ML20058G828
| ML20058G828 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/1990 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1818, NUDOCS 9011140047 | |
| Download: ML20058G828 (156) | |
Text
_
- 437;/F/B aG3 A_
~.
OFFICIALTRANSCRIPT OF PROCEEDINGS
\\
l l
gggg U.S. Nuclear Regulatory Commission Advisory Committee On Reactor Safeguard 3-
Title:
Subcommittee On Improved Light Water Reactors i
Docket No.
D l
l toCATIOR Bethesda, Maryland dam Wednesday, October 31, 1990 PAGth 1 - 117 i
)
o n p,~
bild Ji!lC,P(n
,(gfg,}
,O[)lj - [
y l
10r thelhe f '98 COUUdi' tee Ig ANN RILEY& ASSOCIATES, LTD.
1612 K St. N.W. Suke 300 Mahington, D.C. 20006 (202) 293-3950 3 i y'>c
, +
qnj y-
_ _.. _ -.... _ - - - - - - - - - - - - - - - - - - - - - - - - " ~ ~ ~ ~ - ~ ~ - " ~
2 3
4 PUBLIC NOTICE BY THE 5
UNITED STATES NUCLEAR REGULATORY COMMISSION'S 6
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS.
7 8
DATE:
Wednesday, October 31, 1990 9
10 11 12 13 The contents of this transcript of the 14 proceedings =of the United States Nuclear Regulatory 15 Commission's Advisory Committee on Reactor Safeguards, 16 (date)
Wednesday, October 31,-1990 17 as reported herein, are a record'of the discussions recorded at 18 the meeting held on the above date.
19 This transcript'has not been reviewed, corrected 20 or edited, and it may contain inaccuracies.
21 22 23 24 25
1 1
2 UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY COMMISSION 4
5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6
7 SUBCOMMITTEE ON IMPROVED LIGHT WATER REACTORS 8
9 10 11 12 14 Wednesday, October 31, 1990 15 Nuclear Regulatory Commission 16 Conference-Room P-110 17 7920 Norfolk Avenue 18 Bethesda, Maryland 19 20 21 The Subcommittee met, pursuant to notice, at 8:30-22 o' clock a.m., Carl Michelson, Acting Subcommittee Chairman, 23-presiding.
}
25
. ~.-
-2 1
PARTICIPANTS:
2 3
C. MICHELSON, ACRS Member 4
J.
CARROLL, ACRS Member 5
I.
CATTON, ACRS Member t
6 C. SIESS, ACRS Member 7
E. WILKINS, ACRS Member 8
M. EL-ZEFTAWY, ACRS Cognizant Staff Member
(
9 M. VIRGILIO, NRR/NRC 10 R. NEASE, NRR/NRC 2
11 G.
IMBRO, NRR/NRC-12 M. MALSCH, OGC/NRC
(
13 B. GRIMES, NRR/NRC f
L 14 C.' MILLER, NRR/NRC 1
+
15 l
16
+
17 18 19 20 21 l
l 22 23
([)
25
3 1
PROCEEDINGS Q
(v 2
(8:31 a.m.)
]
l 3
MR. MICHELSON:
I believe it's. time to get 1
4 started.
The meeting will now come-to order.
This is a 5
meeting of the Advisory Committee on Reactor Safeguards, 6
Subcommittee on Improved I.ight Water Reactors.
7 I am Carl Micheison, Acting Subcommittee Chairman.
8 Charlie Wylie isn't with us today.
.I assume he will~be back 9
for us by next full Committee meeting.
10 ACRS members in attendance are J._ Carroll, Ivan 11 Catton, Chet Siess, and Ernest Wilkins.
1 12 The purpose of this' meeting is to discuss and t
()
13 review the latest NRC staff proposal regarding the level of 14 design detail under 10 CFR Part 52.
15 Dr. El-Zeftawy is the cognizant ACRS: staff member 16 for this meeting.
17 The rules for participation in today's-. meeting i
18 have been announced as part of the notice of'this meeting 19 previously published'in the Federal Register'on October 18, 20 1990.
A transcript of the meeting.is being kept and will_be 21 made available as stated in the Federal Register Notice.
22 It is requested that each speaker first identify i
23 himself or herself and speak with sufficient clarity and y
volume so that he or she can be readily. heard.
24
)
25 We have received no written comments or requests
4 1
1 to make oral statements from. members of the public.,
2 We have in front of us-a schedule which is subject t
3 to some changes.
The proposed agenda shows that the staff:
4 will make a presentation from eight-forty until ten o' clock, 5
and NUMARC was scheduled from ten to ten-thirty.
It's my s
6 understand that NUMARC has elected not to make a 7
presentation, so that we will have that additional time 8
available if we need it.
9 The purpose of this meeting this morning was to 10 discuss where we're at on this scope and level of detail for l
11 evolutionary light water reactors.
It's been some time 12 since we'. e f.eard last.
The Committee members have-received 13 a status report from Medhat, and I-think it's rather 14 complete.
In there, you will find a copy of-our various 15 letters, and I believe the last. letter, which is of most 16 interest immediately, is the letter in_which we indicated 17 that we thought that the level of detail, of course, should 18 be that required to-assure that the plant is safe, and that, 19 other than that, it appeared that the Level 2.as expressed 20 in SECY ---what was that? -- 241, SECY 241, Level 2 would.
21 appear to be about the right level of detail.
22
. What we want to do today is to discuss-where the 23 staff 11s at on their determination and recommendation on
/~N 24 what to do about scope of design, and also to discuss with b
25 them a little further,-perhaps, some of the ramifications'of 4
l l
, J
i 5
1 what Level 2 might really mean.
O 2
So without any further comments so I don't steal 3
any thunder, I would like to turn it now over -- I believ3 4
Charlie Miller is -- are you going to make a -- let's see.
l 5
Who was going to make the pres 3ntation?
6 MR. VIRGILIO:
Marty.Virgilio.
7 MR. MICHELSON:
Marty is going to make the 8
presentation for the staff.
We do have other staff members 9
here, if there are questions.
So, Marty, if you will.-
-i 10 (Slide.)
11 MR. VIRGILIO:
Good morning.
My name is Marty 12 Virgilio.
I am with NRR.
With me today, I have a number of 13 people that will be responding to questions who participated l
14 in this recent-push to develop our. position on Part 52.
I'd 15 like to take a minute and introduce Gene Imbro in the 16 audience, Charlie Miller, Rebecca Nease, and Brian Grimes.
17 are also here this morning.
18 This morning, we'll be talking about 19 standardization in Part 52 and level of design detail.
20 (Slide.]
21 MR. VIRGILIO:
Just to-refresh everybody as far as 22 the milestones that have been accomplished thus far,.back in
.l 23 July, we issued SECY 241.
We held our commission meeting.
p The next bullet is fairly important.
Brian Grimes 24 25 and Gene Imbro began a task force assignment to help tus l
l
j l
1 determine the appropriate level of detail, and Brian is 2
here, and Gene will be making a presentation later on what i
j l
3 they found from their study.
j 4
We met with you last on August 9th.
The August
{
5 14th ACRS letter, as you discussed earlier, recommended a 6
Level 2 approach.
Subsequent to that, we received a staff j
7 requirements memo, which I'll discuss in more detail as n rt l
8 of this presentation.
j i
9
[ Slide.)
i 10 MR. VIRGILIO:
Just to refresh your memory, back i
11 in July, when we issued SECY 90-241, we introduced and l
12 discussed a number of concepts associated with Part 52.
We 13 introduced the content of the application, and, at that f
l 14 time, we said it must be sufficient to support our safety
[
l 1
l 15 judgment, allow the preparation of procurement specs and
[
?
16 construction and installation specifications, and also allow I
17 the staff to judge the acceptability of ITAAC.
l l
l 18 We also talked about the content of the j
19 application being what we saw to be about at FSAR level of l
i 20 detail, minus site specific information for those FSARs that 21 were issued in the 1985 to 1990 time frame.
t 22 We talked about formatting that FSAR into two i
23 tiers, Tier 1 and Tier 2.
To make that very simple,'we 24 talked about Tier 1 being that portion of the FSAR that was 25 certified, and Tier 2 being that portion that was not' m, - - --.-
~,. -
l 7
1 certified.
()
2 With regard to the certification, or Tier *, we i
i 3
talked about incorporating specific design dstails, top-4 level criteria, into rulemaking that would support the l
5 certification.
We also talked about material available for 4'
6 audit, and that's iri 9rmation normally found in procurement l
7 specifications and construction and installation
]
8 specifications.
And in the paper, we talked ab>ut four 9
different levels of details one could choose, and we used i
i 10 the HVAC system as an example demonstrating how those four 11 levels would look.
12 (Slide.)
j I )
13 MR. VIRGILIO - On the next slide, I talk about the 14 four levels of detail a little bit.
We had identified from l
15 identical physical, function and performance requirements, 16 what we call Level 1, down to functionally identical and
[
t 17 similar principal features, which we called Level 4.
l i
18 What we did in SECY 90-241 was we varied the 19 content of the application and varied the content of the 20 certification in order-to achieve these four levels, t
21 Today, primarily we'll talk about Level 2 --
22 physically similar/ identical function and performance 23 characteristics.
This is essentially the level that the r~'
24 staff believes is necessary to support the design 25 certification.
h
.h
I l
s i
i' 1
MR. MICHELSON:
Could you give me a few examples O2 of what we mean now by physically similar?
3 MR. VIRGILIO:
We will get into that in quite a 4
bit of detail.
l l
5 MR. MICHELSON:
Okay.
Okay.
6 MR. VIRGILIO:
Rather than steal that now.
I 7
MR. MICHELEON:
Right.
Right.
Thank you.
l 8
(Slide.)
l 9
MR. VIRGILIOt With regard to the staff approach, 10 basically we're proposing that the design be developed to a j
11 significant degree to ensure that the top level criteria is 12 properly transmitted into the details of the design.
We l
)
13 intend to audit information in support of our safety l
14 determination and provide controls over changes to some of 15 the information, and rely in part on economic forces -- that 16 is the cost of redesign -- to preserve and foster some l.
l 17 amount of standardization.
18 With regard to level of design detail,'the staff 19 is proposing a graded approach based on safety.
We're 20 proposing that the design be developed to Level 2 or better, 21 recognizing the limits of feasibility and practicality, and 22 what we're going to include in what we require is 23 infottuation contained in certain procurement and i
construction and installation specifications.
l 24
)
25 Our expectations will be defined in a Reg Guide, t
5 t
.,. ~ _, _..
I and we'll identify the design products that need to be 2
developed to support a certification.
3 Again, we view the application as being the FSAR i
4 minus the site-specific and as-built de. tails, but comparable 5
to an FSAR of a plant licensed in the 1985 to 1990 time
)
6 frame.
t 7
MR. MICHELSON:
If you're thinking of the FSAR as 8
part of the application -- to be part of the documentation 9
to be certified, and I guess that's what you're inferring 10 right?
Or are you?
11 MR. VIRGILIO:
Yes.
12 MR. MICHELSON:
Okay.
You --
i 13 MR. VIRGILIO:
A portion of the FSAR will be 14 certified.
15 MR. MICHELSON:
Okay.
You haven't determined yet i
16 what portion you think that might be?
l 17 MR. VIRGILIO:
Yes, we have a pretty good idea, 18 and we'll be presenting some of that'later today.
19 MR. MICHELSON:
Okay.
Will you.tell me also, 20 though, what your general approach is to the staff's SER?
21 If there's a portion of the SER to be certified, then the 22 SER will become a part of the certification for that 23 portion?
j 24 MR. VIRGILIO:
It may or may not.
It's a little 25
. bit too soon to tell exactly how-we intend to craft the
-.- ~.
10 1
FSAR.
1 0,
2 MR. MICHELSON:
Okay.
]
3 MR. VIRGILIO:
We've identified the products and
)
i 4
the details, if you will, that we believe ought to be 5
included in the certification.
6 MR. MICHELSON:
The problem I have is that the SER 7
often calls for additional things to be done, and if it
)
8 isn't certified, even though the FSAR portion is certified, 9
then those things go into a different bin for future 10 consideration, they aren't mandatory.
11 MR. VIRGILIO: You're referring to maybe interface 12 criteria or open items at the time we issue the SER?
l 13 MR. MICHELSON:
Whatavir might be in the staff's 14 SER that needs to be fixed or covered in some way.
15 MR. VIRGILIO:
Certainly, those items would have 16 to be addressed before we go forward with certification.
17 Remember, we have to have a final safety determination.
18 MR. MICHELSON:
Well, you mean you're saying there 19 can be no open items in the SER before you certify?
t 20 MR. VIRGILIO I imagine we will have interface 21 criteria, but as far as what is completed and what is 22 resolved, the staff will make its final determination.
We 23 will cleanly and clearly identify those issues that are 24 resolved, and, yes, there may in fact be open items or 25 interface criteria.
11 1
MR. MICHELSON:
At the time of the FDA, then, t
2 everything must be resolved unless there's something clearly 3
recognizable as resolvable only after the plant's built for 4
some reason.
Is that the approach?
5 MR. VIRGILIO:
Not necessarily.
I think that 6
there can be open items, but they will not be resolved.
7 Again, they'll be open at the time of COL to further 8
litigation.
9 MR. MICHELSON:
Okay.
10 MR. VIRGILIO:
You know, it's to our advantage and s
11 the industry's advantage to resolve as many items as we can i
12 up front, so that we go through the hearing process and the
()
l 13 issues are, in fact, resolved.
But there is no requirement 14 that everything be resolved.
15 Specifically, we looked at site requirements, 16 which, at the time of design certification, we really cannot 17 expect to be resolved.
I i
18 MR. MICHELSON:
Site is clearly a separate item.
19 MR. VIRGILIO:
Yes.
l 20 MR. MICHELSON:
But I'm trying to determine what 21 happens to items that were flagged in the SER.
If, for some 22 reason, they are not closed before the FDA is issued, how 23 are those treated in the certification process?
l
/
24 MR. VIRGILIO:
In my judgment now, what we see is 25 that they would be open items.
They would not be considered s
t I
6 12 l
1 resolved matters, resolved by rulemaking, and thus you would r
2 be subject to further adjudication at the time of the COL.
3 They'd be clearly identified.
4 MR. MICHELSON:
Do they have to be adjudicated t
l 5
further at the time they're resolved, which is after the
(
i 6
certification?
i 7
MR. VIRGILIO:
They would be subject to further 8
adjudication at the COL stage, or at the time that the 9
Commission authorizes operation.
10 KR. MICHELSON:
Okay.
That would be another way f
11 of doing it.
12 MR. VIRGILIO:
Sure.
()
13 MR. MICHELSON:
Okay.
Thank you.
{
14 MR. CARROLL The approach you're taking -- Level 15 2 or better -- is that consistent with the commission's i
16 wishes?
Does that seem to be what they're pushing for?
17 MR. VIRGILIO:
It's a little too soon to tell.
~
18 We're presenting a paper to the Commission on this approach.
19 We're asking them to endorse our recommendations.
t 20 MR. CARROLL:
All right.
21 MR. VIRGILIO:
Again, the application will contain 22 the FSAR, minus as-built and site information, and it will 23 be organized into two parts or two tierst that which is 24 certified and that which is not certified.
25 There will be a third body of informations that l
1
i i
l 13 I
1 information that's available for audit.
This is going to be O
2 sufficient information to confirm the translation of safety j
1 3
criteria into the design.
4 4
The last time we met with you, I know a number of 4
5 you raised questions about what it is that the staff will be I
i 6
looking at, how is the applicant going to know what q
i 7
information the staff will need in order to conduct its 8
audits?
9 What we've done is we've proposed to address this 10 up front, proposed to develop a reg guide that will 11 delineate those products that the staff feels are necessary 12 to support the translation of top-level criteria into the s
13 actual design, and these are the details the staff will
~
14 audit.
15 MR. MICHELSON:
Is the draft reg guide going to be 16 a part of this SECY paper coming out?
17 MR.-VIRGILIO:
We will have tables included in the 18 SECY paper that will provide the body or the input to the 19 reg guide.
20 MR. MICHELSON:
The reg guide comes later.
Do you 21 have a schedule in mind yet as to how much later?
22 MR. VIRGILIO:
We have talked about possibly a 23 year, but you'll see from Gene's presentation --
24 MR. MICHELSON:
Well, I'm thinking, in' terms of O
25 ABWR schedules, what a year means.
_ _ _ ~
i 14 1
MR. VIRGILIO:
Part of this work can probably be l
l 2
done in parallel.
Clearly, as we go forward with the l
l 3
Commission paper, we'll have sufficient detail identified in 1
4 the commission paper by way of tables that we would envision 5
would be the tables included in the draft SER that would go 6
out -- the draft reg guide -- excuse ne -- that would go out 7
for public comment.
So it would be very clear to everybody i
8 what we're talking about.
I think that the work in the 9
design development could progress in parallel as we go 10 forward and finalize the reg guide.
11 MR. MICHELSON:
But there will be a reg guide to 12 define what should be the documentation included in this
()
13 proposed scope?
14 MR. VIRGILIO That's our proposal to the 15 Commission, yes.
16 (Slide.)
17 MR. VIRGILIO:
On the next slide, I get in very 18 briefly to the graded approach based on safety.
19 Collectively, the three parts, Tier 1, the certified portion 20 of the FSAR, Tier 2, the non-certified portion of the FSAR, 21 and the material available for audit, will provide this 22 graded approach to safety that I've shown in this slide --
l l
23 greater than Level 2 for certain nuclear island features; 24 Level 2 for other nuclear island features; and Level 2 for 25 the turbine island features; Level 4 certification and Level
,. - ~, - -. - _
~
9 l
15 1
2 at COL for the site specific features.
O 2
Gene will discuss in a lot more detail the graded l
3 approach.
i 4
MR. CARROLL:
Refresh my memory.
COL is combined f
i 5
l l
6 MR. VIRGILIO Operating licensing, yes.
7 MR. MICHELSON:
Are you going to eventually
[
l 8
address how this fits into Part 52, where they discuss the l
9 finality of design?
i 10 MR. VIRGILIO:
Yes.
[
11 MR. MICHELSON:
Because it's not clear to me how 12 final are each of these tiers.
()
13 MR. VIRGILIO:
Okay.
Yes, we will.
14
[ Slide.)
i 15 MR. VIRGILIO:
With regard to flexibility, we 16 recognize that we've got to strike a balance.
We've got to i
17 have sufficient detail in order for us to ensure our safety 18 judgments, and we also have to allow for the finalization of i
19 the design as the applicant incorporates vendor specific l
i i
20 information.
21 In order to do this, we believe that we can i
22 certify a portion of the design with little or no impact on 23 finalizing the design process, and I've listed some of the 24 features of the design that we believe can be included in 25 the-certification and should be included in the i
a w--.
-w-----
-e..
-- + =. -
16 i
6
)
1 certification.
' ()
t 2
Gene will discuss in much more detail the features 3
that we believe ought to be included in the certification.
4 (Slide.)
5 MR. VIRGILIOt On the next slide, I've shown 6
basically once you certify, you're still allowed some t
7 flexibility; it just involves staff approval before changes 8
can be made.
Certainly, that portion of the design that is 9
certified can be changed by rulemaking, to amend the 10 certification, by exemption per 52.63, or it can be waived 11 if found not applicable per Section 2.758.
12 MR. CARROLL:
What does 52.63 say?
)
13 MR. VIRGILIot Fifty-two-sixty-three basically.
l 14 refers you to 50.12, the process that we use for exemptions
^
15 today, but it requires the staff to include an evaluation of 16 the impacts on standardization for changes that are made to 17 that portion of the design that is certified.
So it 18 provides an extra criteria, in addition to what we look at 19 under 50.12.
20 MR. CARROLL:
And what do you envision the staff -
[
21
- what question is the staff going to be asking?
Y 22 MR. VIRGILIO:
We've looked at a couple of cost 23 benefit methodologies that are currently being developed by
{
l
)
24 research.
I don't offhand remember the number.
Rebecca, do l
25 you remember the number of those research documents?
These l
17 l
1 are being used to help in the prioritization of cost benefit j
O 2
and incorporation of the safety goal into the way we conduct 3
business.
There are two such documents right now.
j i
4 MR. MICHELSON:
Could we go back to your previous h
5
-- you don't need to show the previous slide, but I just
{
6 want to ask you a question.
In the previous slide, you l
l i
7 talked about what would be certified, and you included the 8
general arrangement, and then you included pipe cable tray j
9 and duct routings.
l 10 General arrangements, as you are well aware, are j
t l
11 not very detailed.
They will show you where a pump is, but t
12 they won't tell you where inverters are located.
They may i
13 or may not show the number of the switch gear.
They may or 14 may not show all the motor control centers, things like that i
15 that are important to certain kinds of safety:
16 considerations.
