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November 15, 1990 S
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MEMORANDUM FOR:
Chairman Carr
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Commissioner Rogers Commissioner Curtiss g
Commissioner Remick FROM:
William C. Parler General Counsel
SUBJECT:
REQUIREMENTS FOR DESIGN CERTIFICATION UNDER PART 52 As originally conceived, 10 CFR Part 52 was intended to advance standardization primarily through the design certification itself. Thus Section 52.63 prevented anyone (including NRC) from changing a certified design unless certain strict t
conditions were met, and restricted relitigation' of issues resolved in connection with issuance of the certified design rule.
In contrast, because it was not considered important to advance standardization, no special conditions were imposed on changes to or relitigation of design information not included in or resolved with the certification itself.
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After the adoption of the rule, industry and the staff focused on the need for some degree of flexibility in the certification and licensing process to cover such contingencies as construction problems,. equipment model changes etc.
Recent discussions have centered on the attempt to find an appropriate balance between the need for some flexibility and the need for standardization.
The outcome of this further consideration is that the certified design itself is no i
longer appropriate as a principal means for promoting standardization at other than a preliminary design level. Instead, standardization at a detailed design i
level will be promoted through a policy that detailed design information (so-called Level 2 information) should be available for audit during the Section 52.63(a)(4) restricts relitigation of issues " resolved in i
connection with the issuance or renewal of a design certification".
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Section 52.103 contains additional limitations on relitigation of issues resolved in connection with issuance of a combined license.
This memo does not address the impact of the recent Nuclear Information and Research Service v. NRC D.C. Circuit decision on the scope of the
'l hearing prior to operation under a combined license, but an initial review of that decision suggests that it does not appear to affect the I
level of detail issue discussed in this memo except in the following
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indirect sense.
If and to the extent the decision contemplates relitigation of issues resolved in connection with a certified design l
because of significant new information, this detracts from the value l
i of the design certification, and this could in turn influence the resources vendors may be willing to spend to develop further design detail in support of a certification application.
l NOTE: ATTORNEY CLIENT INFORMATION i
I1MITFD TO.NRC UNLESS THE COMMISSION DETERMINES OTHERWISE 9400030232 940s,29 PDR COMMS NRCC CORRESPONDENCE PDR l
NOTE 8 ATTORNEY CLIENT INFORMATION LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE certification review.
In the subject paper the focus is on the total safety assurance to be derived from standardization and design completion. This safety assurance requires a detailed definition of what will be in the application to address the scope of certification (standardization) and what will be in the application and available for audit to ensure sufficient depth (design completion) to provide reasonable assurance that the facility will be built in i
accordance with the application.
All information will be available either in the application or available for audit.
We have carefully reviewed the staff's approach and, because it can reasonably be reconciled with Part 52, have no legal objection to it.
However, because the conceptual approach in the paper to standardization is different from thr:t originally envisioned, the interpretative analyses of Part 52 to support staff's position is complex. This analyses is explained below.
I.
Audit Material There is nothing in Part 52 which requires a certification applicant to have information available for audit solely to enhance standardization, and there is no provision in Part 52 which would authorize denial of an otherwise acceptable certification application solely because applicant had not done all that was feasible and practical to complete the design. Section 52.47(a)(2) does say that NRC can require certain design information to be available for audit, but only to the extent "necessary for the Commission to make its safety determination".
J The nature of this " safety determination" can be inferred from other provisions in 52.47(a) which say that the provisions of Parts 20, 50, 73 and 100 will apply j
to the design certification application and that all safety questions associated with the design must be finally concluded.
In the subject paper, especially Appendix A, staff analyzes what degree of design detail is feasible and practical at the design certification stage, and concludes generally that a so-called Level 2 (detailed design complete) is both feasible and practical at this time except for design matters affected by site-specific factors. Staff then proposes that this detailed design information be available for NRC audit as part of the certification process.
Importantly, Staff also proposes that the detailed design information to be made available for audit be subject to staff review to provide the necessary confidence that the detailed design will fully implement the requirements in the application and will perform its intended functions.
