 1242 listed reliability assurance as open issues for both evolutionary end passive plants (policy issue numbers E.1B.0-12 and P.18.0-61 respec-
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tively). These policy issues were described in Section II.M of SECY-93-087, i
" Policy, Technical, and Licensing Issues Pertaining to Evolutionary anu Advanced Light-Water Reactor (ALWR) Designs," dated April 2, 1993. Therefore, the only open policy issue for the reliability assurance program for pastive
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plants is captured by P.18.0-61. The staff concluded that pending Commission resolution of the policy issue for RAP, DSER Open Iss"a P.15.0-61 will remain open.
In response to the RAI Q and OSER upen Issues, EPRI made significant changes to Chapter 1, Section 6.
The changes proposed by EPRI to Chapter 1, Section 6
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satisfactorily answered all nine RAI question Necifically, the staff i
determined that (1) RAI Qs I and 2 were answei w y Sections 6.1 and 6.2; f
(2) RAI Q 3 was answered by Sections 6.3 and 6.4; (3) RAI Q 4 is no longer j
applicable since the Section 6 format was revised by the January 9,1991, EPRI
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submittal which does not differentiate between safety and non-safety related SSCs and RAI Q 4 is considered closed; (4) RAI Q 5 was answered by Sec-tions 6. E ud 6.4; (5) RAI Qs 6, 7, and 9 were answered by Sections 6.2; and (6) RAI tr 8 was answered by Section 6.4.
The details of the staff's evalua-i tion are presented in Sections 6.1 through 6.4 below.
7 Additionally, the changes proposed by EPRI to Chapter 1, Section 6 satis-factorily resolved all five DSER open issues. Open Issues P.I.0-12 through f
P.I.0-14 and P.I.0-16 are closed. DSER Open Issue ' l.0-15 is Confirmatory j
issue P.I.0-15.
Specifically, the staff determined that (1) DSER Open DRAFT EPRI Passive Plant SER 1.6-6 July 1993 l
r DRAFT
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l Issue P.I.0-12 was resolved by Sections 6.1 and 6.2; (2) DSER Open Issue a
P.I.0-13 were resolved by Section 6.2; (3) DSER Open Issue P.I.0-14 was l
resolved by Sections 6.2, 6.3, and 6.4; (4) DSER Open Issue P.I.0-16 is no i
longer applicable since the Section 6 format was revised by the January 9, j
1991, EPRI submittal which does not differentiate between safety and non-safety related SSCs and DSER Open Issue P.I.0-16 is considered resolved; and (S) DSER Open Issue P.I.0-15 was resolved by the markups to Section 6.3 of f
Revision 4, submitted on February 23, 1993 and March 2, 1993, and is cor.sid-I ered confirmatory. The details of the staff's evaluation are presented in Sections 6.1 through 6.4 below.
l 6.1 D-RAP Goals and Obiectives i
Section 6.1 of Chapter 1 of the passive Requirements Document contains the j
D-RAP goals and objectives. A portion of RAI Q l requested EPRI to describe the basic reliability framework (scope, purpose, and objective) of a RAP. The D-RAP goals and objectives provided in Section 6.1 answered that portion of j
RAI Q l.
The remainder of RAI Question I was answered by Section *.2.
RAI Q 2 requested EFEI to describe the guidance a designer would use to develop the basic framework of a RAP. The D-RAP goals and objectives provided in Sec-I tion 6.1 answered that portion of RAI Q 2.
The remainder of RAI Q 2 was i
answered by Section 6.2.
A portion of DSER Open Issue P.I.0-12 requested EPRI I
to define the basic framework (scope, purpose, and objective) of a RAP. The D-RAP goals and objectives provided in Section 6.1 resolved that portion of l
DSER Open Issue P.I.0-12.
The remaind r of DSER Open Issue P.I.0-12 was I
resolved by Section 6.2.
The staff reviewed the EPRI-proposed requirements in Section 6.1 and concluded that they are responsive to the staff's inquiries by l
including sufficient information to satisfy the applicable RAI and DSER open items, do not conflict with any NRC requirements, and are therefore accept-l able.