17 Did you mean that to be a part of the general 18 arrangement, or what did you mean?
19 MR. VIRGILIO:
Gene's going to get into this in a 20 lot more detail.
i 21 MR. MICHELSON:
Okay.
l s
22 MR. VIRGILIO:
But within a defined envelope, you 23 can pretty much site your principal safety-related
(
)
components within plus or minus so many feet of a given 24 t
25 location.
4
i 18 1
MR. MICHELSON:
Sure.
That would be good enough, 2
if thtt's the intention.
i I
3 MR. VIRGILIO:
That was the intent.
4 4
MR. MICHELSON:
Yes, because general arrangement 5
drawings we see now are not quiet that good.
They're, in 6
fact, nowhere near that good.
7 MR. VIRGILIOt Yes.
Well, this would, within 8
tolerances, cite your principal features.
l 9
MR. MICHELSON:
Okay.
That was what you had in 10 mind for general.
Okay.
11 MR. VIRGILIO:
Yes.
12 MR. SIESS:
When they get around to building the b
(_/
13 second plant, do they still work under the same criteria as 14 they had for the first one that nobody had ever built and 15 didn't know where things went?
16 MR. VIRGILIOt I'm sorry, I don't quite understand 17 the question.
18 MR. SIESS:
Well, we were just asking about detail 19 location of things.
Now, once a plant is built, obviously 20 everybody knows where everything in, not within a few feet, 21 but within, you know, a few inches.- Now, when we talk about 22 standard plants, I assume we're talking about more than one.
23 Now, when the second one comes up, it doesn't ha 'e to look l
{)
like the first one within a few feet, then?
24 25 MR. VIRGILIO Unless it's so chosen by the 4
19 1
applicants.
If you had two or three people get together and 2
build it at the same time --
3 MR. SIESS:
No.
I'm just talking about the 4
concept of standardization where you certify a design, and i
l 5
anybody that's got the money and willingness can go out and I,
buy it.
7 MR. VIRGILIO:
It is not our intent to go back and j
8 amend the certified design to be more precise.
9 MR. SIESS:
Okay.
10 MR. VIRGILIO:
We would accept those tolerances j
11 from Plant A to P' ant B to Plant C.
12 MR. SIESS:
And by tolerances, you mean more than
(
}
13 just dimensions in feet and inches, meters and millimeters?
14 MR. VIRGILIOt What we certify, you know, within a 15 defined envolope would be acceptable for follow-on plants.
16 We wouldn't go back -- I understand khat you're proposing.
17 As I understand it, it's that we were to go back and 18 recertify --
19 MR. SIESS:
No.
I'm not proposing anything, I'm 20 asking.
t 21 MR. VIRGILIO:
Oh:y.
22 MR. SIFSS:
That was a question mark at the end.
23 MR. VIRGILIO:
We are not proposing to go back and 24 amend the certification so that the second plant is more l
25 standard, if you will, or closer.
l
20 l
1 MR. SIESS:
But it's your intention that the 2
second plant would be -- although it might not be identical I
3 with the first one, would be just as safa?
4 MR. VIRGILIO It would be physically similar and 5
functionally identical.
What we would do is we would reap 6
the benefits of standardization.
It would be -- we would i
7 make our safety judgments, and we would --
8 MR. SIESS:
That's what I said.
You would not 9
have to make a safety judgement on the second plant?
10 MR. VIRGILIO:
That was part of the certification.
11 MR. SIESS:
Okay.
12 MR. VIRGILIO:
We're not intending on going back t
13 and re-reviewing second, third or fourth plants of a 14 certified design except for that portion that wasn't 15 resolved.
16 MR. SIESS:
And that's the benefit of 17 standardization to you?
You said "We would reap the 18 benefits of standardization," "we" being the NRC?
19 MR. VIRGILIO:
The citizens of the United States.
20 MR. SIESS Oh.
Okay.
21 (Slide.]
22 MR. VIPGILIO:
What I want to do next is talk 23 about the flexibility inherent in Tier 2.
We talked about 24 Tier 1, and then we talked about a rule change, an O
25 exemption, or a waiver.
i I
I 21 1
With regard to Tier 2, what we are proposing is, l
2 between the time of the design certification and the 3
combined operating license, we use the same process as that 4
was provided for Tier 18 amendment, rulemaking, exemption 5
or waiver.
6 Between the COL and authorization to operate, 7
we'll need a little bit of flexibility in order to ensure 8
that the plants can be constructed, and what we propose to 9
do is provide in the certification provisions paralleling 10 those of Section 50.59 of our regulations.
11 MR. MICHELSON:
Let me ask, just a moment, once we 12 have a standard design and it's been certified and so forth, l ( )
13 then a customer comes along, what does he have to go through 14 in licensing?
He will get his combined construction and 15 operating license before he ever starts constructing, won't 16 he?
4 17 MR. VIRGILIO:
Yes.
18 MR. MICHELSON:
So, he'll have to do all of this 19 before he breaks ground.
20 MR. VIRGILIO:
Yes.
21 MR. MICHELSON: -Is that right?
22 MR. GRIMES:
I think there is a provision on an 23 atomic site for breaking ground.
24 MR. MICHELSON:
Okay.
Yes.
Really, he can break 25 ground, I guess you're saying,.but he can't put in
l t
22 1
substantive structures or whatever.
)
O 2
MR. WILKINS:
Can't pour concrete.
3 MR. MICHELSON:
Yes.
So, this will all be i
4 resolved at the time he wants to build a plant.
l 5
MR. VIRGILIO:
Yes.
6 MR. MICHELSON:
Okay.
How are you going to 7
resolve these -- what does 50.59 mean for a fellow who -- I 8
mean how do we interpret 50.59 now for somebody who doesn't 9
have a construction permit or anything yet?
He just says I 10 want to build a plant.
Now, what does ha do?
Section 50.59 11 doesn't pertain to people who think they might want to build i
12 a plant.
13 MR. VIRGILIO:
We will use 50.59 to control 14 changes.
15 MR. MICHELSON:
ou will use the principles.
Are 16 you going to amend 50.59 to cover this sort of thing?
i 17 MR. VIRCILIO:
No.
What we propose to do is amend 18 the certificatirn or include in the certification provisions 19 paralleling those of 50.59.
l 20 MR. MICHELSON:
Okay.
And then to now apply to 21 anybody who proposes, wishes to become an applicant for --
22 MR. VIRGILIO:
No.
That would be only for those 3
23 people who have a COL, and for that time perici between the 24 COL --
25 MR. MICHELSON:
Wait a' minute now.
This is the e
mm.,
y w
c-
- - - + - -
23 1
part that puzzles me a little bit, I guess, 2
I'm going to make a lot of changes before I build 3
this thing, and they're going to be coming -- they're going 4
to be reviewed under 50.59, but I don't have a COL yet.
5 MR. VIRGILIO Then, those changes can be made to 6
the third body of information, without NRC involvement, 7
provided the criteria in the FSAR or the SSAR and the 8
criteria in the certification is not violated.
What tie're 9
proposing is, within that third body of information, that's 10 when you can finalize the design.
That's when you can 11 incorporate vendor-specific data.
12 MR. MICHEISON:
What's this third body?
I got
()
13 Tier 1, Tier 2, and then the stuff for audit.
14 MR. WILKINS:
This slide addresses only the second a
15
- body, 16 MR. VIRGILIO:
Yes.
Well, actually, no.
This 17 slide, in the bottom bullet, talks about what is available 18 for audit.
Remember, there are three bodies of information.
19 MR. MICHELSON:
And that's the third body.
20 MR. VIRGILIO:
The information available, the 21 information certifief., the information in the SSAR that is 22 not certified, and the material available-for audit.
23 MR. MICHELSON:
That's basically the procurement 24 and construction specifications, per Part 52, at least.
l 25 MR. VIRGILIO:
Information normally contained in e
i
.i 24 i
1 procurement and construction and installation specs.
O 2
MR. MICHELSON:
So, I am going to build this i
3 plant, and I'n going to look at the certified portion of the 4
design, and I'm saying now I want to move things thus and so 5
and so forth.
Nobody says I have to do a 50.59 analysis in 6
deciding that's all right, because I haven't got to my COL 7
yet.
8 MR. VIRGILIOt If it's in the certified portion of 9
the design and you have a design cert --
i 10 MR. MICHELSON Well, it's not the -- this stuff 11 is not in the certified part, unless you're going to certify 12 an awful lot.
d 13 MR. VIRGILIO:
Where is it going to be included?
14 MR. MICHELSON:
That's what I'm asking.
15 MR. VIRGILIOt If it's included in the SSAR but 16 not certifiet
- he same process that one would follow for 17 changing Tier 1 -- an amendment, an exemption, or a waiver -
18
- would apply to that information.
If it's in the third 19 body, then the licensee can make changes without NRC.
20 involvement, provided that T-
.r 1 and Tier 2 criteria and 21 safety is preserved.
22 MR. MICHELSON:
Okay.
So, I can go ahead and 23 change anything I wish, as long as I preserve what portion
[
24 was certified.
25 MR. VIRGILIO:
And the criteria that is in the i
L r
--n--,
~~~<
l 25 1
non-certified portion of the design.
You can't violate that 2
between the time that you're issued a design cart and the 3
time you're issued a COL.
4 MR. MICHELSON:
That will be said somewhere, 5
because I'm not sure that's said anywhere.
6 MR. VIRGILIO:
It will be built into the 7
certification.
I 8
MR. MICHELSON:
Now, I decide, under some kind of l
9 a process, that I haven't violated, and so, I go ahead and l
10 do it.
How does the NRC check on my decision?
It's not a 11 50.59 kind of analysis or a 50.59 kind of documentation yet, 12 because I haven't got a COL.
i
()
13 MR. VIRGILIO:
If it's in that third body of 14 information, we may wind up looking at it as part of our i
15 inspection process, but it is not going to require prior NRC 16 review.
17 MR. MICHELSON:
You're not inspecting -- you don't 18 inspect people who haven't yet got a COL, do you?
19 MR. VIRGILIO:
Yes, we will, if they have a. design 20 cert.
That's the proposal that we're putting forward to the 21 Commission.
22 MR. MICHELSON:
If they've got a certified design l
l 23 rnd somebody proposes to use it'and starts putting some 24 things on paper, you will start inspecting them right away Y
25 as to what they're doing?
r
i 26 1
MR. VIRGILIO:
Essentially, yes.
2 MR. MICHELSON:
I may not even tell you I'm doing
]
3 it.
I can go off in the corner, and there is nothing 4
illegal about going off and making hypothetical designs.
i 5
MR. VIRGILIO:
I think what we're looking at is
]
6 somebody that declares their intent as an applicant.
7 MR. WILKINS:
They have to apply.
j 8
MR. VIRGILIO:
Yes.
)
1 9
MR. MICHELSON:
Then you can do it.
10 MR. VIRGILIO:
Yes.
11 MR. MICHELSON:
But they haven't applied yet.
12 MR. VIRGILIO:
Once they apply, they've declared 13 their intent as an applicant, and that's when we would begin 14 to --
15 MR. WILKINS:
If they haven't applied, they can do 16 anything they want to.
17 MR. MICHELSON:
Now, once they apply, then what do
[
18 you do?
Then you will start auditing what they're proposing 19 to do.
20 MR. VIRGILIO:
In the third body of information.
21 As an applicant, they cannot' change the second body or 22 certainly cannot change Tier 1 without prior NRC approval, 23 and that's this second bullet here.
24 MR. MICHELSON:
Now, this 50.59 type of analysis 25 will start at the time they have applied for a COL.
l
. - ~
i 27 1
MR. VIRGILIO:
Part 50.59 will start at the time 2
that they have been granted a COL.
3 MR. MICHELSON:
Oh, at the time they're granted.
)
i 4
So, between the time they apply and the time they grant, how i
5 do you --
6 MR. VIRGILIO:
We'll control changes to the Tier 2 7
information, just as we'll control changes to the Tier 1 i
8 information and Tier 3 information.
Remember, the majority 9
of the information normally contained in procurement,
]
10 construction, and installation specifications can be changed 11 without prior NRC approval, provided that they maintain 12 safety and don't violate the Tier 1 and Tier 2 criteria.
13 MR. MICHELSON:
You're going to audit that.
So, 14 what are you going to audit?
Are they required to document i
15 these things in some particular manner?
Part 50.59 is just 16 a documentation process anyway.
It's a control process.
17 MR. VIRGILIO:
That preserves safety.
18 MR. MICHELSON:
You will have something equivalent 19 to that required for a person working on a COL.
20 MR. VIRGILIO:
For somebody working on a COL, 21 they're going to have to come in and get prior NRC approval 22 for the information contained in their SSAR.
I 23 MR MICHELSON:
That's okay.
They've already got 24 that.
It's certified.
25 MR. VIRGILIO Not only the certified portion but
- ~,
1 28 l
1 1
also that portion that is not certified but included in the 2
application.
3 MR. MICHELSON:
This will all be clear when we 4
reach your SECY, I presume.
)
5 MR. WILKINS Let me see if I can rephrase this.
1 6
MR. MICHELSON:
All right.
7 MR. WILXINS:
I thought I understood it, but now j
~
8 our Chairman is making me donder.
The applicant says to 9
himself, "This vendor has got a certified design.
I want to i
10 do business with this vendor.
So I'm going to apply for a 11 combined operating license."
At that time, he submits to 12 you all kinds of information, particularly of the Tier 2
( )
13 type, because the Tier 1 type is already on record?
14 MR. VIRGILIO:
No.
Let me see if I can back up a 3
15 little bit.
Before we get our certification issued, before 16 the NRC will make a finding and issue a certification, we 1
17 will have an FSAR.
We will have reviewed it, and we will 18 have made all our safety determinations at that level.
19 We will also have audited a ceTtain amount of 20 information normally contained in procurament and 21 installation and construction -- I'm sorry -- construction 22 and installation specifications.
23 MR. WILKINS:
All right.
Then I said something 24 wrong.
Let me try it again.
The applicant files an 25 application for certification?
I thought the vendor did'
l I
29 1
that.
l 2
MR. VIRGILIO:
The vendor is the applicant.
Right i
3 now, we have several --
4 MR. WILKINS Oh.
Well, then my applicant is the 5
utility.
When I say applicant, I mean a utility.
6 MR. VIRGILIO Then you're talking an application 7
for a COL.
8 MR. WILKINS:
All right.
That's what I thought I 9
was saying.
All right.
i 10 MR. VIRGILIO Okay.
11 MR. WILKINS:
All right.
So the utility files an 12 application for a COL.
He refers to, in that application, l ()
13 he refers to the existence of a certification of the 14 vendor's design.
15 MR. VIRGILIO:
Yes.
He's referring to an FSAR 16 level of detail information.
1 17 MR. WILKINS All right.
Now, the utility has to l
18 furnish you with some additional information at the Tier 2 19 level.
l 20 MR. VIRGILIO:
Yes.
Programmatic information.
If l
}
21 you go back into Part 52, remember, these are not design 22 details except for the site specific information.
The 23 applicant for COL would be given a site specific design 24 information and programmatic information, emergency plans, 25 security plans.
i i
N 1
30 1
MR. WILKINS:
All right.
Would he have to have
)
i 2
information available for audit?
I would think so.
3 MR. VIRGILIO:
Yes, associated with that body of l
4 information --
l 5
MR. WILKINS t But only with that body of 6
information.
1 7
MR. VIRGILIO:
Yes.
We're talking about the 1
8 information that's' required with the COL.
9 MR. WILKINS:
And possibly some interface, 10 possibly some interface information.
11 MR. VIRGILIO:
Yes.
12 MR. WILKINS:
Okay.
And if the utility wished to
()
13 make some changes before the COL is issued, then there are 14 these procedures of amendment -- I can't say it out loud, 15 but the words you've got on the line on the slide there.
16 MR. VIRGILIO:
Right.
l j
17 MR. WILKINS:
Exemptions and waivers and the 18 amendment rulemaking.
19 MR. VIRGILIO:
That's correct.
20 MR. MICHELSON:
What happens if he wants to make 21 changes that were not a part of the certification, because 22 certifications aren't that detailed, nowhere near that 23 detailed, we think.
24 MR. VIRGILIO:
If it was part of the FSAR but not 25 part of the certification, we're going to condition the
31 l
1 certification itself to require that they follow this O2 i
procedure.
3 MR. SIESS:
If the certification doesn't cover the 4
detail, how would you know he changed it?
5 MR. MICHELSON:
You don't..
6 MR. SIESS:
I mean, so, presumably, the 7
certification covers everything the staff thinks is i
8 necessary to protect the health and safety of the problem.
9 MR. MICHELSON:
If they do, there's no problem, j
1 l
10 but I don't think that's going to be.
11 MR. VIRGILIO:
We'll get into this in a lot more 12 detail in Gene's presentation.
(
13 MR. MICHELSON:
Maybe it will become clear then.
14 MR. VIRGILIO:
At the time of design 15 certification, we anticipate that 80 psrcent of the design 16 will be complete, and that the applicant for a COL will be-17 able to finalize the design pretty much by incorporating J
1 1
18 vendor-specific data and information and making changes in 19 this third body of information.
This is-where'we anticipate 20 the changes to be made as the design is finalized.
We 21 intend to construct the certification so that we don't 22 require NRC involvement for finalization and incorporation i
23 of vendor-specific information.
24 MR. MICHELSON:
Could you clear up another point i
O 25 for me?
In the second bullet, you talk about a combined.
l j
1 1
1
)
i l
32 1
operating license, and then you also talk about an 2
authorization to operate.
Could you tell me what that 3
authorization to operate is?
I thought that's what the COL l
4 S:a s.
5 HR. VIRGILIO:
Part 52.103 again requires that the 6
Commission make a finding before operation that all the
(
7 criteria is, in fact, satisfied -- the ITAAC, the inspection 8
test analysis and acceptance criteria.
The Commission will 1
9 make a specific finding, and at that point, the licensee 10 will be authorized to operate.
11 There is another step in the procedure after the 12 granting of a COL.
13 MR. WILKINS:
And that basically says the 14 Commission finds that the plant has been constructed in 15 accordance witn the terms of the license.
16 MR. VI9GILIO:
Yes.
Exactly.
17 MR. MICHELSON:
Kind of back.to two-step 1
18 licensing.
19 MR. WILKINS:
No, but then it was always three-20 step, then, if you want.
It was always three-step.
21 (Laughter.)
22 MR. MICHELSON:
No, no.
Wht
.ey granted a 1
23 license to operate, that was the day they were allowed to 24 start operating.
This is different.
O 25 MR. WILKINS:
At full power?
i
t 33 1
MR. MICHELSON:
No, not at full power.
O2 MR. WILXINS:
Well, all right.
~
l 3
MR. MICHELSON:
This won't be full power either, 4
probably.
But a COL has to be issued before you can even
(
i 5
start constructing.
So now you're saying, Okay, then we got 6
to do something else before we allow them to operate, and I
7 that's this new term.
l 8
MR. VIRGILIO:
That's the specific provisions of 9
52.103.
10 MR. MICHELSON:
Okay.
I didn't quite appreciate 1
11 that, and I realize now what it is.
Thank you.
12 (Slide.)
( )
13 MR. VIRGILIO:
What I'd like to do next is just 14 briefly address the SRM in our answers, and through that, I 15 believe some of these questions that you have will hopefully 16 be resolved.
17 I'm not going to read these for you.
Basically, 18 we were asked a number of questions by the Commission with 19 regard to feasibility and practicality, standardization, how 20 are we going to allow the flexibility for the designing i
i 21 finalization and construction process, what were the I
I 22 advantages and disadvantages of two tiers, and public 23 comments, how are we going to do our review with regard to 24 the standardization portion of the design, and lessons O
25 learned.
.l
-34 1
MR. WILKINS:
Did I miss something?
What is SSC?
O 2
MR. VIRGILIO:
Structure systems and components.
3 MR. WILKINS:
Which is what it always is.
All
'l 4
right.
l I
5
[ slide.)
a 6
MR. V!RGILIO:
With regard to the first question, 7
what we found is it is neither feasible nor practical to 8
achieve Level 1.
It requires vendor specific nameplate 9
data, specific component data typically found on equipment' 10 outline drawings, or it requires somebody to custom build a
]
11 plant, which we felt was neither feasible nor practical.
I 12 What we found is that Level 2 --
l 13 MR. CARROLL:
Does the_ Navy build submarines to 14 Level 1?
,f 3.-
15 MR. VIRGi IO:
It's outside my scope.
,j 16 MR. CARROLL:
I don't know why I asked that 17 question.
18 (Laughter.)
19 MR. WILKINS:
Yes, you do.
j a
20 (Laughter.)
21 MR. MICHELSON:
Proceed.-
22 MR. VIRGILIO:.With regard to Level 2, Level 2,'in 23 fact, requires detailed installation and performance 24 requirements, and we believe that that is feasible and 25 practical, and that for certain structures and components in g
.~
l 35 1
the nuclear island,-you can achieve better.than Level'2, and-
[
l k/
2 you can achieve at least Level 2'for the balance of nuclear 3
island and turbine island.