This is clearly a safety review of the kind embraced by 10 CFR Part 50, especially Appendix B, and would contribute to reaching a final conclusion on safety questions. Accordingly, this safety rationale will support staff's approach under 52.47(a)(2). However:
the certification rulemaking record will now potentially include, at least indirectly, all of the detailed design information available for audit because, even though it is not part of the application, it could form a basis for a Commission finding in the rulemaking.
Other parties to the certification rulemaking will need to be granted access to this material, and those portions of the material actually reviewed NOTE: ATTORNEY CLIENT INFORMATION LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE
NOTE: ATTORNEY CLIENT INFORMATION LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE l and relied upon will need to be defined lest the record become unwieldy.
the actual safety findina about the audit material will need to be l
carefully defined because it is not spelled out in Part 50. A finding that design information in Tiers 1 and 2 hn been properly translated into the detailed design will need to be carefully distinguished from and will have different implications from a finding that applicant has an adequate orocess in place for translating the Tiers I and 2 I
information into the detailed design.
j questions may be raised about why all of the detailed design material to be available for audit is strictly necessary for the staff safety review at the certification stage, as opposed to later as part of the I
l review for conformance with acceptance criteria.
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l 2.
The Two-Tier Acoroach l
Staff recommends adoption of a two-tier approach to the certification rule whereby Tier 1 includes the certified design itself, and Tier-2 includes further design detail (along the lines of a recent FSAR) that is approved by rule but not " certified". Section 52.63(a)(4) says that the NRC shall treat as resolved "those matters resolved in connection with the issuance or renewal of a design l
certification", and it was expected that the definition of what in fact was j
resolved would rely on material in the rulemaking record and certification application not included in the certified design itself. To the extent Tier 2 contains information which serves to define what safety issues were resolved in j
approving Tier 1 and the basis for that resolution, Tier 2 is essentially an effort to implement 52.63(a)(4) in a disciplined manner.
Staff intends generally that Tier 2 include only the safety information needed for its safety evaluation of Tier 1, and Staff's approach is in accord with Part 52.
i Tier 1 information alone is expected to significantly exceed that submitted in a traditional PSAR under Part 50. Tier 1 and Tier 2 information, which comprise a complete applicatica, will approximate slightly more detail than that in a l
recent FSAR. However, since Tier 1 does not include sufficient detail in itself l
to constitute the non-site related portion of a combined license application, the combined license application must necessarily reference both Tier 1 and Tier 2.
As a result, changes to Tier 2 may raise unresolved safety issues for litigation in the combined license proceeding.
NRC will need to be in a position to review these changes prior to issuance of a combined license, and the certified design rule will probably need to include some express condition I
to the effect that the certified design can only be used if Tier 2 is used as well.
Staff is proposing a stringent condition here that will require utility license applicants referencing the certified designs to follow Tier 2 (as originally This promulgated or as amended by rule) or request an exemption or rule waiver.
makes sense so long as it is understood that Tier 2 is the basis for the finding NOTE: ATTORNEY CLIENT INFORMATION i
LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE
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NOTE: ATTORNEY CLIENT INFORMATION LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE
. that the more general features of Tier I will provide adequate safety for the proposed design and the number of changes is not so numerous as to overwhelm staff resources.
3.
Charce Processes A.
Tier 1 There has been much discussion about the process for charging information in the two tiers.
In brief, Part 52 itself prescribes the mechanism for changes in the Tier 1 or certified design itself (rulemaking, exemption, or rule waiver).
B.
Tier 2 Part 52 does not address changes to Tier 2 except to a limited extent. Section 52.83 says that the provisions of Part 50 " applicable to holders of operating licenses also apply to holders of combined licenses... once the Commission has made the findings required under s 52.103...".
Since the change process of section 50.59 applies only to holders of operating licenses, it follows that this change process applies only to combined license holders after operation is authorized.2 However, nothing in Part 52 specifically precludes issuance of a certification rule that would define change processes for earlier points in time
- for example during construction after combined license issuance.
Since Tier 2 will be a condition of using Tier 1, it follows that a departure from Tier 2 may create unresolved issues for litigation either prior to issuance of a combined license or later.