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DRAFT EPRI Passive Plant SER 1.6-7 July 1993
DRAFT 6.2 Basic Prooram Elements of the D-RAP Section 6.2 of Chapter 1 of the passive Requirements Document describes the basic program elements the staff required to be included in the D-RAP. A portion of RAI Q1 requested EPRI to describe the basic definitions of program elements and a description of hqw the elements would be applied to the plant SSCs. The basic RAP program elements provided in Section 6.2 satisfactorily answeted that portion of RAI Ql. The remainder of RAI Q1 was answered by Section 6.1.
RAI Q2 requested EPRI to describe the guidanc'e a designer would use to develop the basic framework of a RAP. The basic RAP program elements provided in Section 6.2 satisfactorily answered that portion of RAI Q2. The remainder of RAI Q2 was answered by Section 6.1.
RAI QS requested EPRI to describe how RAP addresses plant aging concerns. The reliability activity task descriptions provided in Section 6.2.4 satisfactorily answered that portion of RAI Q5. The remainder of RAI Q5 was answered by Section 6.4.
RAI Q6 requested EPRI to provide details on an approach for providing feedback to the designer when actual plant performance data consistently differs from the designers PRA/ RAP assumptions. The analysis requirements, application of risk significance, reliability activity task descriptions, and control of PRA design assumption provided in Section 6.2 satisfactorily answered RAI Q6.
RAI Q7 requested EPRI to provide information on how a designer might establish a RAP and how it might function throughout plant life. The analysis require-ments, reliability activity task descriptions, and control of PRA oesign assumption provided in Section 6.2 satisfactorily answered RAI Q6.
PAI Q7 requested EPRI to provide information on how a designer might establish a RAP and how it might function throughout plant life. The analysis requirements, reliability task descriptions, and control of PRA design assumptions provided in Section 6.2 satisfactory answered RAI Q7. RAI Q9 requested EPRI to describe how a RAP will aid in achieving and maintaining reliability for SSCs important to safety.
The analysis requirements, application of risk signifi-cance, reliability activity task descriptions, and control of PRA design assumption provided in Section 6.2 satisfactorily answered RAI Q9.
DRAFT EPRI Passive Plant SER 1.6-8 July 1993
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DRAFT L'
l A portion of DSER Open Issue P.I.0-12 requested EPRI to define the RAP program elements, and describe how the elements would be applied to the plant struc-tures, systems, and equipment. The basic program elements and how they apply to the plant structures, systems, and equipment provided in Section 6.2 satisfactorily resolved that portion of DSER Open Issue P.I.0-12.
The remainder of DSER Open Issue P.I.0-12 was satisfactorily resolved by Sec-tions 6.1.
DSER Open Issue P.1.0-13 requested EPRI to provide the overall reliability and availability design goals based on safety requirements that have associated with them core-damage frequencies or probabilities. The l
analysis requirements, reliability activity task descriptions, and control of PRA design assumption provided in Section 6.2 satisfactori h resolved DSER I
Open Issue P.I.0-13.
DSER Open Issue P.1.0-14 requested EPRI to provide the reliability engineering techniques used during the design phase to ensure that overall design reliability and availability goals are met. The basic program i
elements including analysis requirements, reliability activity task descrip-tions, and control of PRA design assumption provided in Section 6.2 satisfac-torily resolved that portion of DSER Open Issue P.I.0-14.
The remainder of DSER Open Issue P.I.0-14 was satisfactorily resolved by Sections 6.3 and 6.4.
l The staff reviewed the EPRI-proposed requirements in Section 6.2 and concluded that they are responsive to the staff's questions by including sufficient information to satisfy the applicable RAI and DSER items, do not conflict with any HRC requirements, and are therefore acceptable. The staff's detailed i
evaluation of Section 6.2 is given below.
Analysis Reauirements l
Section 6.2.1 of Chapter 1 requires an analysis that shows the adequacy of the i
plant system designs and the recommended maintenance activities, spare parts, surveillance tests, and test intervals consistent with the SSC reliability and availability assumptions of the probabilistic risk assessment (PRA).