4 MR. MICHELSON:
Are you going to explain to us 5
later exactly what Level'2 covers?
6 MR. VIRGILIO:
Yes.
7 MR. MICHELSON:
Okay.
Thank you.
I 8
(Slide.)
9 MR. VIRGILIO:
The Commission ask a questions.
10 Where is Level 1 not needed for standardization?
And the l
11 answer really depends on the level of standardization you 1
12 desire.
If you want physical identity, as what we described
( )
13 Level 4 to include, you need to either custom-build the 14 plant or you need that vendor-specific data.
15 Level 2 and our graded approach with greater than 16 Level 2 in some of the Nuclear. Island provides what.we 17 believe -- a very substantial-degree ofsstandardization.
18 You're going to find physical), similar' plants with 19 identical functional and performance ~ characteristics.
20 (Slide.)
21 MR. VIRGILIO:
With regard'to -- the next question 22 the Commission asked us was how-were we going to achieve 23 standardization with the needed' flexibility? -And again, 7y what we're going to do is rely, in part, on. economic forces.
24 O
25 That information in the third body is not going to i
j 1
36' i
J l
1 be required -- is not going to require NRC review prior to
(
2 changes, but having that information developed as a L
3 condition of achieving a design certification will provide 4
certain economic forces.
Cost of redesign would l'ikely to l
5 be fairly substantial, and for a short-term period, it would i
l 6
be clearly the way that one would go in terms of proceeding.
7 with COL.
8 As time goes on, we recognize that those economic t
9 forces will diminish, particularly in areas where you're l
10 getting rapid advances in technology, instrumentation, and 11 control.
But we still-believe the process of' certifying 12 Tier 1 and the information' included in Tier 2 and-that'
()
13 control process we talked earlier will provide a significant 14 degree of standardization.
15 MR. MICHELSON:
Let me-just search for a moment.
16 Is it your thought or intention that a standard 17 plant be one that can be duplicated at a new site,by using.
i 18 the previous site's drawings,.other than those.that are 19 clearly site-related?
20 MR.-VIRGILIO:
Yes.
21 MR. MICHELSON:
.That's your intent.
22 MR. GRIMES:
I think that would be possible if the 23 new purchaser were able to buy-the exact same components 24 from the exact vendors.
I think the actual practical
,f 25 situation is that he would take the material that goes into l
l 1
l 37 1
procurement specs and start from thtt point.
2 MR. MICHELSON:
But insofar as possible, you would 3
think that a standard plant is one you could duplicate with 4
the previous plant's drawings, except where you had to 5
change components for some reason, and then it would be only 6
as required to adapt the new' component to the original 7
design.
8 MR. GRIMES:
That is,-indeed, a large part of the 9
engineering that goes in,-is reconciling the actual physical l
10 characteristics.
11 MR. MICHELSON:
Here's one of the things that 12 bothers me, and I'm sure you'll clear it up later, but I i
13 somehow have to get it cleared up now:
When we start 14 talking about cable trays, for. instance, there's'one way to 15 talk about them, and that's to say they're located within a j
16 certain zone, but within that zone, I don't know which tray l
17 is where and so forth.
18 If I take that' approach, then I.have.to have a 19 separate set of drawings'for each plant, unless I choose to 20 elect to use the previous drawings.
I may use a different -
t 21
- I will put the cable traysta'little differently but within 22 that zone, but I'll arrange-them differently.- Now, that's g
23 non-standard in the sense of thinking that,. insofar as possible, you can-purely duplicate.
O 24
=
25 Also, within that bank of cable trays, I may elect.
l l
38-1 to put my division 1 up near the top or near.the bottom or 2
in between.
I don't know where the-cables might go, because-3 you didn't tell me where they had'to go within the certified 1
4 design.
5 Now, again, I couldn't duplicate -- use-the 6
drawings of the previous plant, because -- but j
7 standardization, to me, meant if I walked into a'given I
8 plant, yes, maybe the cable tray is a foot further down from l
9 the ceiling, because they discovered a problem of some sort, j
10 but the same cables are in the same tray.
11 FR. GRIMES:
I think.that's our. intent,'and Gene 12 will describe that a little further-along.
13 MR. MICHELSON:
But that isn't necessary, though, 14 within your definitions, as I read.them.
15 MR. GRIMES:
Well, that's why;we need this 16 regulatory guide and tables, and the commission paper will 17 define more specifically what it will need for each design 18 discipline.
19 MR. MICHELSON:
Okay.
But I think if we're really 20 going standardization, I. thought part of.the: merit of.
21 standardization was not having to redesign the plant every.
22 time.
23 MR. GRIMES:
Well, I think you can get, perhaps, 24 half of the engineering done, as we'll describe, without 25 redesigning, but you've probably got half of the engineering l
j 39 1
to do.
, ()
2 MR. MICHELSON:
Well, the next plant you build, l
3 though, you ought to be able to use 90 percent of the l
4 previous engineering.
I 5
MR. CARROLL:
Well, except the other complication 6
is if you change constructors.
You know, Stone & Webster 7
may have a sequence or something that Bechtel doesn't use in 1
8 terms of how they want to-build the place, and that could
-j 9
have an impact.
10 MR. GRIMES:
I think we'll show a little further 11 on what'our concept of the engineering hours that hec, to go 1
12 into the various degrees of-design finalization, and.I think c
13 you will see that we think a-lot of the engineering hours do 14 come in in the last portion, the reconciliation portion, and i
15 that, therefore, there is going to be a substantial amount 16 of engineering for each of these components.
17 MR. MICHELSON:
What I've read of what you've said
.i 18 about these matters in the past, it always,seems you're 1
19 talking about the first plan, and I'm trying to say now how i
20 about-the second and third plan?
When do I start reaping 4
21 the benefits of standardization, or to what extent-am I 22 forced to reap the benefits of standardization?
23 And I1 haven't sense yet that you're forcing the 24 second owner to duplicate the first plant, only within a Os 25 zone or in a region or some general physical location.
You.
I s
40 1
do have to put the cable tray, perhaps, in that: location, l
2 but you can put it 10 feet off the ceiling or 1 foot.off the
'I 3
ceiling.
You can put whatever cables, within'certain-4 limits, at least, that you wish,.and you can -- it is simply 5
no longer a standard plant.
6 Now, I don't how far the French go.
Do you know.
7 how far the French go when they duplicate a particular-line?.
8 Are they duplicating everything, physically, using the same 9
drawings as they build each plant?'
10 MR. GRIMES:
I don't believe so.-
11 MR. SIESS:
They're using the same contractor, 12 too.
I 13 MR. MICHELSON:
Yes.
Well, that's all right.--I 1
14 think contractors can be taught a little bit, too.
That's.
15 the problem in the past; even utilities haven't wanted to l
16 learn.
17 MR. SIESS:
I mean the contractor did the 18 engineering and is going to do the construction in France.
19 MR. MICHELSON:
Yes, _I realize that, of course.
i 20 (Slide.)
21 MR. VIRGILIO:
The Commission' asked us to discuss 22 the two-tier approach and its advantages and disadvantages, 23 and as far as advantages go, we see it's an easier, less-24 costly design and construction process from plant to plant.
25 It will allow the accommodation of improvements and account i
41' 1
for equipment unavailability as time goes on and will allow O
2 for some degree of owner input.-
j 3
In the disadvantages side, it provides-a' potential 4
loss of standardization and an increased chance for hearings 5
for the changes that are made pursuant to 50.59.
These 6
issues may be adjudicated at the time of the authorization 7
to operate.
8
-(Slide.)
9 MR. VIRGILIO:
We received public-comments from s
10 industry and DOE, and they all suggested, pretty'much, that i
11 NRC focus on safety when they-determine what the appropriate 12 level of detail should be.
I think we have.
i()
13 I think in the approach that we're proposing now, 14 what we have is Tier 1 and Tier 2, the application reviewed 15 by the staff pursuant to thc Standard Review Plan,in a 16 typical fashion, and then what we're asking for is certain 1
17 additional details normally contained in procurement and l
-18 construction and installation specifications be developedi 19 and available for audit to ensure that that top-level.
20 criteria has been carried into the design.
21 So, I do believe that this approach really does 22 address safety, and it does provide a certain amount of' 23 standardization, a significant degree, I might add.
(~s 24 They asked us to discuss theLtwo-tiered-approach,
'25 a lot of comments on the two-tiered approach,.and we see-J l
L{
'l 42 1
that it's a logical implementation of the rule.
2-With regard to the need for flexibility, that's
~
s l
3 primarily why you need a two-tiered approach, to allow for 4
construction and allow for advances in technology and 5
accommodate unavailability in equipment, and,there were a<
6 number of questions regarding issue' finality, as defined in 7
Section 52.63, and again, the matters that we resolve will, j
l i'
8 be written in our SER.
9 If we have reviewed and we find it acceptable, k
10' there is no intent on the part of the staff to go back and 11 re-review that information; it is. resolved.
j 12 MR. SIESSt The SER:
That's the SER for. -
i ()
13 certification.
14 MR. VIRGILIO:
Supporting certification, 15 supporting COL.
16 MR. SIESS:
And that's the only SER that-you ever 17 have to do?
18 MR. VIRGILIO:
As far as the staff is concerned, 19 to support the certification and the' COL.
20 MR. SIESS:
Okay.
4 g'
21 MR. VIRGILIO:
Now, changes -- certainly, changes
-22 that involve the staff -- remember, we talked'about those 1
23 different processes --
24 MR. SIESS:
Yes.
25 MR. VIRGILIO:
We'll include additional safety i
s
l 43 1
1 evaluation reports.
2 MR. SIESS:
Well, I thought you'were mentioning 3
something in your SER as making -- aus affecting issue 4
finality.
5 MR. VIRGILIO:
If the staff --
6 MR. SIESS:
What do you mean by." issue finality"?
7 No more adjudication, no more hearing,.no more lawsuits?~
j 8
MR. VIRGILIO:
No more staff' review.
9 MR. SIESS:
No more staff review.
Oh, well.
10 MR. VIRGILIO:
Yes.
11 MR. MICHELSON:
That's as defined by 52.63, I 12 think, I assume, is what you're referring to.
(
13 KR. VIRGILIO:
Yes, Part 52.63.
14 MR. MICHELSON:. Now, are you going;to say more 15 about finality later, or is this the time to ask the 16 questions about finality?
17 MR. VIRGILIO:
If you're talking about, design 18 finality, if you'll just hold for a minute,:GeneLwill1get 19 into that, as far as how far_we could final ~ize the design.
20 MR. MICHELSON:
Well, maybe I am'talkingLa little.
21 more in principle.
I clearly agree with-the statement you 22 just made that where the staff has= identified an item and put it to bed that it stays in bed.
q 23 24 How about the items that the staff didn't 25 identify, remained silent on for whatever reason,. perhaps-
44
)
i 1
because they thought it was okay, perhaps'because they 2
didn't even think of it?
How about those items?' What is 3
the 'inality consideration there?
i 4
MR. VIRGILIO:
The way.we envision this to be is j
5 if it's in the application, typically we would -- well, j
P 6
historically --
7 MR. MICHELSON:
Everything is in the application..
i 8
MD, VIRGILIO:- Okay.
If it's'in the application, 9
what we intend to do is provide a design certification based 10 on the application, through amendment, whatever, iffit's 11 amendment 25.
12 MR. MICHELSON:
Now, we're talking'about.the.
()
13 finality provision, though.. How does it apply to items that 14 you did not -- you remained silent on'during the
=
15 certification process?
16 MR. VIRGILIO:
If it was'in the application and 17 we've certified the plant based on our review of that 18 application, whether we specifically addressed:it:in the.SER 19 or not, we believe that that will be final.
That's'our 20 recommendation to the Commission.
{
21 MR. MICHELSON:
So, it's not just. iter: you 22 identified and put to bed.
It's also anything you didn't.
23 even think of that was in the application and you just 24 didn't consider it.
It ic final.
O 25 MR. VIRGILIO:
Well, we-intend to review the
k 45 i
1 application, consider it-all, but we may not write-up a 2
statement supporting the acceptability'of every sentence in 3
the SSAR.
4 MR. SIESS:
How will we know you considered it if 5
you don't write it up?
6 MR. MICHELSON:
That's right.
7 MR. VIRGILIO:
The same'way you'll know -- you s
8 knew that we considered it when we license plants in the ~
I 9
future.
That's the way we grant a license.
10 MR. SIESS:
But that was never final.
We've never-11 licensed a plant final.
We're still building them.
I've 12 been through the SCP.
We didn't license those plants final..
l t
13 MR. VIRGILIO:
When we issue ~a design (j
14 certification, it will be final.
That is the advantage of.
15 the design-certification process.
Once an issue is.
16 addressed and resolved, we do not intend to go.back and look 17 at it again.
I 1
l 18 That is, in part, what's, driving'usito have that
=l i
19 third body of information.
We're going to have the. design 20 developed to a significant degree.- We're going to audit' 21 that information.
We're not going to have an as-built 22 plant, but'we're going-to have as close-to it'as we can get, 1
23 within the limits of what's feasible and practical.
24 MR. CARROLL:
Let's take a fairly current issue:
O 25 Suppose we had had certified plants and the motor-operated i
~
l
46--
1 valve issue-came up.
Would the Generic Letter 89-10 apply _
O 2
to the certified plants?
I 3
MR. VIRGILIO:
We may have had to do it a little j
4 bit differently.
I'm not that-familiar with that Generic
]
5 Letter, but I believe that was,not an adequate-protection 6
- issue, i
7 If it's necessary_for adequate protection, we'll 8
be able to go back, and pursuant'to Part~52.and Part 51.09,.
9 our backfit regulations today,-if there is a safety _ issue,'-
10 we'll be able to go back,;but we will not be able to go back 11 for a cost-benefit enhancement.
It's final.
The staff has 12 made its determination, and we will not be going back for 13 any cost-beneficial safety enhancements.
14 If there is an ah quate-protection issue, the 15 staff will, in fact, go back, and that will: reopen the 3
16 issue.
That's the only reason.
17 MR. WILKINS:
That was always the case and will 18 always be the case and should be the case.
19 MR. VIRGILIO:
Does that address your question on 4
20 issue finality?
21 MR. MICHELSON:
I think it covers most of it.
I 22 think that I-understand what you're saying, and my only 23 comment on it'would be I think it behooves the staff, then, 24 under such circumstances, to do an extremely careful review, 25 because this is it.
l y
1-r 47 1
Even if you' haven't -- I_think you should be very i
2 careful to address everything's that acceptable, as you go 3
along, and there are many areas which, in the SER, so far, 4
like on ABWR, you just are silent.
I don't know whether you l
5 even looked at-it'or not.
?
6 I would say you should -- every case, you.should 7
say,.yes, we looked at it, and-it's'okay.
Then I would at 8
least know.
Now, I don't know whether you:ever lookedLat 9
it.
a 10 MR. WILKINS:
But there is a presumption that they 11 looked at it.
I l
12 MR. VIRGILIO:
Yes.
()
13 MR. MICHELSON: - Well, unfortunately, when you-14 start pursuing, on an audit basis, just a few of'these 15 items, you find they ha"en't even looked at them, then you l-l 16 don't know what to presume.
I l
l 17 MR. CATTON:
Maybe I missed something", but from 18 the conversation, it sounds to me like there's nothing final i
19 about a safety issue.
20 MR. MICHELSON:
Only if it's --
21 MR. CATTON:
If it's a safety issue, you're-22 address it.
23 MR. SIESS:
The adequate' protection --
u 24 MR. MICHELSON:
If it's under adequate protection 25 only.
.I n--.,,
'I 48.
1 MR. SIESS:
If it's a safety issue, it's only a O
H 2
safety issue because it doesn't provide adequate protection.
s 3
MR. MICHELSON:
No.
It's a safety enhancement.
i 4
That's where we get into the-cost-benefit business.
I i
5 MR. SIESS:
Butfsafety enhancement is a backfit.
~
6 MR. MICHELSON:
Yes, that's right.
7 MR. SIESS:
On anything.
8 MR. MICHELSON:
Yes..
9 MR. SIESS:
Certified, non-certified, whatever.
10 MR '. CATTON:
This business about'the amount of 11 square footage and the quenching for the severe accident, i
12 those are unresolved, really, and it's going to be a number d )
13 of years before we even know what it's all' about.
14 MR. MICHELSON:
That's a different issue.
15 MR. CATTON:- There would be nothing final about 16 that.
17 MR. MICHELSON:
That will be open, I assume, 18 MR. GRIMES:
If I could clarify on Dr. Siess's 19 point, the difference between this'and Part 52 and Part 50 20 is that, in the future, the backfit option is not open for 21 the staff in terms of finding a. favorable cost-benefit and 22 imposing a change.
In Part 52, a favorable cost-benefit 23 cannot propose a char.7e.
You must-find:that you have a i
24 condition where you woulo shut down the! plant'and change is
'25 required for adequate protection of the public.
l
.g
' /
49 1
MR. SIESS:
Is that bad?
o/
t 2
MR. GRIMES:
No.
I think that's a good feature s,
3 for this future licensing.
4 MR. SIESS:
If we.want standard plants, we t
5 shouldn't go around changing them, unless there is a good 6
reason for changing.
7 MR. GRIMES:
I was not trying to say one way or 8
another.
I was trying to clarify what the regulations 9
provide.
10 KR. MICHELSON:
My only comment:was that's a good l
11
-- I think it's a good idea,.but you better do you homework 12 very carefully when you certify, and lt think we have to'make 13 a judgement as to whether it's done with sufficient care,-
14 because you can't go back, i'
15 (Slide.(
l 16 MR. VIRGILIO:
I think we've been talking all 17 around this subject and that is how are we going to conduct-18 our review?.There is not going to be any specific 19 standardization review per'se.
We'll be doing our SSAR 20 review directed by the Standard Review Plan, and it will be.
21 supplemented with questions and answers and will be l
22 supplemented with audits.
23 For the information that's available ---that third 5
l
' 24 body of information normally contained in procurement, 25 construction-and installation specifications, we intend to H
m - m - -
- m w wr s-m e e a
- -e-O 7
T'
"+cd*
+
50 l
1 conduct integrated design type inspections taking vertical-2 slices through that information and insuring that top level 3
criteria addressed in Tier 1 and Tier 2 has been adequately 4
carried into the design products.
5 MR. CARROLL:
On the subject of the standard 6
review plan, is there any effort under way to update the 7
standard review plan to bring into it such things as severe 8
accident issues to the extent we've resolved them or 9
implications of the EPRI requirements document?
10 MR. VIRGILIO:
Charlie,'do you have a better 11 handle on -- Charlie Miller from the staff is here, and we 12 13 MR. CARROLL:
The reason I'm asking this is -- one 14 of the things we're considering.next week is the ESPI 90 15 PDA, and many of the committee members feel that that's 16 really a lousy SER in a lot of ways.
And part-of the 17 problem seems to be that reviewers have got standard review 18 plan blinders on, and they're not looking at the world as it 19 exists today with severe accidents and other good things.
20 MR. MILLER:
This is Charlie Miller from the 21 staff.
WIth regard to.the' standard review plan, the staff 22 is going to have to make a judgment whether, you know 23 there's going to be a bang for the buck of updating them f or 24 each individual design.
25 To the extent that: items are identified that wa
~
1 51-1 think can apply generically across the board, we may well k
2 indeed update the standard review plan.
3 But if it's indigenous to a certain design, then 4
it really doesn't buy you anything, and we would have to 5
capture that in our review and in the certification _for each 6
of.the designs.
7 MR. CARROIL:
But the'90-016 issues, for example, 8
pretty much tend to go across the ALMR board, and it's not f
9 just as simple as saying that we've got this issue or_that 10 issue.
A given issue affects things in a whole bunch of-11 different branches.
12 MR. MILLER:
That's correct.
13 MR. CARROLL:- It's_just the way we approach-14 things.
15 MR. MICHELSON:_ Okay.
Well, I guess I would.
16 encourage some thought-to be given to_whether thatfs i
17 desirable because it looks to me like a lot of the reviewers 18 down in the trenches, you know, just are doing things.like 19 they were doing them in the 1970s.
And this is 1990.
20 MR. CARROLL:
Some of that review was 1970-l 21 vintage.
22 MR. MICHELSON: LAs a matter of fact it'was.
23 MR. CARROLL:
That was part of the problem.
It' 24 was never redone.
25
[ Slide.]
52
-f 1
MR. VIRGILIO Okay.
The last question the Li 2
Commission asked us was to discuss the lessons ~1 earned l
3 associated with standardization, and what we-find is the 4
product line approach -- the BWR 6 Mark III, for example --
)
5 provided little standardization..Where_we saw the most
-j 6
standardization was when we saw the duplicate plant approach 7
implemented at SNUPPS and at Palo Verde.