- Further, the reliability and availability analyses will be carried out as an integral part of the design process to influence the design options and allow appropri-I ate cost / benefit tradeoffs during the design of the standard AWR plant. The passive Requirements Document requires that this analysis be performed by the plant designer sufficiently ahead of procurement and construction to minimize i
the impact of potential design changes and ensure that SSC reliability DRAFT 993 EPRI Passive Plant SER 1.6-9 July
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DRAFT l
assumptions'are met. The staff concluded that these requirements are respon-I sive to the staff's questions by including sufficient information to satisfy i
the applicable RAI and DSER items, do not conflict with existing NRC require-ments, and are therefore acceptable. The staff also concluded that, in addition to PRA methodology, deterministic or other methods may be used for making decisions about the adequacy of plant system designs. Furthermore, the staff encourages a vendor or COL applicant to include references to the
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analytical methods or models that were used in performing the analyses required by this section in the top-level RAP program document. As an example, Section 3.5.4 of Chapter 10 of the passive Requirements Document describes analytical methods for.the man-machine interface systems (M-MIS) i design. The staff concluded that these or similar methods should be used for i
all reliability and maintainability analyses performed by the plant designer
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or COL applicant. The staff will evaluate this issue during its review of an individual applict. tion for FDA/DC or a COL.
.h Desion Oroanization Interface Section 6.2.1.8 of Chapter 1 requires the plant designer to identify the design organization responsible for coordinating D-RAP activities with the plant owners organization and the formal communication channels for resolution of D-RAP issues. The staff concluded that, in addition to the EPRI require-ments in this section, a plant designer and a COL applicant should provide the 4
organizational description and specify organizational accountability for implementing the D-RAP. As an example, Section 3.1.2 of Chapter 10 of the passive Requirements Document, "M-MIS Design Organization and Plan," specifies requirements that should ensure that the M-MIS design is coordinated and implemented properly. An application for FDA/DC and a COL should contain an organizational description and accountability for RAP in similar depth and detail as that contained in Section 3.1.2 of Chapter 10 of the passive Requirements Document. The staff will evaluate this description during its review of an individual application for FDA/DC and a COL.
DRAFT r
i EPRI Passive Plant SER 1.6-10 July 1993
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DRAFT Acolication of Risk Sionificance Section 6.2.2 of Chapter I requires the plant designer to ensure that the dominant modes of failure identified by the PRA are appropriately addressed in the plant design consistent with their risk significance.
This section further states that the PRA methodology used by the plant designer will provide for importance-weighting of SSCs according to their risk significance i
and for identifying the dominant failure modes of these SSCs.
The staff I
concluded that these requirements are responsive to the staff's questions by including sufficient information to satisfy the applicable RAI and DSER items, do not conflict with existing NRC requirements, and are therefore acceptable.
The staff further concluded that, in addition to PRA methodology, determin-istic or other methods may be used in establishing dominant failure modes and risk significance for the RAP. As discussed above, the staff will evaluate this issue during its review of an individual application for FDA/DC or a COL.
Plant Reliability Data System Enoineerino Data Base
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Section 6.2.3 of Chapter I requires the plant designer to supply the initial input information necessary to establish an engineering data base for all SSCs considered to be candidates for the D-RAP. The engineering data base shall provide sufficient engineering data for D-RAP implementation.
The engineering
- t data shall be provided in a format that allows direct input into the data base without editing, translating, or other manual processing of the data. The staff concluded that the EPRI-proposed requirements are responsive to the staff's questions by including sufficient information to satisfy the applica-ble RAI and DSER items, do not conflict with existing NRC requirements, and are therefore acceptable. The staff will evaluate the actual data bases during its review of an individual application for FDA/DC or a COL.
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8 peliability Activity Task Descriptions Section 6.2.4 of Chapter I requires the plant designer to provide the owner /
operator with descriptions of recommended reliability activities. These activities will include those tasks necessary to maintain SSC environmental i
DRAFT EPRI Passive Plant SER 1.6-11 July 1993
DRAFT qualification, prevent predictable failures, or maintain functional reliabil-ity. The plant designer will also recommend appropriate condition monitoring parameters to be periodically evaluated and their acceptable limits to provide added assurance of operability. Condition monitoring recommendations will include provisions for detecting age-related degradation where appropriate.
The staff concluded the requirements of this section are responsive to the j
staff's questions by including sufficient information to satisfy the appli-cable RAI and DSER items, do not conflict with existing NRC requirements, and are therefore acceptable.
l 4
i Control of PRA Desion Assumptions l
Section 6.2.5 of Chapter I rcquires the plant designer to provide a program for verifying that PRA assumptions remain within limits required to maintain reliability goals during the design and construction process. This program will apply to all participants in the design and construction process whose activities could affect the plant designer's PRA assumptions. The passive Requirements Document further states that the results of the verification program will be included as part of the final as-built design documentation.