Here we reape6 the 8
greatest benefits from standardization.
9 MR. MICHELSON:
Let me ask a question related,
(
10 kind of, to the problem that the BWR's got and~that is when 11 we talk about standardizing-certain basic, I~ guess, plant 12 layouts are we standardizing the location then of the walls
( )
13 and that sort of thing'and~somebody isn't going to come back 14 in later and add another wall here or there?
Is it-15 standardized to that level?
16 NR. VIRGILIO:
Yeah, we'll be certified.
This is i
17 a real good time to introduce Gene Imbro and let him talk i
l 18 about the details of what'we intend to have in the 4
19 certification.
20 (Slide.)
21 MR. IMBRO:
My name is Gene Imbro.
I'm from the 22 Office of Nuclear Reactor Regulation.
We participated over 23 the last few months in trying to flush out what an 24 appropriate level of detail would be for a standard. plant.
t0 25 Just to kind of refresh your memory, we were here-
.)
a
,, l
53 1
and gave you all a presentation, I guess, in August.
- And, 2
basically, I wanted to set out or redefine-the objectives we 3
had at that time.
{9 4
Bacically, we had two objectives.
First of all,_
5 we wanted to define a level of design-detail cufficient that t'
would allow the staff to make safety determinations and also 7
to capture the benefits associated with standardization.
8 And as a second part-of that we really wanted to 9
get a handle on the engineering effort that was required:to-10 get a level of detail sufficient to satisfy the first two 11 items.
12 (Slide.]
13 MR. IMBRO:
So our approach was basically to try 14 to look at the design process for both Part 50~and Part 52 15 to determine what design products are available at what 16 stages of the design and also try-to understand ~the 17 differences in the design processes and some'of'the probl' ems 18 that were encountered by the Part 50 design' process and kind 19 of why that was so and to look at maybe how Part 50~would 20 enhance the design process, 21 We also tried to define the engineering products.
22 that were completed at the' time of design certification'that 23 we expected would be completed at the time of design 24 certification.
And our approach was basically to divide,the
.j 25 plant systems into categories roughly based on safety
54 I
1 significance and also look at each engineering discipline to t
2 define what products came from which areas of the 3
engineering side.of the house.
4 Then, further, our goal was to define the.
5 information that was going to be contained in Tier 1,which-i 6
would be the certified portion of the design and also'then 7
the balance of the SSAR, obviously, would.be what's in Tier
[
8 2.
9 And then also to define what engineering products, 10 again, we felt needed to be cc.;mpleted at the design
~
11 certification.
And those would be continued in the 10 applicant's files and available for staff audit.
13 MR. MICHELSON:
Gene, let me ask you on that one, 14 in reading Part 52 it was never quite clear to me whether'it 15 meant these would be items that if we were to ask for the 16 applicant would then develop or whether these are items 17 which we expect the applicant to develop in every case-and' 18 we would just go in and select a few.
Which way'is it?
19 MR. IMBRO:
Well, there are. things.that-we would.'
20 expect the applicant to develop.
We want the design to:
21 proceed quite far along'--
22 MR. MICHELSON:
Okay.
Let's say that you expect i
23 him to have this in his file, and you went on an audit basis' j
24 to look for it and it wasn't there.
Is it acceptable,<then,-
O 25 that he'-- what do you do about it?
Well, he-has.to go back 1
l'
?
l 55 1
and develop it.
But is-he just going to lay back or do you
()
2 really expect that every one of these items will be'in his l
3 file already?
4 MR. IMBRO:
Yeah.
Yeah.
5 MR. MICHELSON:
You expect, for instance,.every 6
procurement and installation specification is to be in the a
'i 7
file of a person applying for certification?
8 MR. IMBRO:
Well, not so much --
9 MR. MICHELSON:
Is that what you're saying?
f 10 MR. IMBRO:
Yeah.
Well, let me qualify that.
Not 11 so much the specs themselves, but he should'have the 12 engineering progressed to a sufficient level that --
13 MR. MICHELSON:
Part 52 refers to looking at the 3
14 specifications, L st looking at the information behind the 15 specifications.
16 MR. IMBRO:
Yeah, but Part 52 --
17 MR. CARROLL:
You two guys may be saying different 18 things -- certification _as. opposed'to the utility coming --
19 MR. IMBRO:
No, no,uno.
We're talking about 20 certification.
21 MR. CARROLL:
You're' talking about certification?1 22 Okay.
l 23 MR. ' MICHELSON:L Yeah, I'm talking about Part 52 --
y 24 52.47.
O I
s 25 MR. IMBRO:
But I think Part 52 makes the 1
l L
h
_ _... _ _ _ _. - ~ _ - -
k 56 1
distinction that if required by the staff th'en the applicant
()
2 would have to develop certain purchase specifications.
i s
3 MR. MICHELSON:
Yeah, it sounded'like if you 4
t; anted to see what the specification would look like he.has' 5
to develop it.
6 MR. IMBRO:
That's right.
7 MR. MICHELSON:
This last item-here sounds like 8
you expect him to develop every one.and:you're going to go 9
in and look at wh!.ch ones you wish.
10 MR. IMBRO:
What'we are'sayinglis he does not have 11 to put together the formality of putting 1 together a purchase 12 specification, but he has to have enough enginet ing 13 information to be able to write the spec.
14 MR. MICHELSON:
That's a_little different than 15 that bullet seems to infer.
16 MR. GRIMES:
This is Brian Grimes.
17 I think Part 52 specifically-saystit'sJthe 18 information normally contained in the specification.
So, 19 we'd expect to see data sheets, later on, might be stapled' 20 to the actual specification.
21 MR. ' MICHELSON:
Well, I am reading a'different 22 part of the same 52.47 than you are.-
23 I'm reading the part that says "That-information-i 24 normally contained in certain procurements-and construction 1
25 and installation specifications be completed and available-
...,J.
t 57 1
for audit if such information is necessary for the
()
2 Commission to make a safety determination."
3 That's the part of'it I'm reading.
You're reading =
4 a different part.
5 MR. GRIMES:
No, I read the same part.
~
6 MR. MICHELSON:
Okay.
It says it's got to be 7
completed and ready you to look at.
8 MR. GRIMES:
"The information normally contained In other words,= the engineering informationl 9
in.
10 "normally contained in," not the specification.
11 MR. MICHELSON:
Well, then I am not. reading what 12 you're reading.
I will read it very carefully and clearly.
l 13 "That information normally. contained in certain-(
14 procurement specifications and construction and installation-15 specifications be completed and available for audit."
16 So, it's got to be completed and available for t
17 audit, but I thought only where the-NRC asked for it.
18 MR. GRIMES:- Right.
l 19 MR. MICHELSON:
Not everywhere else.
20 MR. GRIMES:
What we're saying'is the NRC is going i
21 to ask for it in a large portion of.the cases.
22 MR. MICHELSON:
Okay. ;Now, that was my 23 understaliding.
Here'it'seems to mean the applicants' files-q t
24 are going to have this informstion, and you're going to go It S L
25 in and audit it.
?
1-
\\
58 l
1 MR. GRIMES:
Right'.
O 2
MR. MICHELSON:
That's different.
I 3
MR. GRIMES:
We're asking for it up! front.
4 MR. MICHELSON:
That's~different than what.52.47 5
seems to ask for.
6 MR. GRIMES:' We're saying we're'now asking,'up 7
front,.that certain information be available, which>willfb's 8
defined.
In other words, we're not going to wait until we 9
get the application.
10 MR. MICHELSON:
Okay. :You're going.go on to say, i
11 ahead of time, what you expect to be in their files.
12 MR. CARROLL:
The vehicle for that would be one of
()
13 the reg guides?
14 MR. GRIMES:
.Yes.
15 MR. MICHELSON:
And 52.47 seems'to allow that, 16 because it does say certain-things are. going to have to be l
17 completed for your inspection.
t 18 MR. GRIMES:
And the substance;of the regulatory 19 guide will be the' Commission.
20 MR. MICHELSON:
Okay.
21 MR. WILKINS:
Will the existence of that 22 regulatory guide prohibit you from' auditing things that'you 23 have not previously identified?
I' don't think so.
24 MR. GRIMES:
No.
25 MR. MICHELSON:
But it may not expect to find 'it.
'l
i 59 i
1 MR. WILKINS:.May not expect to find it.
You may l
2 have to give them a chance to get-it.
i 3
MR. MICHELSON:
Yes.
F l
4 MR. GRIMES:
It will be extensive enough to
)
5 indicate what we expect to be available.
6 MR. MICHELSON:
Okay.
But that, then, will' 7
finally define how much work they're going to have:to do for.
-l 8
sure and maybe a little more besides?
j 9
MR. GRIMES:
Right.
10 (Slide.)
11 MR. GRIMES:
In looking at the Part 50 design 12 process, we kind of refreshed our memory as to what we had 13 gone through in past years, and Part 50-design process 14 really was -- had n lot of problems.. The main problem with 15 the Part 50 desirjn process is that, in many_ cases, the 16 construction was started with a very little percentage.of 17 the -- a small percent of the design completed.
18 So, you had, in a large degree, the design --'_the' l
19 design completion was being driven by the. construction-
'i 20 schedule, and probably, in some instances, the construction-21 really go ahead of the final design.
22 Also, space was allocated on a first-come, first--
23 serve basis.
People went in, in design the plants, andL 24 blocked out space for their components, cable trays,.
25 whatever, without, really, a whole lot of_ thought as to the
1
- 60 l
1 best way to optimize the. system and to locate components and.
the most easy way to maintain'and these types of things.
2 l
l 3
So, there wasn't really h whole lot of j
l 4
consideration for the big picture.
Everybody was sort of i
5 doing their own thing, and it came together, you know, how 6
it came together.
7 MR. CARROLL:
Don't blame:the electricals for the 8
problem.
It's the heating and ventilating guys that really 9
screwed things up.
10 MR. IMBRO:
No blame.is; pointed at any particular 11 design group.
I think each should probably share.
t 12 Also, there's a lot of design changes in.the Part 13 50 process, because the design was continually being refined 14 as you were getting -- getting vendor data.
You know, you.
15 had deviations from construction caused by construction.
16 In some cases, components:were: installed not in 17 accordance with the schedule but because something was 18 onsite and they had the crew available to put it in, so they t
19 put it in, and that kind of caused problems in installing l
20 other things that maybe had to go in behind it,'and so, a i
21 lot of design changes resulted from the= fact that the design 22 and construction were going simultaneously.
1 l
L 23 Of course,.when we.look at design changes, 7 think 24 we all recognize that, you know, you. change a small piece-t 25 over here, and by the time you're finished, it kind of has a w
,w
.w,-
,.,,-..r.
61 1
ripple effect.
So, one change really engenders a lot of-
)
2 other changes.
3 So, I guess the point was it was kind of an 4
inefficient process, and probably, design was done about two 5
or three times before it was actually completed..
G (Slide.)
7 MR. IMBRO:
Now, for the Part 52. process, we would.
8 envision a little more orderly way to do" business.
First of 9
all, the design -- we're requiring that the design really 10 achieve a high degree of finality before construction 11 starts.
12 So, you won't-have the situation where i
13 construction is really driving the design.
People.will have 14 a chance to, hopefully, think'out things andLdo things in a 4
15 more kind of logical approach.
16 We have heard some people talk about thefconcept' L
17 of zone manager, where you have one engineer that's-kind of 4
18 looking -- responsible for a particular zone.and'looking at 19 the components that go through and trying to give priorities 20 as to what goes where and what goes in first and'that type j
H 21 of thing.
, 22 Since the design will be completed to a very.high 23 degree of finality, we'would expect: fewer-field changes.
24 MR. MICHELSON:
That hasn't been decided yet, how 4
25 high that degree of finality is going to be.-
1 e-
,,w-
.,n
_~
1 4
62 i
i t
j 1
MR. IMBRO We're going to tell you that in a l
()
2 minute.
Rest assured, it's going to be completed quite far.
i 3
But even with all that, you still ntnd flexibility for t
4 vendor-specific data, because you remember that Part 50 1
l 5
basically stops at the point where you write procurement j
\\
6 specs.
So, you haven't purchased equipment yet.
j i
7 MR. GRIMES:
Part 52.
8 MR. IMBRO:
Part 52.
Excuse 20, Part 52.
And i
9 certainly, no matter how well you plan, there are always 10 going to be some construction deviations.
So, you have to t
11 have some flexibility to allow taking care of those types of j
t 12 things.
i 13
[ Slide.)
i 14 MR. IMBRO What we did, in taking a look at the 15 Part 52 process, was kind of try and look at the phases of f
l 16 design evolution, and roughly, we broke it down into four 17 levels as a concept 'tal phase, a preliminary phase, a detail 6
18 phase, and a final phase, and those are covered on the 19 slidem.
[
i 20 Roughly, a conceptual phase is developing general 21 arrangement drawings, looking at system functional 22 requirements, developing simplified single lines and P& ids i
23 and that type of thing.
So, it's kind of the planning.
l l
24 Preliminary design, you're writing specs for major
\\
25 components and-that type of thing; you're writing system
}
i
.,J._~
4
.,4,
l f
63 1
l descriptions.
()
2 Then in the detailed phase of design is where r
3 you're really getting down to the. point of really kind of 4
developing pretty precise single-line diagrar'; and P& ids, 5
and you're at the point where you have piping laid out, 4
6 you're developing isometrics, you're doing preliminary l
i 7
piping analyses, and you're starting to finalize the list of 1
8 components.
9 Also, I think the key point in here is that -- is 10 develop equipment functional and performance requirements, 11 and these are the basis on which the purchase specs are 12 written.
So, as you will see later, we're basically saying i
13 that for a Part 52 process, we'd like to have the design i
14 proceed up to this point.
15 Now, the final design-phase, then, is the actual l
16 preparation of the specifications, going through the vendor-17 selection process, and then doing all the reconciliations 18 that you have to do when you get the vendor-specific data 19 and, also, as the plant is being constructed and you get as-20 built data back from the field.
So, this is kind of the 1
21 fine-tuning.
22 Now, we estimate that from here up is about 50 1
23 percent of the engineering hours, and probably 50 percent of 24 the engineering hours are required to do all of this very
+
25 detailed design work that's necessary to actually build the i
s
...-,--,e r - - - -
e.
.-s-,--..
v e
,~ --
,1-,-e a-e=-~
e~>-
~
i 64 l
l 1
plant, but yet, it doesn't really change the design finality 2
very much, because at this point, you've invested so much 3
money in engineering that economics will pretty much dictate
{,
l l
4 not making major changes in the plant design.
]
5 MR. MICHELSON:
Where are you going to do the 3
6 cable-tray layouts?
l 7
MR. IMBRO:
It will probably be in here someplace.
l
?
8 MR. MICHELSON:
It wasn't listed.
j 9
It gets sticky for such things as talking about 10 piping isometrics.
What bore piping are you thinking about l
11 in laying out the isometrics?
12 MR. IMBRO:
I'm going to get into that on one of j
13 the next clides.
4 14 MR. MICHELSON:
But apparently, all the piping f
15 layouts will be done under Part 52 per your previous 16 statement.
17 MR. IMBRO:
Yes.
Let me defer that to later.
I i
18 can give you a little more detail.
t 19 MR. MICHELSON:
I had a little trouble with that l
20 50-percent number you were using, because a lot of the 21 detail is in laying out all that cable trays and the cable 22 routings and the small-bore piping routings and all that.
l 23 MR. IMBRO:
I think a lot of that will be done in l
24 the detail phase.
l 25 MR. MICHELSON:
It's not listed on your final l
~
j I
65 l
1 design phase.
That's what I had a little trouble with.
You l
2 don't list any of that for final.
You said 50 percent was 3
the final design phase, and you didn't identify what was in 4
it.
5 MR. IMBRO:
Maybe I can clarify in the next few i
6 slides.
[
7 MR. MICHELSON:
Okay.
I 8
MR. CARROLL:
Are you going to be here tomorrow 9
for the meeting on the design basis document?
10 MR. IMBRO:
Yes.
11 MR. CARROLL:
I'm surprised, when I look at all of 12 this, that I don't see the words " design basis 13 documentation."
14 MR. IMBRO:
Well, in a way, it's pretty much in i
l 15 the -- the system descriptions, pretty much, are going to be 16
-- I mean everything is design documentation.
You're going 17 to do a lot of preliminary calculations and analyses in the 18 detail phase, and the system descriptions are going to be 19 done by i. hat time.
So, a lot of that, really, is what would 20 be --
21 MR. CARROLL:
Okay.
Now, I don't see system 22 descriptions in any of this, either.
23 MR. 148RO:
I think it was on the first slide.
1 24 MR. CARROLL:
It says " functional requirements."
25 MR. IMBP):
If you go back to the conceptual
1 1
phase, I think we talked about system description.
2 MR. CARROLL:
I'm looking at the conceptual phase.
3 MR. IMBRO:
We don't have everything in there, but 4
system descriptioro will be.
1 5
MR. CARROLL Don't forget to put good design J
6 basis documentation in the reg guide.
MR. IMBRO:
This is an abbreviation of a package 8
that's about an inch thick.
9 MR. CARROLL:
There's a lesson learned in the i
10 industry.
i 11 MR. GRIMES:
We understand.
We got the message.
12 (Slide.)
( )
13 MR. IMBRO:
What we tried to is break the system --
14
- you know, in order to -- this was a very kind of complex 15 problem to figure out what the level of design detail was 16 that we wanted to attain.
So, what we tried to do is to 17 break the systems down and to group the systems in 18 categories, rather than address individual systems,-and we 19 chose to break the systers and structures down into four 20 basic classifications.
j 21 One would b's nuclear -- and these classifications 22 are roughly -- you know, correlate with safety' significance 23 and also with the level of detail which we. expect to be 24 completed, and I guess the highest or most safety-O*
i 25 significant, we felt, obviously, was the Nuclear Island, and i
l
I 67 8
1 we defined Nuclear Island as containing systems and 2
components such as this, the primary coolant system,
)
3 engineered safety features, and the reactivity control 4
systems, and the like.
5 The balance of Nuclear Island was everything that 6
wasn't included in Nuclear Island, such as emergency core 7
cooling systems, containment sprays, 11 those systems that 8
you find in the aux building.that are generally classed as 9
part of the Nuclear Island.
10 MR. CARROLL Where is the control room?
l 11 MR. IMBRot I'd probably put it in balance of 12 Nuclear Island.
/)
13 MR. WILKINS:
It's down at the bottom.
14 MR. MICHELSON:
Its habitability part is, at 15 least, at the bottom.
I 16 (Slide.)
17 MR. IMBRO:
For the other two categories, we chose 18
-- it's pretty straightforward -- the Turbine Island and all 19 the systems contained in the Turbine Island.
i 1
20 MR. MICHELSON:
But a lot of those systems have 21 branches going out into the areas where the. Nuclear -- so-22 called Nuclear Island is located.
I 23 MR. IMBRO:
That's right.
24 MR. MICHELSON:
So, it's hard to talk about them O
25 as Turbine Islands.
They're very definitely -- auxiliary 1
1
. - ~ -
_ +, _..
,_s
_.,,s
-,,,.,_,y r---.
68 1
1 1
steam may go throughout the Nuclear Island to heat rooms and i
2 so forth.
3 MR. IMBRO:
We agree.
In the next slide or so --
4 basically, we're going to treat the Turbine Island and the 5
balance of Nuclear Island the same, because of that reason 6
that you suggest and, also, the fact that systems in the 7
Turbine Island can certainly challenge the plant in terms of i
8 causing plant trips.
And so, we feel that that's also very 9
important.
10 ihe last group of systems are the site-specifics -
11
- ultimate heat sink, essential service water, other non-12 safety-related systems.
13 (Slide.)
(
)
14 MR. IMBRO So, I guess, kind of the bottem line 15 is that we're looking for greater than Level 2 for the 16 Nuclear Island, and in that, we mean that for the Nuclear s
17 Island, you need a certain amount of vendor-information, and 18 it's available, because the applicant is an NSSS vendor.
In 19 order to do your safety analysis, you need geometries of the 20 primary coolant system, reactor internals, and that type of 21 thing.
22 So, for Nuclear-Island, we would really expect and 23 feel like it's necessary for us to make our safety judgement 24 to really have a very high degree of finality, approaching O
25 Level 1 but not really quite there, because-everything is
i i'
69 l
l 1
not specified.
1 2
For example, in the reactor protective system, we 3
would expect the design to have proceeded quite far, even to 1
4 the point where maybe some of the components would be i
l 5
selected, but certainly, you wouldn't have it to the point 6
where you'd have interconnection wiring diagrams prepared, 7
because you really don't what all the equipment is going to 8
be.