The staff concluded the requirements of this section are responsive to the staff's questions by including sufficient information to satisfy the appli-cable RAI and DSER items, do not conflict with existing NRC requirements, and are therefore acceptable.
6.3 D-rap Performance Standards Section 6.3 of Chapter 1 of the passive Requirements Document contains the quantitative reliability and availability performance standards for use in the design phase. RAI Q 3 requested EPRI to describe how RAP goals, targets, and requirements link to the more specific parts of the program described in other parts of the EPRI document. The quantitative reliability and availability performance standards for use in the design phase provided in Section 6.3 satisfactorily answered that portion of RAI Q 3.
The remainder of RAI Q 3 was satisfactorily answered by Section 6.4.
DSER Open Issue P.1.0-14 requested EPRI to provide the reliability engineering techniques used during the design phase to ensure that overall design reliability and availability goals are l
DRAFT EPRI Passive Plant SER 1.6-12 July 1993 i
l DRAFT met. The quantitative reliability and availability performance standards for use in the design phase provided in Section 6.3 satisfactorily resolved that portion of DSER Open Issue P.].0-14.
The remainder of DSER Open Issue P.1.0-14 was resolved by Sect ;ns 6.2 and 6.4.
The clarification statement in the markup to Revision 4 of Section 6.3 that indicates the design features in that section shall be consistent with ALWR core damage frequency and conse-quences goals, satisfactorily resolved DSER Open Issue P.I.0-15.
This issue is Confirmatory Issue P.1.0-15.
The staff's evaluation of the sub-sections of l
Section 6.3 that address plant availability and outage durations as they effect economic considerations, only considers the general relationship between safety and economic requirements.
Core Damace FrecuenCY Section 6.3.1 of Chapter 1 states that the plant designer will evaluate the mean annual core damage frequency of the design using PRA and will confirm that this frequency is less than or equal to 10E-5 event per reactor-year, including both internal and external events (excluding sabotage).
In Sec-tion 2.3.3 of this chapter, the staff discussed EPRI's public safety goal and concluded that the use of this goal is acceptable. However, the staff will not use EPRI's public safety goal as an acceptance criterion.
The staff concluded that the contributions of the SSCs to the core damage frequency should be apportioned for this, or any other, performance standard.
Therefore, the applicant's submittal for FDA/DC should include apportionment of these contributions to the core damage frequency. The staff will evaluate the adequacy of the apportionment of the SSCs' contribution to core damage frequency during its review of an individual application for FDA/DC.
Inadvertent Deoressurization I
Section 6.3.2 of Chapter 1 states that r.on-safety-related active reactor coolant system (RCS) makeup capability and any other necessary measures will be provided so that the chance of inadvertent RCS depressurization can be demonstrated by reliability analysis to be less than 10 percent over the
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i entire 60-year life of the plant. Further, recovery from inadvertent RCS DRAFT l
EPRI Passive Plant SER 1.6-13 July 1993
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DRAFT depressurization will be rapid enough that the lifetime average design availability requirements can still be met assuming one inadvertent RCS depressurization during the 60-year plant life.
The staff notes that refer-ring to the active RCS makeup capability as non-safety related is inconsistent with risk-significant concepts in Section 6.2.2 of Chapter 1 of the passive Requirements Document. However,.the staff concluded that these requirements
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do not conflict with existing NRC requirements and are, therefore, acceptable.
Station Blackout Section 6.3.3 of Chapter I states the plant designer shall provide design features to assure that the frequency of station blackouts exceeding 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> duration can be demonstrated by PRA methods to have an expected frequency of i
less than 10E-3 events per reactor year.
The staff concluded the requirements of this section of the passive Requirements Document do not conflict with regulatory requirements and are, therefore, acceptable.
Trio Freauency Section 6.3.4 of Chapter 1 states the plant designer shall perform an evalua-tion of potential system failures that will result in reactor trips which show the expected trip frequency to be less than one per year. Because human errors cause a large fraction of reactor trips, emphasis shall be placed on the human factors aspects of operation and surveillance testing. The staff
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concluded the requirements of this section of the passive Requirements Document do not conflict with regulatory requirements and are, therefore, acceptable.