9 The other thing we're also suggesting for systems 10 in the Nuclear Island, particularly innovative-type systems, i
11 such as application of multiplexing and fiber-cptics and 12 data networks and all this other computer-based protection
- l
- ()
13 systems is that people do prototype testing for those 14 concepts that are innovative and really have not been used 15 before.
So, you can actually-have a demonstration of their 16 capabilities.
17 MR. SIESS:
Excuse me.
18 MR. IMBRO:
Yes.
19 MR. SIESS:
I'm way behind on something, but back 20 when you were talking about the various design phases, at 21 what stage, right now, is the ABWR?
22 MR. IMBRO. Well, it varies, and I'd say -- before 23 I say anything, I'll condition on the fact that we were out 24 to San Jose in April, so my information is probably dated, O
25 but at the time we were out at GE, we felt that the
l 70 1
mechanical systems, particularly those systems traditionally
()
2 supplied by the NSSS vendor, were pretty far along, maybe to 3
Level 2.
4 The systems that were traditionally supplied by S
the AE or designed by the AE, the electrical distribution 6
systems and that, I guess we would say would be probably 7
between Level 3 and 4; so, conceptual, maybe to some I
8 preliminary design.
So, they weren't as advanced as we're l
9 suggesting here.
i 10 MR. SIESS I'm just wondering, sometimes, why 11 we're going through this abstract discussion of level of 12 design detail when we actually have a certification in 13 progress, an actual case out there and actual drawings and a 14 stack of SARs like that.
Would it help in some of these 15 things to tie back to a plant that we -- to a design that we 16 know something about?
17 MR. GRIMES:
We are trying to do that, and what we 18 found is that we think there will have to be substantial 19 additional engineering on the ABWR to bring it to this level 20 of completion.
21 MR. SIESS:
That itself is helpful.
l l
22 MR. GRIMES:
The second thing we would like to do l
23 is, when we develop the regulatory guide, we'd want to get 24 that out for comment as soon as possible,.but then I think 25 there will be a learning process as we actually go through
l 71 1
the ABWR review that will provide feedback'into the final
()
2 version of the regulatory guide.
3 So, I think we want to use that licensing process 4
also as a learning process as to how to finalize the 5
regulatory guide.
So, in two ways, I think it has benefits.
6 First, we make clear our expectations of level of 7
detail to anyone who is submitting an application for 8
certification, and second, I think we can '
trn as we go 9
through the licensing process how to process and refine that 10 regulatory guide.
11 MR. SIESS:
That makes sense.
12 MR. IMBRO:
Also, we have -- we have discussed 13 this at a reasonable length in the SECY paper, which will
)
14 probably be out in a week or something like that.
15 MR. MICHELSON:
The part I have a little 16 difficulty with, though, is in the case of General Electric, 17 there is little doubt in my mind they can probably 18 ultimately provide whatever level of detail you may wish, 19 because they're building one.
At least, for -- most of that 20 plant will be duplicated in Japan.
21 So, most of the design will be duplicated there.
22 They will have to do some control room and turbine building 23 design, because it's a different~ turbine building and 24 control room.
25 So, I guess you could -- you know, it's not an
~
J 72 l
1 imposition to ask them for whatever level of detail you O
2 think is reasonable, but how much do you have to ask for 1
3 because other people are coming in without necessarily a 4
customer, and they have -- how much should be required cf i
5 them?
6 MR. SIESS:
What other certification do we have on 7
the horizon?
l 8
MR. MICHELSON:
CE.
Well, t'a r3t sure that they 1
9 have a customer for that design or They think they do, 10 but that's all right.
Maybe the
-te a n s.
11 MR. SIESS:
It just bota,ers me that we're dealing 12 with abstractions as if this is going to be a process for
()
13 the next 20 years with 8 or 10 certifications.
14 All we can really see ahead of us is two that i
15 we're going to learn on.
Westinghouse has said they're
)
16 going to stop.
The next one after the combustion and GE 17 will probably be a CANDIL.
18 MR. IMBRO:
We're trying to define a process and 19 methodology to approach those things.
It's a complicated 20 thing.
21 MR. SIESS:
But there's only so far you can go in 22 the abstract in describing a process.
23 MR. IMBRO:
We're going to get into some 24 specifics.
25 MR. SIESS:
It's never worked in the past.
i 73 (Slide.)
1 I
2 MR. IMBRO:
As an example of things that will be 3
included in Tier I, we've prepared these two viewgraphs 4
which are, I guess, a brief summary of what's going to be in 5
the SECY paper and just a list of some of the things we 6
think can be in the Tier I certification.
We can go through 7
the list here 8
Design bases and criteria; that pretty much goes j
9 across the board for all systems -- structures, components.
10 Si:aplified piping and instrumentation diagrams; simplified 3
11 single lines --
12 MR. MICHELSON:
Does simplified mean you're
(
13 leaving some of the things out?
14 MR. IMBRO:
- Yes, obviously, you don't have vendor 15 information, so there are certain things that are going to 16 be --
17 MR. MICHELSON:
Not much vendor information 18 appears on a P&ID.
For that matter, you don't know the 19 nozzle locations of pumps or things like that.
20 MR. IMBRO:
You know the nozzle size.
21 MR. MICHELSON. You know there's going to be a 22 pump there and the size.
23 MR. IMBRO:
Right.
We feel that putting this type 24 of information in, pretty much locks the design in terms of O
25 the way you approach single failure criteria, what major
. ~. -
~
74 1
valves yoit have in, where you major instrumentation is.
2 It's kind of a cartoon at this point because we feel like, 3
as the design evolves, a lot of information on a completed 4
P&ID vould be continually changing.
l 5
We feel like some information, at least at a basic j
6 level, should be put in to at least define major concepts, t
7 It's the same thing with the single lines -- electrical 8
single lines.
9 MR. MICHELSON:
On the location of equipment, what 10 is the scope of equipment that you would expect to appear at 11 a Tier I level information.
12 MR. IMBRO:
Pretty much everything.
13 MR. MICHELSON:
For instance, cable trays?
14 MR. IMBRO:
Yes.
15 MR. MICHELSON:
Small bore pipes?
16 MR. IMBRO:
Well, --
17 MR. GRIMES:
I think we define here on Tier I that 18 it's piping that's six inches and above within some 19 tolerance and then high energy piping 2 and a half inches 20 and above.
Now, remember that this is Tier I and not the 21 level --
22 MR. MICHELSON:
I'm just trying to find out, how 23 about in the case of cable trays, how would you expect that 1
24 to appear on a general arrangement drawing?
25 MR. IMBRO:
Basically, for the purpose of Tier I,
. ~ __
75 1
you have a zone blocked out so that you'd have --
l
()
2 MR. MICHELSON:
You just have a dotted line and 3
say they're all within that dotted line and that sort of l
4 thing?
5 MR. IMBRO:
Yes.
Also, to continue on, at the 6
time of design certification, you really would want to have 7
a cable and raceway schedule developed, but we couldn't 8
really put that in Tier I because a lot of that information 9
changes.
10 MR. MICHELSON:
Right.
I 11 MR. IMBRO:
At least the design would have to be 12 that far.
13 MR. MICHELSON:
The general arrangement drawings 14 I'm acquainted with aren't in that level of detail yet on t
15 any of them I'm seen.
How about small bore piping then?
16 Will you show a dotted line for the stuff under 6 inches or 1
i 17 do you just let them put it where they wish?
i 18 MR. IMBRO:
hell, far the Class 1 piping, we're 19 basically saying --
i 20 MR. MICHELSON:
That won't be Class 1 paging 21 necessarily.
It will be Class 3.
22 MR. IMBRO:
That's right.
23 MR. GRIMES:
That would not be covered in Tier I, 24 but it would be required to be -- the routing be completed.
c
\\
25 for audit.
4 s-
,gi.-
9 e-g 5$wa--
4----.n g.
pj w--
-, a w
s.w w-+--
y-.
w ~
- nav-
-*e-.-a w
g we
-r a-
_. ~. _ _ -
i 76 I
i 1
MR. MICHELSON:
How about -- for Tier I?
{
2 MR. GRIMES:
It would not be required in a Tier I.
)
i 3
MR. MICHELSON:
In Tier I,
-- okay, you're not 4
going to indicate what zones are dedicated to small bore j
5 water piping, for instance; or small bore steam' piping under 6
2 and a half inches?
I 7
MR. GRIMES:
The way we thought of approaching 8
that is that if the design has been carried to that level, I
9 then you will be able to audit --
10 MR. MICHELSON:
I think we're dealing with what 11 level does it have to be carried to to get certification.
12 The supplier will take it to that level.
13 MR. GRIMES:
There's.two different questions:
14 one, how far do you have to carry your design?
That is 1
15 available for audit.
The second ist what has to be 16 certified in Tier I?
17 MR. MICHELSON - Right.
18 MR. GRIMES:
So, we tried to restrict that 19 certified in Tier I to really key safet" related things that 20 we don't want to see changed.
21 MR. MICHELSON:
You don't think the routing of 22 water lines is something that --
23 MR. GRIMES:
Well, that's sometnias that they 24 could change as long as it does not impact their safety 25 analyses or their Tier I committment,
~.. -.
. =
77 1
MR. MICHELSON:
Okay, now we're getting to one 3
j 2
other point, of course, of this whole thing.
Forget all of 3
this; as long as it's safe, it's okay.
4 MR. GRIMES:
At a certain level.
i 5
MR. MICHELSON:
What do you mean, at a certain 6
level?
E 7
MR. GRIMES:
Below this Tier I in safety analysis 8
information; in other words, we're saying that your final 9
safety analysis addresses the key safety questions, 10 specifies key information that's specified here in Tier I.
11 There is other information which you must have done enough 12 engineering to know that what you've said is, indeed, 13 feasible and does not interfere with your committment.
14 You can change that other information later on 15 without restriction, as long as it doesn't change your SSAR 16 committment.
17 MR. MICHELSON:
How does this prevent them from 18 putting a 2 inch water line over an electrical board?
19 MR. GRIMES:
Well, that would change your 20 commitments that you would have done a safety analysis to 21 say you can't have adverse interactions.
We would have done 22 an audit to determine that.
23 MR. MICHELSON:
That takes precedence over any of 24 this?
25 MR. GRIMES:
Right.
1 78 1
MR. MICHELSON:
As I understand it, that has to 2
take precedence.
It's got to be safe, first of all.
i 3
MR. GRIMES:
Right.
4 4
4 MR. MICHELSON:
That's where the problems in the 5
past have come in.
People haven't really recognized that 6
putting a 2 inch water line over the electrical board was a-i 7
hazard.
Then later, you've got to take it out and change 8
it, and that's what we're trying to avoid this time; is all 9
that taking out and changing process.
10 MR. GRIMES:
Right, if they've done it down to the l
l 11 detailed level in engineering, they've got those things 12 thought through and they've got a substantial amount of 13 investment in it.
14 MR. MICHELSON:
I would be more assured of that if 15 I saw a zone for small bore piping identified and I knew it 16 would be within that zone and not over in the electrical 17 area.
But if it isn't on the drawings, then I just l
18 speculate that they're smart enough not to do it.
19 They won't be allowed to do it because later,.
20 clearly under the -- first of all, it has to be safe, no 21 matter what.
22 MR. GRIMES:
Right.
23 MR. CARROLL:
I was happy to see on that slide 24 that you had given some prominence to software V&V.
Now my O
25 concern is how are you going to do that.
Certainly you are i
1 79 l
1 going to mount a new effort to develop some iteria for 2
software V&V that goes beyond the standarJa we have right 3
now which are years old and not very good.
4 MR. IMBRO:
Sorry, that's really not my field of l
5 expertise but I think what we art saying is that people need 6
to develop these things upfront and that should be part of i
l 7
design certification so it is uniformly applied across all l
8 systems.
i 9
MR. GRIMES:
A few minutes ago Gene mentioned that i
10 for a unique advanced technology design you would expect a 11 prototype phase and have to reconsider the Staff's review 12 for a particular design.
()
13 MR, CARROLL:
I guess my problem is I don't see 14 the criteria the Staff is going to use in that area being 15 developed and we're not even sure the Staff has the kind of 16 people with the computer science background that is needed l
17 to develop it.
18 Hal Lewis and I have been concerned about this for 19 some time.
We probably will smoke the issue out pretty well l
20 when we have a meeting here in a month or so and bring in 21 Staff and all the vendors on this subject but we are 22 concerned about it.
23 MR. GRIMES:
I think we recognize the problem.
24 MR. CARROLL:
Recognizing and doing something 25 about things are two different matters.
80 i
l 1
MR. GRIMES:
That's correct.
First step.
02 1
5 (Slide.)
1 3
MR. IMBRO:
We talked a little bit before about 4
correlation of design finality and engineering hours and S
What design finality really means and I guess design j
6 finality is kind of an abstract concept.
At least I would 7
define it as a kind of a level of confidence that the type 8
of changes that will take place are relatively small and I
9 won't in fact impact to any degree the standardization.
10 Now what we are saying basically is -- let's go on j
11 to the next slide --
12 (Slide.)
13 MR. MICHELSON:
Design finality and design 14 completion don't mean the same thing, then?
15 MR. IMBRO:
That's right.
They are two different l
16 things.
That's right.
17 See, we're saying at this point we have broken 18 down this curve to indicate the four phases of design --
19 conceptual, preliminary detail, final and than they also had 20 a field phase.
21 What we're saying, at the time of design 22 certification we would expect that 50 percent of the j
23 engineering hours would be completed and at that point we 24 feel like, I mean, obviously this curve, you are not going O
25 to read it with the dividers but it's fairly broad but i
81 i
1 roughly about 85 percent of design finality.
2 This means that a lot of the design will be 3
developed from here on but it would be mainly in looking and 4
addressing vendor reconciliations when you get specified 5
vendor data, developing a lot of the design details that you i
6 need.
You know, when you find the exact nozzle locations 7
and you see the configuration and the equipment you know I
8 exactly where to spot it in the room.
I mean even though i
9 you have defined it upfront, up to this point you are going 10 to say, well, it's going to be about here. When you get the 11 vendors' cecific information you know exactly where you are 12 going to put it, you know exactly how you need to run the 13 last 20 feet of piping.
14 obviously you need to then perform in a final 15 stress analyses and all those other reconciliations that get 16 done so there is a significant amount of engineering that 17 gets done out here.
18 However, for all intents and purposes the design 19 is going to look the same.
20 MR. MICHELSON:
At what point -- well, what is the 21 difference between finality for tier 1 and finality for 22 items in tier 27 23 MR. IMBRO:
Well, I'm not sure how to answer that.
24 Tier 1 basically is frozen.
You can't change it 25 unless you go through --
J l
1
+
j 82
{
1 MR. MICHELSON:
At what point have we done i
t 2
everything it takes to know, yes, this is it?
Where do we i
3 reach that point?
4 MR. IMBRO:
Let me address your question, if I 5
can.
6 We are saying the design needs to be completed to 7
this level to give us confidence that we would gain because 8
we don't really see an as-built plant, so we want the design i
9 complete at this level of detail.
10 What we are going to certify in tier 1 though is I
11 probably back in here some place, see, but we're saying the 12 design needs to go this far and if I get the design this far 13 I am p::etty sure that -- I have a quite high degree of 14 confidence that this portion is not going to chance.
15 MR. MICHELSON:
Somewhere around 25 percent of the 16 input is put in when we have reached our final tier 1 17 design.
18 MR. GRIMES:
I guess i don't think we could say 19 that.
I think we'd have to say that because tier 1 includes l
20 a lot of NSSS things that are going into the final design 21 phase, for those aspects the primary system might be 80 or
)
22 90 percent of the engineering hours completed.
23 MR. IMBRO:
This is kind of an integrated curve..
24 Brian is correct.
We would expect -- actually if you go to 25 the next slide --
. - ~.
i 83 1
1 (Slide.)
t
()
2 MR. GRIMES:
-- I think it's on there.
3 MR. IMBRO This I guese answers your question, so 4
we are saying that the nuclear island is going to be greater 5
than level 2 so you would have basically the design finality 6
quite high.
t' 7
For the balance of the nuclear island and turbine 8
island, we have a design finality basically something like l
9 85 percent, okay?
10 (Slide.)
11 MR. IMBRot This is the same slide but basically 12 to show that at the time of design certification site 13 specific systems, since you really don't know the detailed 14 information about the site, are basically completed to a 15 conceptual level, maybe a little bit of preliminary design.
16 The balance of the nuclear island and turbine 17 island as we said we are treating the same and that is 18 basically completed.
You have a high degree of confidence 19 that that design is not going to change.
20 Certainly for the primary system and containment 21 and all of those things that we termed " nuclear island,"
22 those are going to be completed to a higher degree of detail 23 and the balance of nuclear island and turbine island and 24 will give you a very high degree of design finality in these 25 nreas.
84 1
MR. MICHELSON:
Now let me ask then, if I think O
2 that my estimate is that the total engineering hours for a 3
particular design that is going to cost us one billion 4
dollars, then to get certified I am going to have to spend 5
about a half a billion dollars of engineering?' Is that the 6
way I read that?
7 MR. IMBRO:
Yes.
8 MR. GRIMES:
There is a question of upfront money 9
here. We need the customer to kling this level.
10 MR. SIESS:
Wht is going to pay the second half-11 billion?
The first customer?
12 Who's going to pay which?
()
13 MR. GRIMES:
The second half would be addressed by 14 each customer that finalizes the design.
15 MR. SIESS:
Half a billion each?
16 MR. GRIMES:
Yes.
17 MR. SIESS:
I don't save anything by waiting for 18 the t..ird one?
i 19 MR. GRIMES:
Well, if you went in with the second 20 one to buy exactly the same components you could well save 21 that money but if you are going to buy it separately, buy 22 different vendor components for the plant, then you are 23 going to have to do the engineering to finalize the stress l
24 analysis and all the other electrical installations.
25 MR. SIESS:
That is a heck of an incentive though,
s 85 l
1 isn't it?
l O2 MR. CARROLL No, not really, because part of it 3
is site too.
4 (Slide.)
5 MR. IMBRO:
What we are saying also is that at the 6
time of COL that we would expect that the site-specific 7
systems would reach a completion level that would be equal 8
to the balance in nuclear and turbine island where they were 9
at the time of design certification.
Before you grant a 10 COL, you want the design finalized for the site-specific i
11 systems.
12 (Slide.)
( )
13 MR. IMBRO:
This was to try and lay out that 14 information on a time scale and obviously there's a lot of 15 assumptions built in here.
One of them is that you have a 16 customer at the time of completion of design certification.
l 17 We would estimate that in four years you could 18 basically get to the point where -- it depends on man-l l
19 loading.
There's a lot of things going here but I' guess our l
20 rough guess is that you could get to the point of design 21 certification in four years and if you had a customer 22 waiting at the door at the time of design certification it 23 would probably take you another two to get to the point.
24 where you had a COL and then from thera on we're assuming a O
25 four-year construction time, so that would take you out to
i 86 1
1 about ten years.
()
2 From start to finish we're looking at a ten year 3
process from the beginning of design until the time you 4
actually get the okay to go to power.
f
+
5 MR. CARROLL:
What would that same curve look like 6
for a second plant, assuming that I want to duplicate this?
7 MR. IMBRO:
You can cut out this point.
You would 8
have this.
This in a certified design.
Applicant would 9
come in, apply for a COL.
He'd need to complete the site 10 specific portions of the design and then also go out and 11 purchase all the components and do all your reconciliations 12 for the design that's embodied in the design certification
)
and proceed on from here.
13 14 You would probably save about four years roughly.
l 15 That's a guess.
16 MR. CARROLL:
Now suppose I went with the same 17 hardware as on the second plan?
18 MR. IMBRO:
I suppose you could save a lot of 19 angineering time -- you might be able to save a little bit.
20 I'a not so sure.
You still need to --
21 MR. MICHELSON:
I think you would save more money 22 than time.
23 MR. IMBRO:
Yes, right, because you need a lot of 24 time for the Staff review plus certainly it is going to take 25 still the same number of years to build it.
.m..
1 87 1
MR. MICHELSON:
Do you think a person is going to l
l l
2 buy his components before he gets a license to construct?
)
t 3
MR. IMBRO:
I think if I were out there I would be 4
start ordering them pretty quick, sure.
I mean at that 5
point you might --
l 6
MR. MICHELSON:
-- orders, as long as they have 7
the right clauses --
8 MR. CATTON:
That's the way the airlines, the 9
major airlines --
l 10 MR. MICHELSON:
Oh, yes, but they can cancel that 11 easily.
That gets expensive.
12 MR. IMBRO:
Marty is on for a wrap up.
()
13 MR. CARROLL:
Let me go back to your percent 14 design finality of the function or various hours.
Where did 15 you get that curve?
How did you --
16 MR. IMBRO:
Okay.
We got it basically by -- we l
l 17 went out to visit three architect engineers.
We talked with 18 Bechtel, we talked with Ebasco, we talked with United 19 Engineers and Constructors, we talked with Westinghouse.
20 Like I say, I wouldn't go ahead and put dividers on this and 21 read it precisely, but it's kind of a general intuition.
22 MR. GRIMES:
We also asked somebody we believe is 23 an expert in each of the design disciplines, who has been 24 through the design process in an AE or NSSS, to help us get O
25 a consensus on this.
So we had a small-group that we put
i l
l I
88 1
together for a month, and we did some thinking and got a l
2 consensus opinion based on the experience of the individuals t
l 3
we had.
i 4
MR. IMBRO:
It seems to fit with everybody's l
P 5
experience, even though it's hard to put a handle on, you 6
know --
t I
7 MR. CARROLL:
Well, if you showed this to Bechtel, j
8 they'd say, Yeah, it looks right, or to GE, or whoever.
9 MR. GRIMES:
I don't know what they'll say.
l I
10 MR. WILKINS:
Well,.if you erase the numbers on 11 the vertical scale, they'd probably agree with it.
t 12 (Laughter.)
()
13 MR. MICHElsON:
Broaden the line considerably.
I 14 MR. CARROLL:
How do you envision this really 15 going?
It'll be an NSSS vendor and an AE that'll jointly 16 come in with --
l l
17 MR. IMBRO:
Oh, yes.
Absolutely.
Yes.
You know, 4
18 I mean, if you're thinking about why the Part 50 plants were i
i 19 so different, I mean you had 50-some utilities and about six 20 AEs and four NSSS vendors, so, you know, you got all kinds
{
1 21 of permutations and combinations.
So it's not surprising l
l 22 that they're all different.
23 With the Part 52 process, basically you're' going l
24 to have an NSSS vendor and an AE married together.
So the 25 design is not going-to change and the utility is not really i
s 1
i 1
l 89 1
going to get in until after design certificating.
So it's
()
not going to be a whole lot of utility influence on how --
2 i
3 except possibly for the selection of maybe specific vendor.
4 MR. SIESS:
Where does the constructor get in?
5 MR. IMBRO:
Probably at the. point of COL.
I mean, 6
when someone --
7 MR. SIESS:
Because in the non-regulated industry, i
8 the best designs and best construction comes about wher; the 9
constructor's in from the beginning.
10 MR. IMBRO:
Well, I would expect that General I
11 Electric or any other NSSS --
12 MR. SIESS:
Who's the AE on the ABWR?
13 MR. IMBRO:
Bechtel, I believe.
I mean GE fell in 14 the back.
Is that true, John?
15 MR. CHAMBERS:
Yes.
John Chambers.. We don't 16 specifically have an AE, but we have used Bechtel in a lot 17 of our BOP design work.
18 MR. SIESS:
You're doing your own?
l l
19 MR. CHAMBERS:
We don't have a specific.AE as it 20 would have been traditionally in the past, but we have 21 subcontracted Bechtel to do a lot of our traditional AE 22 work, like BOP type things, structural type things.
23 MR. SIESS:
Now, Bechtel is both an engineering 24 dcsign firm and a construction firm?
v 25 MR. CHAMBERS:
Yes.
n w
, +., -. -, -,. - -
~.
~
90 1
MR. SIESS:
Were you utilizing-just their design O
2 expertise here, or was it also involving their constructic 3
experience?
4 MR. CHAMBERS:- Well, certainly, they feed back a 5
lot of their construction experience into their design.
6 process.
7 MR. SIESS:
I would hope so.
8 MR. CHAMBERS:
And we've used that.
Also, if 9
you'll look at the EPRI ~vguirement. documents, that document 10 addresses a lot of those aspects of the design, past 11 operational experience, past construction experience.
12 MR. SIESS:
Okay.
()
13 MR. CHAMBERS : - So it's gotten in there,-but'not 14 through the traditional "We've picked this AE process."
15 MR. SIESS:
Thank you.
16 MR. MICHELSON:
Before you leave, for the Japanese 17 project, who's doing the architect engineering?
18 MR. CHAMBERS:
That is Hitachi'on one plant and 19 Tochiba on the other.
4 20 MR. MICHELSON:
Now, it's my understanding, but 21 correct-me if I'm wrong, but the> nuclear island, the reactor 22 building essentially is all the Japanese design on the ABWR.
23 MR. CHAMBERS:' Yes.
24 MR. MICHELSON:
So we're really looking at that j
25 Japanese architect / engineer, which was, I think, a.more d
I
.~
91 1
correct answer.
Now, on those portions that you have to 2
alter because you can't meet the Japanese design, the 3
control building has been moved, the turbine building is 4
oriented differently, and for those portions, it was my 5
understanding you would be using just an architect / engineer l
6 in the US.
.{
7 MR. CHAMBERS:
That's correct.
i
.8 MR. MICHELSON:
Yes.
\\
~
9 MR. CHAMBERS:
That may be a more accurate l
10 interpretatiors of --
l 11 KR. MICHELSON:
But the nuclear. island is all 12 Japaneso, including architect engineering, construction, the
()
13 whole bit, iff I understood the; situation correctly.
3 14 MR. CHAMBERS:
Yes.
l 15 (Slide.]
16 MR. IMBRO:
I didn't remember I had-a final slide, l
17 but what this tries-to portray in a graphical sense'is the 18 volume of information that would be included in the r
19 different portions of the design -- well, let me explain it-1 20 easier than to characterize.
t 21 Tier 1 and Tier 2 --'these two circles would~
22 comprise information that's.in the SSAR.
This annulus here 23 that says "available at design certification".would.be the 1
24 additional information, design information, that would be 25 resident at the AE or design organization.
A a
4 ;
- ~.
92 J
l The top and the outer circle, then, would 2
represent how far you could really. push the design if you l
3 wanted to develop all the details.
This again is at design 1
l 4
certification, which means you do not have vendor specific l
5 information or as-built information available.
j 6
So I think the message tera is that.we're pushing 7
-- at least we feel justified from a safety viewpoint to~be 1
,1 8
able to make a safety judgment that we'd like to have nearly.
9 all the information that it's possible to generate.-
10 Now, certainly, there are some things that you-11 could generate, but it would be very manpower intensive, l
12 wouldn't really change standardization a whole lot.
So' l G 13 there's really no point in doing certain things, but-for'the O
14 most part, I guess-at this point, you have the, capability.
15 then to be able to prepare purchase specifications without 16 additional engineering.
l-17 MR. MICHELSON:
I guess your regulatory guide will i
18 tell me how big those relative areas are going to be.
19 MR. IMBRO:
Yes.
l i.
20 MR. WILKINS:
The slide can be very misleading.
l-21 MR. MICHELSON:
Yes.
22 MR. GRIMES:
One other point before:Marty. wraps up 23 that I guess I'd like to make.
The key difference between 24 the Part 50 process, from the staff's point of view, and the 25 Part 52 process when you're reviewing this is that ir. the
93
,t 1
Part 50 process, we had a real plant walk-through and a look j
(~'/
r
(,,
2 at before we granted the operating license.
3 Here, we are making final safety determinations as 4
we woul.d at the operating license stage, both for design 5
certification and at COL issuance without a physical plant.
6 So we think it's really important to take a lot of 7
systems, anything that could.possibly' impact the safety of' t
8
-the plant, to-a fairly good. level, to a-detail design-level, 9
so we really know that the decision we are' making will hold 10 some water over the years..
l 11 MR. SIESS:
Am I correct that I could not use the 4
12 ABWR Review to see specific examples of the Tier I, Tier.II 13 stuff?
14 MR. GRIMES:
Not yet.
(
4 15 MR. SIESS:
Now, I got the impression that because-16 they're actually going to build those plants that there's f
4 17 more information available at this stage than there would be-
- q 18 otherwise; that there might be more-information_than would 19 be required for subsequent design; is.that right?
20 MR. GRIMES:
Well, I think you have to think'about j
21 a couple things.
My understanding:is the Japanese plant is 22 a two unit facility that may share some systems.
As Dr.
1 23 Michelson mentioned,.some of the arrangements of buildings.
24 are being changed for.a single unit.
l O
25 MR. SIESS:
I'm' talking about down at the nitty-y f
1
94 l'
gritty details of the Tier I, Tier II stuff.
O2 MR. GRIMES:
I think.that unless there's a I
3 decision made by GE -- and perhaps GE will Want to address' 4
it -- to adopt the exact design that.has been arrived at in:
1 5
Japan, it could be very different.
If GE decides'to 6
translate documents and use that~same information, it could 7
be very similar.
8 I don't know what the actual situation is.
9 MR. SIESS:
By very different, you mean that: lists:
10 of the plant would be Tier I, Tier.II or-more of the. plant l
11 would be?
12 MR. GRIMES:
No, I'm saying that at the present i
13 time --
14 MR. SIESS:
Now, I'm not' talking about the detail 15 of, the specifics of a pump or a valve or a. pipe run or a-16 cable tray run; I'm talking about-the classification of 17 what's Tier I, what's Tier II and how much information'you 18 have.
19 MR. GRIMES:
No, I don't:think our definition 20 would change on what we would desire, based.on what's l
21 available.
22 MR. SIESS:
I guess I can't-get.through.-
Forget-23 about it.
24 MR. GRIMES:
Well, try again.. Th'at's what we're
- O 25 here for.
II 95' 1
MR. SIESS:
Well, I got the impression and maybe I O-t got it from Carl and not from you, that you were going to 2
1 3
have a lot more detail available at this stage, at a given l
l 4
stage on ABWR, because somebody was actually planning to 5
build it.
6 Now, I would like to look at an actual y
7 certification process as to what degree of detail is
]
8 required, et cetera, et cetera,.rather than this abstract 3
9 stuff that we're hearing here which, presumably, the 10 Commission wants.
I got the-impression'that I couldn't use i
11 the ABWR that way!'that they would always have more' detail.
12 than the minimum you require.
l ()
13 MR. GRIMES:
I think if GE wishes to adopt the
-t 14 level of detail that we're talking about here,1then we would-15 have a very good fit with what our requirements are..
16 MR. SIESS:
I guess I'm trying to find some-17 reason why.we're going.through this very involved process of j
18
-- in what I c all the abstract rather than doing what we 19 have to do on two actual physical cases that.we have before 20 us.
21 MR. VIRGILIO:
Brian, let me help a littl'e bit.
22 In our paper right-now, we include an analysis based on 23 audit we conducted at GE in February.
Gene led the team out 24 there -- of how BWR, the proposed ~BWR currently stacks up to-25 what we have outlined to.you today.
It's a fairly detailed 1
l
-96 1
analysis.
1 0'
i 2
It's a substantial section of the paper, and it 3
takes you through the different-categories that' Gene 4
outlined and tells you specifically whrere we believe~they 5
are at Level II and where-we believe they have not reached 6
that Level II design _ detail, at that time, that being back 7
in February when Gene conducted the audit, t
8 MR. SIESS:
There are some real advantages in-9 learn-as-you-go, and in this case, I don't see any
.[
10 disadvantages because the rule-is already written.
The only 11 thing that.you're likely to change as a result of what you 1
12 learn as you go is a Reg Guide which isn't that big a' job.-
(
13 MR. GRIMES:
I think thatlfor the first time, 14 we're really defining. things in terms of design products 15 that we want to see.
If each staff discipline tries to do-16 that during the review process, I think it's going-to j
17 greatly extend the process.
i 18 What we're trying to do is get an upfronti 19 agreement --
20 HR. SIESS:
But you're not-up: front on.GE.
21 MR. GRIMES:
.No, I think we are.
We are still 22 ahead of GE domestic design.
23 MR. SIESS:
You think so?--
24 MR. MICHELSON: ~WEll, you should be careful ~though 25 to point out that when you.went out there-to look, which was f
m.
. m
97 j
1 last Fall, was roughly two years this past February.
That 2
is still roughly two years before you can anticipate an FDA.-
3 I don't think you're going to get an FDA at the l
4 end of '91, for instance, but maybe you disagree.
Let'slsay 5
it's in the middle of '92.
You're 18 months and'in 18-6 months there will be a lot more progress made.
7 Have you accounted'for that?
In other words, are l
8 you talking about where they would be at the time they.would 9
be ready certification?
Are you talking about where they 10 are today?
That's two entirely different-things.
l.;
11 MR. GRIMES:
It could be that unless we clarify 12 our intent here, that there might be no more designs done by 13 the time of certification.
What we were trying to do is to~
14 clarify our intent so that there is this. level of design at 15 the time of certification.
16 MR. MICHELSON:
I think that for tne purposes of 17 answering the question, it should be made clear 1 that you 18 looked at it way before certification being anticipated.
19 MR. GRIMES:
Yes, and really before the 20 construction plans.
21 MR. MICHELSON:
I'm not surprised to then' observe 1
22 that, yes, there's a lot more that needs to be done before 23 certification could be envisioned, yes.
24 MR. SIESS:
How is that any-different than any 25 other certification?
7 i
1
' 9 8' 1
MR. MICHELSON:
Well, the whole point of this 2
exercise, if I understand it' correctly, is somehow we have
~
3 to identify what we expect a vendor to come in with:so we 4
grant an FDA and go on to certification.
l 5
We're trying to identify what level of detail we.
J I
6 want them to submit.
Presumably, that will'be all the more 7
they have to subait or have available then.
l 8
MR. GRIMCS:
Both submit in an application and' 9
he ra available, i
10 MR. MICHELSON:
We're trying to identify that 11 amount because some people, if they~ don't have a customer, 12 they can't afford to invest any more than that amount into i
13 this project.
14 MR. GRIMES:
A submittal for applicatien isLgoing 15 to be similar to what we see at an FSAR stage of the Padt 50 16 process.
17 MR. SIESS:- You're going to get all your requests-18 for additional information and all your questions out in l
19 advance?
20 MR. GRIMES:
We'll do'that --
i 21 MR. SIESS:- On a great many of them.
22 MR. GRIMES:
In the review process of the Tier.I,
~
23 Tier II submittal of the application of the SSAR; that-24 process will keep going on.
The staff will review that,.
< O 25 also be auditing the specific design process -- prod'uct, i
s
1 99 1
rather, to see that the commitments are carried out.
02 MR. MICHELSON:
Had a couple of questions on level l
3 of detail which I think are the.ones that' Gene should-be 4
answering.
j I
5 MR. VIRGILIO:
Let me'just-wrap up'and then we can l
i 6
have a --
i 7
MR. SIESS:
Well, you can wrap up and we can go 8
back.
9 (Slide.]
10 MR. VIRGILIO:
I just_ wanted to clarify where we i
11 are in the process right now.
We have a paper that responds 12 to the August SRM in concurrence.
We're going to try to get
()
13 that up to the EDO at the end'of this week.
14 They've tentatively scheduled a Commission meeting 15 sometime in the end of November..They're holding a couple-16 of places open on the 28th and the 29th.
Basically, we're 17 going to ask in that paper -- we're going to' respond to the-f 18 commission, first, and to the seven questions'they asked us, 19 and we're going to ask the Commission to support our staff 20
.proposhi on a graded approach toLdesign finality that Gene 21 discussed, Level II and greater; to support the staff I
3 22 proposal on the content of the application and the 23 certification.
24 That which is to be: certified will be identified O
25 in the commission paper in the tables that will eventually.
1
-~
100 1
be incorporated or form the basis for a Reg Guide, and also-0 2
for the Cormission to support the change process that we're 3
proposing.for the material in the application, certification 4
and held for-audit as I discussed earlier, at the different 5
phases before design cert, after design cert and after COL j
6 and after authorization to operate.
7 We're asking the commission to authorize.the.
8 development of the Reg Guide that we've been talking,about t
9 today, although much of the work that's necessary-to.
10 finalize that Reg Guide has essentially been completed by 11 the staff at this time.
12 That pretty much summarizes the presentation and 5
13 now we're ready to respond to questions that'you might.have.
14 MR. SIESS:
The Reg. Guide has or has not'been-15 completed.
16 MR. VIRGILIO:
The work of the Reg. Guide is 17 essentially complete.. I think at this time we'd be-18 finalizing it and putting it out for public comment and --
19 MR. SIESS:- Going to bring it to the'.ACRS?
20 MR. VIRGILIO:
Certainly.
21 MR. SIESS:
I mean, usually, it takes the ACRS 22 about two months, you know,.to schedule something,.and you.
t 23 say it's already done.
I was wondering why.we hadn't at 24 least seen a copy.
25 MR. CARROLL:
Because he hasn't had.it authorized.
.I
101 1
MR. GRIMES:
The Commission' authorized this-whole 2
approach first, but when you see the Commission paper you g
3 will also have available at that time the contents'of the 4
Reg. Guide.
5 MR. MICHELSON:- We'll get a draft Reg. Guide at.
i 6
that time?
7 MR. GRIMES:
It probably will be finalized within 8
the next two weeke.
9 MR. WILKINS:
I noticed today.that there was an 10 agenda item which didn't occur,:namely, the-NUMARC 11 presentation and that compels me to ask whether you are 12 aware of NUMARC's reaction to the proposal that you're 13 planning to take to the Commission and is it likely to be
()
14 adverse or enthusiastic?
I recognize.you're not NUMARC, but 15 16 MR. VIRGILIO: 'This is the first time we've 17 discussed the contents of the paper in a public forum so l
l 18 they have not had any reaction.
19 MR. WILKINS:
They haven't seen it.
~
20 MR. VIRGILIO:
Based on our last meeting when we 21 had NUMARC here before you, they' discussed Level 2 as~being _
l 22 the target, and they thought that-they had Level 3 and were 23 approaching Level 2 on'many systems.
24 MR. WILKINS:
There might have been-some O
25 differences of opinion'between the staff-and NUMARC as;to
102 1
what is in-Tier 1 and what is in Tier-2, however.
i 2
MR. GRIMES:
My guess-is we're recommending more 3
than NUMARC had intended for Tier'l and probably more than I
4 NUMARC envisioned would be available for-auditi..
5 MR. CARROLL:
At the last -- or at the meeting.you 6
referred to, we had some seeming differences of opinion.
7 between an attorney that represented:NUMARC and OGC on some 8
of the procedural things.. I don't even. remember what they 9
were.
Do you feel those have all been reconciled?
10 MR. VIRGILIO:
Well, again, thisais the first time 4
11 this has been aired in public.
Oneiof-the issues that we 12 discussed at that time was finality - ' issue resolution.
13 That seemed to be the big issue,'and I would'. hope that it's 14 resolved, but I don't know.
We've had no feedback at all' 15 from the industry since this is the first airing of this in 16 public.
17 MR. CARROLL:
Okay.
When we talked about your 18 time curves here on finality versus engineering hours, etc.,
19 you also sort of related this to a billion dollar-program to 20 complete the whole thing.
21 MR. MICHELSON:
I don't think-the staff mentioned 22 a-billion dollars.
I happened to-have used it only as an 23 example.
24 MR. GRIMES:
It is probably a reasanable estimate.
25 MR.-CARROLL:
Okay.
That was my question.
Why is
d
- )
103 j
1-it a reasonable estimate?-
What is your basis for that.
2 number?
3 MR. GRIMES:
Again, it's talking to people who 4
have built these plants and talking to some individuals that j
\\
a 5
have been involved in the process.
1 6
MR. IMBRO:
Mostly because the AE estimated eight i
1 7
to ten man hours so --
1 8
MR. CARROLL:
Now let me-ask this question.. With 9
Standard Review Plan 17.3 on the street, which seemed to me 10 to envision perhaps less Mickey Mouse in the QA world-of 11 designing a power plant, have any.of them come back and 17.
said, hey, did you really mean what you're saying in-17.3 if-'
- 3 the cost goes down from a billion dollars to a hundred 14 million or something?
i 15 MR. IMBRO:
Hopefully, QA does not have that big 16 of an impact, but no one has mentioned it.
17 MR. CARROLL:
They really haven't had 17.3 very 18 long.
But I kind of have the-feeling'that if -- I mean,.
19 they're always going to -- until they actually have some I
20 experience with how the staff's going to implement it, 21 they're always. going to be conservative, but I really think 22 it could have a. fairly large impact on the cost.
y 23 MR. IMBRO:
I don't really have a feel for that.
24 I think it recommends more a. performance-based audit rather-25 than bean counting
E h
104 1
1 MR. SIESS:
There's a-lot more than performance-
.2 based audits in 17.3.
3 MR. IMBRO: I do not have a detailed knowledge of i
4 that.
7 5
MR. CARROLL:
In fact, an organization in 17.3 6
could function quite nicely and not have anybody that has 7
the words QA on their'hardihat.
I guess I would throw that 8
out.
I mean, people have got'this mind set about a billion-9
. dollars, and I'm not sure that that really is what's going 10 to eventuate if the people that are pushing.17.3 mean what' 11 they're saying.
12 MR. GRIMES:
I think there are also other 13 technology changes;like computer-aided design that could-14 affect the back end,Jthe last'50% of the engineering we 15 talked about.