Production Availability Reauirement Section 6.3.5 of Chapter 1 states the plant will be designed for an annual average production availability of more than 87 percent over its life. The staff's review of this requirement was limited to areas where economic considerations c:,uld potentially compromise plant safety. The staff concluded that this requirement does not conflict with existing NRC requirements and is, therefore, acceptable.
DRAFT EPRI Passive Plant SER 1.6-14 July 1993 l
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Forced Outaces I
Section 6.3.6 of Chapter 1 states the plant shall be designed so that the frequency and duration for forced outages does not exceed 5 days per year.
f The staff's review of this requirement was limited to areas where economic considerations could potentially compromise plant safety. The staff concluded that this requirement does not conflict with existing NRC requirements and is, therefore, acceptable.
Refuelino Duration Capability t
Section 6.3.7 of Chapter I states that the plant will be designed so that the total duration of a no-problem refueling outage will be 17 days or less (breaker to breaker) assuming 24-hour productive days. The staff's review of this requirement was limited to areas where economic considerations could potentially compromise plant safety. The staff concluded that this require-ment does not conflict with existing NRC requirements and is, therefore, i
acceptable.
Planned Outaces a
Section 6.3.8 of Chapter I states that the plant will be designed so that l
refueling and regular maintenance will be completed in an average of less than i
25 days per year. An average of 25 days per year for refueling and plant maintenance corresponds to 50 days in a 24-month fuel cycle. The staff's review of this requirement was limited to areas where economic considerations could potentially compromise plant safety. The staff concluded that this requirement does not conflict with existing NRC requirements and is there-fore, acceptable.
i Maior Outaoes i
Section 6.3.9 o' Chapter I states that the plant will be designed so that the frequency and duration of major outages will not exceed 180 days per 10 years.
The staff's review of this requirement was limited to areas where economic DRAFT EPRI Passive Plant SER 1.6-15 July 1993
i DRAFT l
considerations could potentially compromise plant safety. The staff concluded that this requirement does not conflict with existing NRC requirements and is, therefore, acceptable.
6.4 System Desion Section 6.4 of Chapter I of the passive Requirements Document describes the qualitative processes to be used in system design.
describe how RAP goals, targets and requirements link to th' niore specific e
parts of the system design program described in other parts of the EPRI document. The qualitative processes to be used in system design provided in i
Section 6.4 satisfactorily answered that portion of RAI Q 3.
The remainder of RAI Q 3 was satisfactorily answered by Section 6.3.
RAI Q 5 requested EPRI to describe how RAP addresses plant aging concerns. The qualitative processes to be used in system design provided in Section 6.4 satisfactorily answered that portion of RAI Q 5.
The remainder of RAI Q 5 was satisfactorily answered by Section 6.2.
RAI Q 8 requested EPRI to provide information on the interfaces between RAP and the major programs. The qualitative processes to be used in system design provided in Section 6.4 satisfactorily answered RAI Q 8.
DSER Open Issue P.' G-14 requested EPRI to provide the reliability engineering techniques used during the design phase to ensure that overall design reli-ability and availability goals are met. The qualitative processes to be used in system design provided in Section 6.4 satisfactorily resolved that portion of DSER Open Issue P.I.0-14.
The remainder of DSER Open Issue P.I.0-14 was satisfactorily resolved by Sections 6.2 and 6.3.
The staff reviewed the EPRI-proposed requirements in Section 6.4 and concluded that they are responsive to the staff's questions by including sufficient information to satisfy the applicable RAI and DSER items, do not conflict with any NRC requirements, and f
are, therefore, acceptable. The staff's detailed evaluation is given below.
Shared Systems Section 6.4.1 of Chapter I requires that, for multiple-unit plants on a single i
site, the number of shared systems will be limited to auxiliary support systems such as sewer, auxiliary steam, or site security.
For any systems that are shared, the plant designer or COL applicant will analyze the effect DRAFT EPRI Passive Plant SER 1.6-16 July 1993 t
DRAFT of any failure or any testing in that system that will affect the maintenance, ALARA (as low as is reasonably achievable) goals, availability, safety, or l
operability of other systems and the availability of each unit. The staff concludes that these requirements do not conflict with existing NRC require-ments and are, therefore, acceptable.