If everything was on a computer-aided design-l 16 system those final changes might be somewhat less; intensive.
17 MR. MICHELSON:. Does that take care of your 18 questions?
19 MR. CARROLL:
Yes.
20
' MR. - MICHELSON:
I have a question on.the -- in 21 talking about 50.59 type--changes in the future'-- there was 22 a document prepared'by NSAC -- NSAC 125 -- which talked
(
23 about possible interpretation of 50.59.
That' document was i
24 written without any evolutionary reactors in mind, I 25 believe.
-l 105 1
The staff, to varying degrees, is' working on,-
]
2 perhaps, endorsement of -- reinterpretation of how you do
')
3 50.59.
In that process are you also going to start telling
(
4 people how to do 50.59 for evolutionary plants?
5 MR. VIRGILIO:
No.
But let me say this ---
l 6
MR. MICHELSON:
Well, then how do.we' interpret?
l 7
Will the Regulatory Guide cover all this interpretation of 8
50.59 then?
9 MR. VIRGILIO:
I don't know that there's an 10 interpretation of 50.59.
There's an' application.
I:think; 1
11 we're proposing to use the same 50.59 and'the same tests for 12 unreviewed safety questions.
13 MR. CARROLL:
That's very much just.the starting 14 point.
And 13.you look at what's going on out-in industry j
i 15 today you will find a tremendous varjation in how.different I
16 utilities are applying this.to the operating' plants.
That's t
i 17 what the NSAC document is attempting to deal with.
18 MR. VIRGILIO:
Yes.
And as a matter of fact 19
.what's different about the application would be.that they
~
20 won't be able to change what's in Tier 1 under 50.59.
21 MR. MICHELSON:
Where's that interpretation going i
22 to be explicitly stated and to what --
23 MR..VIRGILIO:
In the design certification itself q
24 is what we envision.
25 MR. MICHELSON:
Well, that's a late game -- a late h
.l 106 1
1 time in the game for that.
I think it has to be either in a~
f 2
Regulatory Guide or in a regulation as to how we're going to i
3 use 50.59 for evolutionary plants.
4 MR. VIRGILIO:.If the Commission enitorses this
.f
(
)
5 paper, we will.have-accomplished'that goal.
6 MR. MICHELSON:
'It will be defined-in the paper?
'I 7
MR. VIRGILIO:
Yes.
8
.MR. MICHELSON:
Okay.
.I'll look for it in the 9
paper.
i Li 10 MR. VIRGILIO:
But in essence it's the same test.
- L 4
11 It's the same test for unreviewed safety question that is l
12 defined in NSAC 125, and, basically, we~would --
..3 MR. CARROLL:
But the problem-is that I can write
{
}
13 14 one paragraph and say I've done.a safety evaluation under.
t 15 50.59 and I meet all of the three tests.
'For this very same d
l l
16 situation, you 5:now, I can write a book.
It just depends on 1
i 17 how you really. interpret those words-in 50.59.
So just
.j 18 regurgitating what 50.59'says isn't guidance.
i 19 MR.'VIRGILIO:
Yeah.
I'm not an expert on 50.59, i
i i
20 but rs I understand it we are allowing.the industry some a
~
21 time to implement NSAC 125.
We're currently in the process 4
22 of developing inspection-guidance --
23 MR. MJ.CHELSON:
But NSAC 125 has nothing to.do q
i 24 with the evolutioaary plants.
25 MR. VIRGILIO:
That's right.
i 6
i 1.J.;
_ _ _ - - - _ _ _ _ _ _ _ _ ~ _ _ _ - _ _ - - - _ _ _ _ _ _ _ _ _ _ _.
I 107-1 MR. MICHELSON:
I'm only asking my_ question on_the 2
evolutionary so let's stick to that.
How are we going to 3
tell the industry to implement 50.59 type decision making 4
for the evolutionary plants?
Whers will that be?
Will it 5
be in a Reg. Guide or --
4 6
MR. VIRGILIO:
The first step will be this 7
Commission paper and then the second step would be likely
(
8 incorporated in the Reg. Guide or. Reg. Guides that we:
9 promulgate to support --
10 MR. MICHELSON:
So I will look'for more 11 amplification when the' Reg. Guide is-available.
12 MR. GRIMES:
But remember that'the real test,'I 13 think, is going to be when that certification is granted and 14 the condition is put in there-and talked through-with:the 15 people --
l 16 MR. MICHELSON:
Well, I don't know what degree E
17 finality has to do with all this, but I_think I've already 18 passed the finality point by that' point.
And I want to know 19 what I've agreed to, finally, and'it's going to have to be 20 before we reach that stage.
21 MR. VIRGILIO:
If I didn't mention it earlier, you.
22 need to recognize that 50.59 itself is culled out in Part.
23 52.63.
I That we understand, and it's being l
24 MR. MICHELSON:
25 interpreted now in new ways for certain purposes,.and it has l
I
?
108 1
to be interpreted for this purpose, I think, in some.way.
O2 i
MR. VIRGILIO:
I don't think it's being.
.-l 3
interpreted in different ways.
We're proposing to apply it 4
at different times in the process.
[
5 MR. MICHELSON:- Clearly the NSAC interpretations 6
are not what we need here.
We need some -- and if 7
interpretations were needed, and apparently th'ay were or 8
they wouldn't have written NSAC 125, then I'm saying there.-
q 9
has to be a companion type of approach for the evolutionary if 10 plant determinations.
j 11 MR. VIRGILIO:
Are you looking for another; test j
12 that would further inst.re standardization?
-I guess I'm-13 trying to understand your interest.
14 MR. MICHELSON' No.
I'.m just.looking for -- I 15 would like to know how a utility can make changes.to these 16 designs, what kind of process they will follow and so forth 17 so I'm assured that it isn't going to really affect-the 18 basic safety of the plant.
And I'd likerto know how that's 19 done.
Well, 50.59 has a few good words in it, but it can be 20 interpreted in many different ways and that's why NSAC 21 finally wrote the 125 if I-understand correctly.
22 And the 125, though, didn't address how.you do-23 this for evolutionary plant determinations, only for 24 operating -- present day operating plants.
o 25 MR. VIRGILIO:
It will be addressed'in the paper.
L L
1 l
109 1
MR. MICHELSON:
It will have to be addressed O2 somewhere.
P 3
MR. GRIMES:
I guess I don't see too many 4
differences that would not be applicable.
If you don't have
~
5 an operating plant, you don't have to consider. current 6
operating conditions as you make the change, for example.
7 But most of the document, I think, would be-directly 8
applicable.
9 MR. MICHELSON:
And it may only take one paragraph 10 to say it.
I just think that should be. cleared up, though, 11 before we finalize thase documents.
12 Another question, Level-2, by' definition, talks
-[}
about structure systems and components-affecting' safety.
13 14 Now, presumably, then Level.;t designs.doLnot apply-to a 15 nonsafety air system if it doesn't affect safety or a 16 nonsafety water system if it doesn't affect safety,.and so 17 forth.
l 18 MR. VIRGILIO:
If there is no nexus to safety, l
l 19 then we cannot require it.
20 MR. GRIMES:
If we think there-isEa nexus, 1
21 however, we could address it.
22 MR. MICHELSON:
Well, I am just-looking strictly 23 purely at your definition of Level.2 in the SECY 241.
24 That's all I'm looking at right now.
And 'iti does-definitely O
12 5 have the words "affecting safety," which is new term, by the
- 110, 1
way.
It's not important to safety, it's not safety-relate'd, 2
it is some new term called "affecting.shfety," whatever that 3
is, f
4 MR. GRIMES:
That's why we're going to define by 5
groups of systems and by specific design products what:it 6
means.
7 MR. MICHELSON:
Okay.
Now, really, what I Was 8
leading to -- I'm just chatting a little bit --.I think-9 "affecting safety" wasn't the right word, but you'reigoing\\
10 to have to define it if you're going to invent a new term.
11 It's not a regulatory-term.
12 MR. GRIMES:
What we would not like to argue-about 13 or put on general terms is if we have enough detailedi--'
14 that's clear to everybody what we mean.
15 MR. MICHELSON:
Now, the thing I really am leading 16 to, though, is when doing hazards analysis, such as we ch) 17 for severe accidents,-for instance, when we do fire hazards i
18 examinations, pipe-break, internal flooding, seismic, and so 1
19 forth, we hav9 to have a considerable knowledge of the' 20 surroundings to the event, what is in theEneighborhood of 21 the fire or the pipe-break or whatever.
We have to have 22 that in pretty fair detail.
23 In fact, nowadays, the only way we could'do:it is 24 to do a walkdown of the full-scale model. We-aren't going to O
1 25 have that privilege in the case of future reactors.
But i
j c
s L
111 1
yet, you're going to have to assure me that there isn't>an 2
undue fire hazard or an undue flooding hazard and so forth.
3 How are you going to do that.with the level of detail that 4
you prescribe?
5 For instance,-you may only_tell me cable trays 6
will be on that side of the room.
I. don't know what's in p
7 them, don't have to know.
That level of detail wasn't 8
required.
9 MR. GRIMES:
I think.you will have to know what's l
10 in them.
11 MR. MICHELSON:
Well, now that's a new level of 12 detail.
It's a level of detail, I think,_more than intended 13 under Level 2.
14 MR. GRIMES:
I don't think so.
15 MR. MICHELSON:
Well, okay.
t 16 MR. WILKINS:
It's more than you folks have been i
17 saying.
18 MR. MICHELSON:
I think it's more than you've been 19 telling 1me all morning.
20 MR. VIRGILIO:
Certain analyses will push the 21 design.
We had GE come in and give us a presentation on 22 this, and.they said that they found 300 of the 3,000 23 elements that the needed to complete the, fire-hazards 24 analysis in the FSAR, but they had to develop'those details 7-V 25 in order to complete the fire-hazards analysis.
m-m r,-,-.
\\
112:
1 MR. MICHELSON:
Their hazards analysis, by the J
2 way, is another whole story, which we're going to get into.
3 I don't even want to comment on it right now.
.I think j
4 they've got a long way to go.
5 M3. GRIMES:
I think Gene mentioned earlier that i
6 for the detailed design, we would expect schedules of what l
7 goes in.
- i l.
-8 MR.-MICHELSON:
Okay.
You would expect locations-i 9
of all electronic components that would be~ vulnerable to-10 whatever you're worried abouti in that area,; be it flood or-11 fire, whatever.
So, I got to know where allithe inverters-12 are in the room, if there are inverters.in the. room.
I!O 13 That doesn't appear on any layout: drawings I am
'V I
14 familiar with in t.erms of general layouttof the kind we've-l 15 been talking about.
16 MR. GRIMES:
That appears in' detailed design 17 documents.
.i 18 MR. MICHELSON:
So, when'they do the-hazards 19-analysia, they w!11 have to have that level of. detail 20 developed.
It won't have.to be defined as a.part..of' 21 certification; it won't be in the certified design.
But the l
22 fire-hazards report, which used all this detail, where will 23 it be in the certification process?
4 24 MR. VIRGILIO:
Typically, it's been included as a O
25 reference to the FSAR.
l-l
=
113 1
MR. MICHELSON:
It's not-a reference.
It is in 2
the FSAR.
In the case, at'least, of ABWRs, the hazards 3
analysis is there.
4 MR. GRIMES:
I think the detail of the hazards
-l 5
analysis would be available for audit.
The results would be l
6 reflected in Tier 1 and Tier 2.
Now, the conclusions'you 7
draw from that.would be reflected, and.if those conclusions i
8 change, you would have to make it right.
9 MR. MICHELSON:-
So, you will have to develop the 1
10 design to the extent of being able to do these various types 11 of hazards analyses.
The details you use would be available 12 for audit if-anybody wants to look at them.
13 MR. GRIMES:
Yes.
And1again, the hazards analysis 14 may not be the final hazards' analysis, but it would-have to 15 be what you do before you get vendor-specific information.
16 You might have to go back and make some adjustments.here.
s-a 17 MR. MICHELSON:
Along the same lines of reasoning, 18 in the case of ABWR, at least, and I-think the standard 19 review plan requires the fire-hazards analysis to be a part i
20 of the SSAR, if I recall correctly, in 951.
-l 21 Now, 361 requires that you do a pipe-break 22 analysis.
You assume these various breaks outside of 23 containment,'and you.use 361, 362, and 363 to make your 24 determinations.
O 25 l
That type of material was traditionally submitted I
I 114 1
separate from the SSAR, because it came in in.1973, when the 2
flap started, and thereafter, I don't believe they have been 3
putting the reports as a part of it.
In the case-of ABWR, I 4
do not find it as a part of the submittal.-
5 Yet,'the Standard Review plan requires pou do such 6
an examination.
So, I thought if you were-required to do j
I 7
it, it ought to be a part of the. safety; analysis report.
i 8
MR. GRIMES:
I think the results have to be 9
summarized.
10 MR. MICHELSON:
So, the way we'd handle that, the 11 results would be summarized, the report would be.----it would 12 be a docketed report.
No, wait a minute.
I assume the 13 pipe-break report would be a 6ocument that is docketed.
14 It's not just something somebody did-and if you.want to see 15 it, you can go off and see it.
16 MR. GRIMES:
I don't know what we do currently.
17 My impression is when the --
18 MR. MICHELSON:
They were docketed-'in '73.
They 19 vere all docketed.
You had to send'it in formally.
It was 20 a request.
1 21 MR. GRIMES:
I guess that's beyond --
22 MR. MICHELSON:
Okay.
We'll-get into that later.
23 But whatever you need to do to do such types of seismic and 24 fire and flooding exarainations, that would all be a part of O
'25 this process and would all be completed before FDA.
l
l 115 1
MR. GRIMES:
Yes, before the design certification.
O2 i
MR. MICHELSON:
Wait a minute.
I said FDA.
,You 3
can't go into certification until you've got an FDA.
4 MR. GRIMES:
Yes.
5 MR. MICHELSON:
And certification isn't suppoced 4
6 to'mean more technical work.
t 7
MR. GRIMES:
Right.
8 MR. MICHELSON:
It's supposed to be purely -- as I I
9 understand, it's supposed to be a procedure to just go-10 through the rulemaking-and soEforth, to give the public a
11 their chance.
So, we're done at the FDA stage.
12 I'll look for all of -this.as a part of the --
(}
13 before the FDA.
14 MR. GRIMES:
Yes.
15 MR. MICHELSON:
Okay.
i 16 MR. GRIMES:
It may require some additional 17 changes if matters were brought up.
18 MR. MICHELSON:
Do any other members haveyany 19 questions?
We're at about the end of our scheduleditime.
20 Chet?
{
21 MR. SIESS:
I was just trying to figure'out where t
22 our present speakers are-from in relation to the,peopl'e that 23-are doing the ABWR review.
Any overlap?
24 MR. GRIMES:
Yes.
Charlie-Miller-is' Branch Chief 25 for the group that is coordinating that review.
a
e 116
^
1 MR. SIESS:' So, you do talk to each other.
()
2 MR. GRIMES:
Absolutely.
3 MR. SIESS. And you see all the requests for 4
additional information and all the question that go out on 5
ABWR, or he does.
6 MR. GRIMES:
He does.
.i 7
MR. MICHEISON:
One final note of business: L We i
8 have a full Committee meeting, and I believe -- what is11t,=
9 11:30, 10:45?
From 10:45 to 11:15 next Thursday, we are 10 asking the staff to come in and tell us the status of the 11 scope-of-design problem in a very summary form.in 12 preparation for the Committee to go to talk to the i
13 Commission that afternoon.
14 MR. GRIMES:
De you have any-guidance on what l
t l
15 parts we should emphasize?
16 MR. MICHELSON:
I assume, by that time, you will.
17 have the draft SECY for'us and so forth.
Will that be in 18 our hands then, or do we still have to talk ~about it?
19 MR. VIRGILIO:- I would assume it would be, i
20 MR. SIESS:
You can't talk to the Commission about 21 a draft SECY.
22 MR. MICHELSON:
No, no.
We're talking to the 23 Commission about the draft.
I just wondered if the 24 information would be in our hands.
In other words,-how-much l
O 25 more information can-they give us?
It's clearly to i
l'l'
117 1
summarias what you've done today.
l 2
MR. GRIMES:
Let us explore that aspect.
i i
3 MR. MICHELSON:
I think I'd leave.up to you, but i
4 you have to compact this down to 30 minutes, no more than 30 5
minuter,.
We've got a total of 45.. You've got to do about'a 6
20-minute summary.
So, I will leave that totally up to you.
l I
7 MR. GRIMES:
Thank you.
8 MR. WILKINS:
He's all heart.
i 9
MR. MICHELSON: _ You know, tell us exactly where l
10 you're at, so the Committee members know directly from the l
11 staff where the staff is at.
I wouldn't try to go into all 12 the details like we did today, because this is a different
()
type of meeting entirely.
13 14 So, with that, are there any other questions?-
)l 15 (No response.]
16 MR. MICHELSON:
If there are not, then this i
i 17 meeting is adjourned.
18
[Whereupon, at 10:55, the meeting was adjourned.)
19 20 21 22 23
-i 24 5
(
25
1 f()
REPORTER'S CERTIFICATE l
h This is to certify that the atteched proceed-l ings befoce the United States Nuclear-Regulatory Consission i
in the macter oft NAME OF PROCEEDING: Improved Light Water Reactors l
DOCKET NUMBER:
PLACE OF PROCEEDING: Bethesda, Maryland l
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting
?
by me or under the direction of the court report-ing company, and that the transcript is a true and accurate record of the foregoing proceedings.
1 Jns)
(l '
Official Reporter Ann Riley & Associates, Ltd.
4
i STANDARDlZATION AND PART 52 LICENSING r
l OCTOBER 31,1990 l
l l
M.VIRGILIO, ASSISTANTDIRECTOR REACTOR PROJECTS, NRR 301-492-1353 G. IMBRO, SECTION CHIEF SPECIAL PROJECTS BRANCN, NRR 301-492-0954 SUBCOMMITTEE ON IMPROVED I
LIGHTWATER REACTORS
O O
O
~
~
4 j
LEVEL OF DESIGN DETAll i
i MAIOR MILESTONES r
- SECY 90-241 JULY 11,1990 l
- COMMISSION MEETING JULY 18,1990 l
l
- GRIMES /IMBRO BEGIN JULY 26,1990 j
l
- ACRS AUGUST 9,1990
- ACRS LETTER AUGUST 14,1990
- SRM AUGUST 22,1990 1
i i
i
i i:
i i
LEVEL OF DESIGN DETAll 1
j'
{
g j
SECY90-241
- CONTENTS OF THE APPLICATION r
TIER 1 & TIER 2 r
i
- CERTIFICATION -TIER 1 1
MATERIAL AVAILABLE FOR AUDIT 6
- LEVELS 1,2,3, & 4 i
i l
u
~
~.