Startup and Testino Section 6.4.2 of Chapter I requires that the plant designer' or COL applicant review and optimize the startup testing program for initial startup and for startup following refueling / maintenance outages to support completion of required testing with a minimum impact on the availability of the plant. As a basis for this review and optimization, the plant designer will review existing LWR startup test programs and any available reports on optimization of these test programs. The staff concluded that these requirements do not conflict with existing NRC requirements and are, therefore, acceptable.
Failure Mechanisms Section 6.4.3 of Chapter I states that the plant designer will ensure that the systems, equipment, and plant design will account for failure mechanisms shown to have a significant effect on downtime. This section further states the ALWR will be designed so that known failure mechanisms will not prevent the ALWR from achieving its design life or meeting the availability and event frequencies as described in Section 6.3 of Chapter 1.
The staff concluded that these requirements do not conflict with existing NRC requirements and are, therefore, acceptable.
Specific System Desion Features Section 6.4.4 of Chapter 1 states that the plant designer will incorporate design features to support high reliability of safety-significant SSCs and high plant availability. The staff concluded that this requirement does not conflict with existing NRC requirements and is, therefore, acceptable.
DRAFT EPRI Passive Plant SER 1.6-17 July 1993
4 DRAFT Minimum Number of Components 1
Section 6.4.5 of Chapter 1 states that the plant designer will reduce the number of active components required to meet the intended function ~of opera-bility and reliability. The staff concluded that this requirement does not conflict with existing NRC requi.rements and is, therefore, acceptable.
i 6.5 Conclusion The staff's overall conclusion is that, the requirements in Section 6 of Chapter 1 of the passive Requirements Document are directed at the plant designer and the D-RAP and very few requirements are directed toward the procurement, construction, and operational phases, which are the respons-ibility of the combined operating license applicant. Additional guidance and requirements will be necessary to support tha completion of a COL applicant's D-PAP (site specific design information) and for the development of a COL applicant's 0-RAP.
The staff concluded that the reliability and availability requirements in the passive Requirements Document are consistent with accepted industry practices and principles, are responsive to the staff's questions by including 'suffi-cient information to satisfy the applicable RAI and DSER items, and do not conflict with existing regulatory requirements and guidelines. Therefore, they are acceptable.
j However, by themselves, the reliability and availability requirements do not provide sufficient infornation for the staff to determine if the ALWR design i
referencing the EPRI requirements will adequately incorporate RAP consider-ations in a manner that will ensure plant safety and reliability. Therefore, applicants referencing the passive Requirements Document will be required to provide sufficient information to demonstrate that their RAP will result in a plant that is designed and will perform in a manner that will ensure plant 4
safety and reliability.
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EPRI Passive Plant SER 1.6.18 July 1993
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8 OPERABILITY AND MAINTAINABILITY 8.I Introduction i
In Section 8 of Chapter 1 of the passive Requirements Document, EPRI proposes requirements that are meant to enhance the operability and maintainability of the ALWR by incorporating experience gained at operating facilities. These requirements are intended to minimize the need for maintenance and surveil-i lance, thereby minimizing the dose of radioactivity to plant personnel.
Included are general design criteria for the control room and other control l
locations and criteria for designing the instrument and control systems and i
j factoring in man-machine interface considerations.
8.2 Provisions To Enhance Operability and Maintainability I
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In Section 8.2 of Chapter 1 of the passive Requirements Document, EPRI l
proposes requirements regarding resolution of known operational and mainte-nance problems, standardization of operating and maintenance procedures and l
related training, and standardization of components and equipment. This i
section also gives human factors requirements that are related to the opera-tion of the plant, including consideration of instrumentation and controls, control room design, and environmental conditions.
In addition, EPRI provides requirements to address human factors that are related to maintenance of the plant, including support systems, accessways, and orientation of equipment.
EPRI specifies requirements to integrate operations and maintenance require-i l
ments and addresses preventive maintenance and inspection concerns. Sec-tion 8.2 specifies requirements for the qualifications, organizations, and I
training of operations and maintenance personnel.
Radiation Exoosure i
To reduce worker radiation exposure, EPRI states that temperature and humidity in radiation areas where work is to be performed will be maintained at a level required for worker efficiency. All plant areas will be adequately illumi-nated to minimize the time and expesure associated with the installation of DRAFT EPRI Passive Plant SER 1.8-1 July 1993
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DRAFT I
temporary lighting in work areas. To reduce worker doses, equipment will be oriented to facilitate maintenance operations. These provisions are intended
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to maintain worker doses as low as reasonably achievable (ALARA) and, there-ferc, are acceptable.
Personnel Oualification In Section 8 of the DSER dated September 1987 for of Chapter 1 of the Require-ments Document for evolutionary plants, the staff stated its concern that EPRI had indicated that it would add a statement to the Requirements Document i
regarding the qualification of plant operating personnel.
Section 8.2.6.5 of Chapter 1 of the passive Requirements Document indicates that these personnel will meet the requirements of ANSI /ANS 3.1, " Selection, Qualification and Training for Nuclear Power Plants." The staff concludes that this is consis-tent with the regulatory guidance in SRP Sections 13.2.1 and 13.2.2 and is, therefore, acceptable.
t Personnel and Staffino 1
In its letter dated May 5,1991, EPRI stated that qualification and training reautr*.ments of the plant operating personnel are the responsibility of the r. ant owner and are outside the scope of the passive Requirements Docu-ment. Section 8.2.6.5 of Chapter 1 includes a requirement that the plant l
operating organization be staffed by personnel who meet the requirements of ANSI /ANS 3.1.
Since ANSI /ANS 3.1 excludes the selection and training of site security personnel, the staff concludes that there are no conflicts with the y
security training requirements of 10 CFR 73.55(b).
Human Factors Considerations i
in Section 8.2.B.4 of the DSER for Chapter I of the passive Requirements Document for evolutionary plants, the staff recommended that IEEE-P1023/D5,
" Guide for the Application of Human factors Engineering to Systems, Equipment, and Facilities of Nuclear Power Generating Stations," and EPRI-2360, " Human Factors Methods for Assessing and Enhancing Power Plant Maintainability,".be DRAFT EPRI Passive Plant SER 1.8-2 July 1993
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referenced in this section.
In the DSER for Chapter 1 of the passive Require-ments Document the staff concluded that this recommendation was applicable to passive plant designs. However, these documents were not referenced in the passive Requirements Document. Therefore, this was identified as an open issue.
In Revision 4, EPRI changed Section 8.2.1.2 of Chapter 3, to reference IEEE 1023-1988, " Guide for the Application of Human Factors Engineering to Systems, Equipment, and Facilities of Nuclear Power Generating Stations."
Also, in its letter dated September 29, 1992, EPRI stated that Section 3.7.7 of Chapter 10 contains a reference to EPRI NP-4350, " Human Engineering Design Guidelines for Maintainability," which in turn references the older report EPRI NP-2360, " Human Factors Methods for Assessing and Enhancing Power Plant Maintainability." This revision and clarification are acceptable, therefore, this open issue is closed.
60-Year life Section 8.2.3.3 of Chapter 1 of the passive Requirements Document states that components will be designed for an operating period of 60 years (minimum) or in accordance with Section 11.3 of Chapter 1 of the passive Requirements Document. As discussed in Sectiun 3.3 of this chapter, the staff will review the ALWR dasigns for a 60-year life notwithstanding the fact that a 40-year limitation is specified in the Atomic Energy Act and NRC regulations.
8.3 Minimizina Dose levels to Personnel (ALARA)
Section 8.3 of Chapter 1 of the passive Requirements Document specifies the general requirements and design features that will be used to minimize radiation levels and maintain personnel doses ALARA. Specific design criteria are addressed in other chapters of the passive Requirements Document, primar-11y Chapter 6.
To achieve its 100 person-rem / year dose goal for the ALWR, EPRI established several basic requirements that must be met. These include the control of materials selection (including the elimination of cobalt to the extent possible); the use of adequate temporary and permanent shielding; the design of components to permit cleaning and chemical decontamination; the application DRAFT EPRI Passive Plant SER 1.8-3 July 1993
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of robotics for cleanup, maintenance, and inspection tasks; the packaging of equipment in modules to facilitate rapid disassembly / assembly for inspection l
and maintenance; and the design of heating and ventilation systems to control temperature and humidity in radiation work areas.
r EPRI states that the plant designer will consider the use of electropolished surfaces for those areas of the plant (e.g., large-diameter reactor coolant system piping and steam generator channel heads) where this, treatment will significantly reduce the dose to personnel during maintenance.