t
o O O
O LEVEL OF DESIGN DETAIL FOUR LEVELS
- 1. IDENTICAL PHYSICAL, FUNCTIONAL &
PERFORMANCE CHARACTERISTICS
- 2. PHYSICALLY SIMILAR / IDENTICAL FUNCTIONAL & PERFORMANCE CHARACTERISTICS
- 3. IDENTICAL FUNCTIONAL &
PERFORMANCE CHARACTERISTICS
- 4. FUNCTIONALLY IDENTICAll SIMILAR PRINCIPAL FEATURES i
~
'O O
O-i i
i i
i LEVEL OF DESIGN DETAll
{
i STAFFAPPROACH-DETAIL i
I
- LEVEL OF DESIGN DETAIL
- GRADED APPROACH BASED ON SAFETY i
L
- INFORMATION IN CERTAIN PROCUREMENT & C&l SPECS i
I
- APPLICATION L
- FSAR MINUS AS-BUILT & SITE INFORMATION
- ORGANIZED INTO TWO PARTS / TIERS l
l
- AVAILABLE FOR AUDIT i
L
- SUFFICIENT INFORMATION TO CONFIRM TRANSLATION l
I OF SAFETYCRITERIA INTO DESIGN l
i
~
0:
o o
t LEVEL OF DESIGN DETAll
{
l i
STAFFAPPROACH-DETAIL l
- GRADED APPROACH BASED ON SAFETY
(
- > LEVEL 2 FOR CERTAIN NUCLEAR ISLAND FEATURES
- LEVEL 2 FOR OTHER NUCLEAR ISLAND FEATURES 1
- LEVEL 2 FOR KEY TURBINE ISLAND FEATURES i
L 1
- LEVEL 4 AT CERTIFICATION AND LEVEL 2 AT L
COL FOR SITE SPECIFIC FEATURES i
4
~
~ O O
O i
LEVEL OF DESIGN DETAIL i
i STAFFAPPROACH-FLEXIBILITY f
- CERTIFIED PORTION OF THE DESIGN / TIER 1 i
- DESIGN CRITERIA & BASES, FUNCTIONAL DESCRIPTIONS & PERFORMANCE SPECS L
- ANALYSES ASSUMPTIONS AND METHODS
- GENERAL ARRANGEMENTS, P&lDs, ELECTRICAL AND l&C SCHEMATICS l
- ITAAC t
N t
i
1 LEVEL OF DESIGN DETAll i
l STAFFAPPROACH-FLEXIBIU1Y l
I
- CERTIFIED PORTION OF THE DESIGN / TIER 1 4
i
- RULEMAKINGTO AMEND CERTIFICATION i
- EXEMPTION PER SECTION 52.63 t
- WAIVER PER SECTION 2.758 l-I i
i I
i
~~
. ~
O O
O t
LEVEL OF DESIGN DETAll STAFFAPPROACH-FLEKlBILl1Y
- IN APPLICATION BUT NOT CERTIFIED / TIER 2
- BETWEEN DESIGN CERTIFICATION AND COL
=
AMENDMENT RULEMAKING, EXEMPTION, WAIVER
- BETWEEN COL AND AUTHORIZATION TO OPERATE PROVISIONS PARALLELING SECTION 50.59
- FOLLOWING AUTHORIZATION TO OPERATE SECTION 50.59
-INFORMATION AVAILABLE FOR AUDIT SAFETY, TIER 1 & 2 -
\\;
^
~ o o
O l
l LEVEL OF DESIGN DETAll I
STAFFREQUIREMENTS
- 1. SSC WHERE LEVEL 1 OR 2IS FEASIBLE i
AND PRACTICALTO ACHIEVE i
i
- 2. SSC WHERE LEVEL 1 IS NOT NEEDED FOR STANDARDIZATION l
- 3. APPROACH PROVIDING FLEXIBILITY 1
i
- 4. ADVANTAGES / DISADVANTAGES OF TWO TIERS l
- 5. ANALYSIS OF PUBUC COMMENTS
- 6. STANDARDIZATION PORTION OF THE REVIEW 1
- 7. LESSONS LEARNED
i
. o o
o j
i l
LEVELOF DESIGN DETAIL i
- 1. IDENTIFYSSC WHERE LEVEL 1 OR 2IS i
i r
FEASIBLE AND PRACTICAL TO ACHIEVE
\\
i
- LEVEL 1 - VENDOR SPECIFIC /NAMEPl. ATE DATA OR CUSTOM BUILT L
i L
- LEVEL 2-DETAILEDINSTALLATION AND PERFORMANCE REQUIREMENTS l
- > LEVEL 2 FOR CERTAIN SSC IN NUCLEAR l
lSLAND & LEVEL 2 FOR BALANCE OF NUCLEAR l
ISLAND AND TURBINE ISLAND L
O O
O
~
LEVEL OF DESIGN DETAll
- 2. SSC WHERE LEVEL 1IS NOTNEEDED FORSTANDARDIZATION GRADED APPROACH WITH > LEVEL 2 &
LEVEL 2 DESIGN FINALITY PROVIDES A SUBSTANTIAL DEGREE OF STANDARDIZATION
- PHYSICALLYSIMil.AR/ IDENTICAL FUNCTIONAL & PERFORMANCE CHARACTERISTICS
_.____________,,-.-.:JC_..:;
-._,.L
'Z.'d-'
';--'T'9'"'
~
~ O O
O LEVEL OF DESIGN DETAIL l
I i
- 3. STANDARDIZATION WITH NEEDED FLEXIBILl1Y i
l 1
i I
- ECONOMIC FORCES AND REGULATORY PROCESSES i
- REQUIRE DESIGN DEVELOPMENT l
i l
- ESTABLISH CONTROLS ON A SIGNIFICANT l:
PORTION TO PRESERVE STANDARDIZATION
)
r
.l i
l
_._ ___ _ ___j
r' 1 3
~
~O O
O LEVEL OF DESIGN DETAll
- 4. THE TWO TIER APPROACH
- ADVANTAGES
- EASIER, LESS COSTLY DESIGN / CONSTRUCTION PROCESS
- ACCOMODATESTECHNOLOGICAL IMPROVEMENTS & EQUIPMENT UNAVAILABILITY
- ALLOWS SOME CWNER INF'JT
- DISADVANTAGES
- POTENTIAL LOSS OF STANDARDIZATION
- INCREASED CHANCE FOR HEARINGS
l LEVEL OF DESIGN DETAll
- 5. PUBUC COMMENTS
- LEVEL OF DETAIL i
- TWOTIER APPROACH i
i
- NEED FOR FLEXIBILITY e
[
- ISSUE FINALITY ii
}
l 4
i l
,s m
1 i
~ o o
o
~
1 i
1 1
3 LEVEL OF DESIGN DETAll i
- 6. STANDARDIZATION PORTION OF THE REVIEW i
- TRADITIONALREVIEW i
- SSAR SUPPUMENTED WITH Q&A AND i
AUDITS l
- INTEGRATED DESIGN INSPECTIONS 4
i i
~
'O O
O LEVEL OF DESIGN DETAll
- 7. LESSONS LEARNED
- PRODUCT LINE APPROACH YlELDED UTTLE STANDARDIZATION
- DUPLICATE PLANT APPROACH PROVIDED MOST BENERTS
- REDUCED COST OF DESIGN AND STREAMUNED NRC REVIEW
- SIMULTANEOUS PROCUREMENT ENHANCED STANDARDIZATION
- INCREASED CONSTRUCTION EFFIENCIES
- SHARED OPERATING EXPERIENCE
- COMMON PROGRAMS
LEVEL OF DESIGN DETAIL OBJECTIVES i
i i
~
DEFINE A LEVEL OF DESIGN DETAll TO BE COMPLETED AT DESIGN. CERTIFICATION THAT WILL:
4 i
- ALLOW THE STAFF TO MAKE SAFETY DETERMINATIONS i
- CAPTURE THE SAFETY BENEFITS ASSOCIATED WITH l-STANDARDIZATION 1
l l
'
- ESTIMATE. THE ENGINEERING EFFORT REQUIRED TO DEVELOP THE DEFINED LEVEL OF DETAll f
i l
)
i t
l' 4. -.....
LEVEL OF DESIGN DETAIL APPROACH l
l
. DESCRIBE THE DESIGN PROCESS FOR PLANTS LICENSED UNDER PART 50 AND PART 52
- DEFINE THE ENGINEERING PRODUCTS WHICH MUST l
BE COMPLETED AT THE TIME OF DESIGN CERTIFICATION i
i l
- -.THE-DEGREE OF DE5GN DETAll COMPLETED WILL VARY L
DEPENDING ON SYSTEM CATEGORY
=
ENGINEERING DISCIPLINE i
=
j
- DEFINE THE INFORMATION TO BE CONTAINED-IN :
i
= TIER 1
i
.= TIER 2
= APPLICANT'S FILES AND AVAILABLE FOR AUDIT
~
i i
i i
~
o o
o i
l LEVEL OF DESIGN DETAIL 1
l PART 50 DESIGN PROCESS
- DESIGN COMPLETION SCHEDULE DRIVEN BY THE i
CONSTRUCTION SCHEDULE I
- DESIGN WAS EVOLVING AS THE POWER PLANT WAS l
BEING CONSTRUCTED l-l
- CONSTRUCTION WAS BEGUN WITH AS LITTLE AS-L 20 PERCENT OF THE DESIGN COMPLETED
- SPACE WAS ALLOCATED ON A FIRST COME r
i FIRST SERVED BASIS i
- DESIGN CHANGES RESULTED FROM:
= AVAILABILITY OF VENDOR DATA l
= OUT OF. SEQUENCE COMPONENT INSTALLATION 1
= CONGTRUCTION DEVIATIONS i
i-
- CASCADING EFFECT OF DESIGN CHANGES t
i i
l
{.
i l
l i'
O O
O
~
~
LEVEL OF DESIGN DETAIL PART 52 DESIGN PROCESS
- HIGH DEGREE OF DESIGN FINALITY PRIOR TO THE START OF CONSTRUCTION CONTROLLED ALLOCATION OF SPACE TO OPTIMlZE:
= COMPONENT LOCATIONS
= ROUTING OF PIPING
= ROUTING OF CABLE TRAY AND CONDUlT SYSTEMS
- FEWER FIELD CHANGES ANTICIPATED
- FLEXIBILITY 18 NECESSARY TO ACCOUNT FOR:
= VENDOR SPECIFIC DATA
= CONSTRUCTION DEVIATIONS
o o
o i
LEVEL OF DESIGN DETAIL FOUR PHASES OF DESIGN EVOLUTION i.
- CONCEPTUAL DESIGN PHASE
)
i
- DEVELOP GENERAL ARRANGEMENT DRAWINGS
- IDENTIFY SYSTEM FUNCTIONAL REQUIREMENTS AND MAJOR EQUIPMENT I
- DEVELOP SIMPLIFIED SINGLE-LINE DIAGRAMS
- SPECIFICATION OF CODES, STANDARDS AND DESIGN CRITERIA
- DEVELOP SIMPLIFIED PIPING AND INSTRUMENTATION DIAGRAMS L
- PRELIMINARY DESIGN PHASE i
- SPECIFY PERFORMANCE AND FUNCTIONAL REQUIREMENTS -FOR MAJOR MECHANICAL-AND ELECTRICAL COMPONENTS
- l
- DEVELOP PROCESS FLOW DIAGRAMS FOR ALL OPERATING CONDITIONS
- PREPARE SYSTEM DESCRIPTIONS PRELIMINARY PIPE ROUTING l
- DEVELOP INSTRUMENT BLOCK-DIAGRAMS AND LOGIC DIAGRAMS
[
- DEVELOP ELECTRICAL SCHEMATICS
- DEVELOP EQUIPMENT LISTS (ELECTRICAL, MECHANICAL, etc.)
- PRELIMINARY CALCULATIONS AND ANALYSES l
o e
~
O O
O i
4 LEVEL OF DESIGN DETAIL FOUR PHASES OF DESIGN EVOLUTION r
I
- DETAILED DESIGN PHASE
- DEVELOP DETAILED SINGLE-LINE DIAGRAMS
- DEVELOP DETAILED P&lDs AND FLOW DIAGRAMS
- DEVELOP EQUIPMENT FUNCTIONAL AND PERFORMANCE REQUIREMENTS
- DEVELOP PIPING ISOMETRIC DRAWINGS
- PERFORM PIPING STRESS ANALYSES
- DEVELOP TYPICAL PIPE SUPPORT DETAILS
- DEVELOP INSTALLATION CRITERIA AND TYPICAL DETAILS
- BEGIN FINALIZING LISTS OF COMPONENTS
- FINAL -DESIGN PHASE
- PREPARE PURCHASE SPECIFICATIONS
- VENDOR: SELECTION l
- RECONCILIATIONS j
= VENDOR SPECIFIO DATA l
2
= AS-BUILT DATA i
i i.
1
~ -
o o
o LEVEL OF DESIGN DETAIL SYSTEM CATEGORIES l
- NUCLEAR ISLAND L
- PRIMARY COOLANT SYSTEM
- ENGINEERED SAFETY FEATURES ACTUATION SYSTEM l
~
i-
- REACTIVITY CONTROL SYSTEM
- REACTOR CONTROLS AND INSTRUMENTATION
- CONTAINMENT l
- BALANCE OF NUCLEAR ISLAND
- EMERGENCY CORE COOLING SYSTEM i
- CONTAINMENT SPRAY SYSTEM q
- CHEMICAL VOLUME AND CONTROL SYSTEM
- RESIDUAL HEAT REMOVAL SYSTEM
- COMPONENT COOLING WATER _ SYSTEM
- ELECTRICAL DISTRIBUTION SYSTEM i
- SPENT FUEL COOLING SYSTEM
- RADWASTE SYSTEMS
- CONTROL ROOM HABITABILITY ljL i
I
~
~o o
o j
i LEVEL OF DESIGN DETAIL SYSTEM CATEGORIES i
TURBINE ISLAND
- FEEDWATER SYSTEM
- CONDENSATE SYSTEM MAIN STEAM SYSTEM L
i-
- HEATER DRAIN SYSTEM
- AUXILIARY STEAM -SYSTEM
}
- TURBINE BUILDING COOLING WATER SYSTEM I
- TURBINE LUBE OIL -SYSTEM PLANT COMPRESSED AIR SYSTEM 1
l'
.- SITE SPECIFIC SYSTEMS
- ULTIMATE HEAT ' SINK i
j
- ESSENTIAL SERVICE WATER SYSTEM f
I
- NON-ESSENTIAL' SERVICE WATER SYSTEM
- SCREEN ' WASH SYSTEM i
L i
l
~
O O
O i
3 LEVEL OF DESIGN DETAIL RECOMMENDED LEVEL OF DETAIL l
i I
i NUCLEAR ISLAND GREATER THAN LEVEL 2 3
i l
BALANCE OF NUCLEAR ISLAND LEVEL 2 i
i 1
i
-LEVEL 2 TURBINE ISLAND l
l SITE SPECIFIC LEVEL 4 AT DESIGN CERTIFICATION 1
LEVEL 2 AT COMBINED O/L l
l
- ~.. - ~ -.
i O
O O
i LEVEL OF DESIGN DETAIL EXAMPLES OF TIER I INFORMATION I
\\
l' DESIGN BASES AND CRITERIA f
i
- SIMPLIFIED PIPING. AND INSTRUMENTATION DIAGRAMS SIMPLIFIED ELECTRICAL SINGLE-LINE DIAGRAMS CLASS 1E AC/DC GENERAL ARRANGEMENT DRA#1NGS l
i LOCATIONS OF EQUIPMENT (NOTE 1) l l
(~
ROUTING OF ALL PIPING > 6 INCHES (NOTE 1)
' ROUTING OF HIGH-ENERGY PIPING > 2 1/2 INCHES (NOTE 1)
ROUTING OF HVAC DUCTS (NOTE 1) l NOTE 1: -WITHIN DEFINED ENVELOPE f
i i
L f
~
i i-
. J 4
f~~.
. O O
G LEVEL OF DESIGN DETAIL
~
EXAMPLES OF TIER 1 INFORMATION
- ROUTING ~ OF CABLE -TRAY SYSTEMS (NOTE 1)
- EQUIPMENT PERFORMANCE REQUIREMENTS STRUCTURES (EXCEPT FOR LOCALIZED DESIGN-INFLUENCED BY VENDOR SPECIFIC DATA)
SYSTEM FUNCTIONAL AND PERFORMANCE REQUIREMENTS' (EXCEPT l-
-=
FOR VARIATICNS RESULTING FROM VENDOR SPECIFIC DATA)
ROUTING OF - ASME CL' ASS 1N PIPING >- 1 INCH !(NOTE 1)
MAN-MACHINE FUNCTIONAL INTERFACES DATAENETWORK DESCRIPTIONS (SYSTEM ARCHITECTURE)
PROGRAMMATIC. DOCUMENTS
- SOFTWARE VERIFICATION J AND1 VALIDATION'
- SEISMIC QUALIFICATION PLAN:
- ENVIRONMENTALEQUALIFICATION PLAN
- SETPOINT ' TOLERANCE " METHODOLOGY-
'~
IVOTE 1-1WITHIN - DEFINED ENVELOPE ~
~
u.
~
O 0l
. O l
- p. -
e.
L, DESIGN' FINALITY vs. ENGINEERING HOURS l
i'
-p 4
i E'
1
.R
-100
l------
C i
E l
j N
1-
.y.
i 80.
i
.o E:
l S
t l
60:
G N.
I
--- l =
l p
.40 g
N A-t 20 T
i L
Y'
- ~
l j
O-20.,.
. 40.
60 80.
100 P
PERCENT ENGINEERING HOURS I.
[
.i
't s.
g q
-.w?
%.s:w-%..m Wyf-m.
4%,s' y
e.a+=
9 w- - -
--.g
+-
- -g
-+p, m.g y
..vy.
9-mu%;
,.-9_
,y-
n.
.. _ - ; --.. ~.
- o oi O
i
.l DESIGN FINALITY vs. ENGINEERING HOURS P
E-l j
7 100
~~~~"----- - -~~~
---~
-~ -~~-~~~-~~
E N
~ ~ ~ ~ ~ ~ ~ ~ ^ - ~ ~ ~ ~
~ ~ ~
]
T 80
~ - - ^ - ~ ~ ~ ~ ~ ~ ~ ~ - - - -
D FINAL FIELD
- E-S
- ~ ~ ~ ' ~ ~ - ~ ~ ~ ~
~ ~ ~ ~ ~ ~ - ~ ~ ~ - ~ ~ ~ ' - ~ ~
~
- ' ~ ~ ~
I
^60
~~~-~~~~~
C~~ONCEPTUAL
-venoon as-evetr g
neconcetsarious-onu N
.I F
40
---PRELIM DETAILED i
. N i
' A component l
i l20 o m eneurs
- /
y 0
26.
40 60
'80 1'00 l"
~
PERCENT ENGINEERING HOURS:
9 d
[.
_..._,_.__..~2
. ~:.
-,m._.
~..
l 0
oI O
r i
DESIGN _ FINALITY vs._ ENGINEERING HOURS i
1 i.
n i
c l
L.-
P E
R l
C 100
-- LEVEu - - - - -
7 c
E
'N trygt,
~T l
80 s
D L
E S
1 l
60 i
g N
'. z
.p
- 40
~ - - - - - - - - - - - - - - - -
-i LEVEL s N
1A i
1 i
20 l
g-e
.1 -
tevet-4 l
]
T l
.Y-
/
0 w
i O'
20 40 60
~80 10 0 i
?~
PERCENT ENGINEERING. HOURS i
~
. + -
n.,.
.....w
..-8 s
-p.s.
.~d..
O O
I O
~
~
L j
1.;
DESIGN FINALITY vs. ENGINEERING HOURS i
AT DESIGN CERTIFICATION P
-j E
~R
/
,,,,,,y.
C 100 systsu E
SALANCE
~AND N.
OF
. CONTAINMENT NuctsAn-
.T
.AND 80 Tuns:NE-.
O ISLAND I
E S
60.
I l.
O u
~
sits 40 F.
speceFec l
l
__ _ __ SYSTEMS i
.N e'
A
'20 L
I L
.T-
/.
/
'/
j Y-
'0
'20 l40 60 30 100 PERCENT ENGINEERING HOURS l
i i
l
.a -
OI o.
O l
t DESIGN FINALITY vs. ENGINEERING HOURS i
i l
AT COMBINED OPERATING LICENSE P
E R
C PRIMARY E
sits sy3ts.
- sescoric
-. - - f,7,0 N
sysreus l-T 100 D
E l
~ S 80-I Lp.
G y
N 60 tance e
or p
wucteAn
. I 40
_..A N D. _.
N
- Tunosus A
'/
istano
~ L 20 I
/ ////////
/l
/ / / / / / /:
.l h.
/ /////////
'///
//////
,~ 0 20 40 60 80 100-
~=
PERCENT ENGINEERING HOURS l..,,
<,_,y-y,,e_,--,
q<..
y
--.,--,:.,-_,y, e=.
- -[
Ts o-oi
. o 1
DESIGN FINALITY vs. TIME j
i P
l.
Loao E
A o
COL 181tlED EUE1 R
6 l
C DESL998 100 C
R 300 e
E
~-
4 GEBL
- N T
80-
.80 E
D-j N
- j E
rescent armerar G
l-60 nouns 60.
I cessem
% enemmenene i-
?S~
- -rm^ur b -
N l
g
. E N
. E l
. R 1
-=-
40 i
F 40 I
N
- t f
N-
.G 1
i A
20
- H i
L 20 I
0:
i T
~
U R
Y-t S
O Oi 2.
~ 4 6~
8 10
.s i
YEARS FROM PROJECT INITIATION 4
9
,m-*
._.p_
~
e, 3
p
.m.
..+e"*
~ " "
Y
- Y*
W F
C'*'"
'1'#"4%P"'
""'T*-'%'"t-w
- %#"n-w we
' ~-
O oI o
RELATIVE CUANTITIES OF INFORMATION
~
. AVAILABLE - AT DESIGN CERTIFICATION i-1 MAXIMUM IECHK,CALLY N
ACHIEMBLE l
m
/
1 DEStGM_CERIIE1 CAT 10N i
o a
?;
s 1
i.
+
-l i
_. -l., i
.....i,, -. (('
., ~., _ -. - _
O O
O i
~
7 LEVEL-OF DESIGN DETAll RECOMMENDATIONS I
- SUPPORT STAFF PROPOSAL OB -
]
l GRADED APPROACH TO. DESIGN j
FINALITY
- CONTENTOFTHE APPLICATION
[
- AND CERTIFICATION
~
i:
- CHANGE PROCESS FOR MATERIALIN.
L
! APPLICATION,LCERTIFICATION AND i
~
HELD FOR AUDIT:
w a
- AUTHORIZE DEVELOPMENT OF REG. GUIDE
. -- - =
=.,.
-