The plant designer will perform an analysis to determine the effectiveness of using robotic applications in the ALWR, Candidate insper. tion and surveillance functions for robotic application include reading of instruments and gauges, performing radiation surveys and measuring radiation levels, and taking smear surveys. Candidate maintenance functions include steam generator inspection and maintenance,. control rod drive removal, radwaste drum handling, spent fuel consolidation, equipment decontamination, and routine surveillance and maintenance tasks. The passive Requirements Document specifies that the ALWR will include design features such as wider doors and aisles, ramps, and modular construction of equipment and systems (for ease of equipment removal and replacement) to facilitate the use of robotic devices. Table 1.8-4 includes " verify security locks" as one of several functions to be evaluated by the plant designer as a candidate for robotic inspection and surveillance.
However, in its letter of May 17, 1991, EPRI stated that details of the security functions to be performed and consideration of replacing a security i
officer are outside the scope of the passive Requirements Document. This wi'l i
be addressed by the staff during its review of a specific application for a combined license.
These design features are intended to minimize dose levels to plant personnel, are in compliance with RG 8.8, and are, therefore, acceptable.
8.4 Facility Reouirements y
t Section 8.4 of Chapter 1 of the passive Requirements Document specifies that the plant will be designed to provide adequate support facilities for DRAFT EPRI Passite Plant SER 1.8-4 July 1993
DRAFT personnel and equipment. This section addresses general requirements for I
controlling personnel access to the plant and, particularly, to radicactive work areas.
It provides requirements for plant services, contaminated and clean work shops, and spare parts control.
This section includes requirements for the design of the plant's personnel access portal (PAP).
In its letter dated May 13, 1991, EPRI committed to change some of the security terms used in Sections 8.4.1.1 and 8.4.1.2 of Chapter 1 for consistency with terminology in Section 5 of Chapter 9 of the passive Requirements Document. The staff has verified that these changes have been acceptably included in EPRI's June 11, 1991, markup.
EPRI states that the ALWR will be designed to allow controlled personnel access to the plant for the necessary number of personnel needed to perform the required activities. Changing rooms will be located away from radiation sources and will have lockers for at least 1,000 peop,le.
Radioactive work areas will be separated from clean work areas. To the extent possible, the ALWR design will incorporate ramps or steps instead of ladders for personnel movement between floors in areas where personnel are required to wear anti-contamination clothing. Such measures are intended to facilitate the process-ing and movement of large numbers of personnel through the plant during major maintenance outages. The staff concludes that these features are not in conflict with the Commission's regulations and guidance, and are, therefore, acceptable.
5 8.5 Provisions for Replacement of Maior Components Section 8.5 cf Chapter 1 of the passive Requirements Document specifies requirements to facilitate the replacement of all major components other than the reactor vessel and basic plant structures. The plant designer will also i
include plans for transportation and storage of major plant components that may be contaminated and contaminated special tools and equipment removed from the buildings. Designing the plant so that major components can be easily removed and transported out of the buildings without major structural modifi-cations will shorten plant outage time and will, therefore, result in lower DRAFT EPRI Passive Plant SER 1.8-5 July 1993 i
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i overall personnel exposures. The staff concludes that these features are not in conflict with the Comission's regulations and guidance and are, therefore, acceptable.
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8.6 Inspection and Testino Section 8.6 of Chapter I of the passive Requirements Document specifies general requirements for inservice inspection features and techniques to enable the performance of such testing in accordance with Section XI of the j
ASME Code. The staff concludes that these general requirements are not in conflict with the Comission's regulations and guidance. The staff's detailed review of inspection and testing is presented in other chapters throughout this report.
l 8.7 Hazardous and Toxic Chemicals r
Section 8.7 of Chapter 1 of the passive Requirements Document specifies that I
the use of hazardous ard toxic chemicals within the plant will be minimized to f
the extent practicable. This section excludes the use of hazardous chemicals in radiation controlled areas, unless there is no practical alternative to tneir use. Requirements for the use of such substances are also provided.
The staff concludes that these requirements are not in conflict with the Comission's regulations and guidance and are, therefore, acceptable.
8.8 Conclusions The staff concludes that the requirements of Section 8 of Chapter 1 of the passive Requirements Document are not in conflict with the Comission's regulations and are, therefore, acceptable.
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DRAFT EPRI Passive Plant SER 1.8-6 July 1993
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