A change process, like section 50.59, will l
probably not serve to limit the scope of any later litigation.
C.
Audit Material l
There is nothing in Part 52 that would serve as a basis for requiring staff l
review of changes to the detailed design material to be available for audit, although 10 CFR Part 50, Appendix B would require the applicant and combined license holder to have a process for evaluating and controlling such charges.
It may be that changes in this material may affect compliance with acceptance criteria as well.
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Wi iam C. Parler General Counsel Section 52.63(b)(2) does say that a licensee referencing a certified 2
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design may make certain changes without Commission approval " subject to s 50.59", but we would not read this as necessarily extending the l
scopu of s 50.59 to the pre-operation stage.
i NOTE: ATTORNEY CLIENT INFORMATION LIMITED TO NRC UNLESS THE COMMISSION DETERMINES 0WED.SE l
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10 J.1 i 2 ft 3: I5
\\;*.ex; POLICY ISSUE aulv 11, 1990 (Notation Vote)
SECY-90-241 For:
The Commissioners From:
James M. Taylor l
Executive Director for Operations l
l
Subject:
LEVEL OF DETAIL REQUIRED FOR DESIGN CERTIFICATION UNDER PART 52
Purpose:
To present options for Commission consideration regarding l
the implementation of the provisior.s of 10 CFR Part 52 that l
address the level of design detail.
The staff requests l
Commission guidance on this issue.
Backaround:
On !!ay 18, 1989, the Commission issued a new rule, 10 CFR Part 52, that provided for early site permits, certified standard designs, and combined construction permits and operating licenses.
The intent of Part 52 in providing for the review and licensing of standard designs is tc reform the licensing process by effecting early resolution of safety issues and to enhance the safety and reliability of nuclear power plants through standardization.
In the April 27, 1990 Commission meeting, the issue of the level of detail required by Part 52 was discussed briefly.
After the meeting, Staff Requirements Memoranda were issued which directed the staff to present a paper examining the i
level of detail required by Part 52 to facilitate design certification of an essentially complete design.
In response, the staff examined the requirements of Part 52 and discussed the subject with industry representatives.
The staff is presenting the Commission with four levels of design detail in this paper.
Our objectives are to present the technical and regulatcry considerations pertinent to actions that might be taken by the applicant and the NRC l
NOTE:
TO BE MADE PUBLICLY AVAILABLE WHEN THE FINAL SRM IS MADE CONTACT:
AVAILABLE OR UPON AGREEMENT fiartir, i'. Virgilic, NRP.
OF THE COMMISSION 497-1257 A@%)M6HL %
I r
The Commissioners at each level. The level of detail associated with a design certification can be considered in terns of three variables: (1) the contents of an application for design certification, (2) the material to be developed by the applicant and made available for audit, and (3) the information certified by rulemaking.
Part 52 is clear regarding the scope of an application for design cortifi-i cation stating that, with some exceptions for reactors of advanced design, "Any person may seek a standard design certification for an essentially complete nuclear power i
plant design..." An essentially complete design includes all structures, systems, and components which can affect safe operation of the plant except for site-specific elements such as the service water intake structure and the ultimate heat sink." Accordingly, scope is not addressed in this paper.
Discussion:
A.
DESIGli DETAIL IN A CERTIFICATION APPLICATI0fl Section 52.47(a)(1) requires that an application for a design certification include a level of detail that would satisfy the regulatory requirements for technical informa-tion in an FSAR, except to the extent that particular 4
requirements are technically irrelevant or site specific.
Section 52.47(a)(2) addresses level of detail from three perspectives.
First, the level of detail must permit NRC to reach a final conclusion on all safety questions associated with the design before certification. Second, the level of detail must be such to allow the applicant's l
proposed means of assuring that construction conforms to l
the design. The staff believes this, in conjunction with other provisions of Part 52, to require and define the purpose of inspections, tests, analyses, and acceptance criteria (ITAAC). Third, Section 52.47(a)(2) requires a i
level of detail in the application such that the application itself would contain sufficient information to permit the preparation of procurement and construction and installation specifications. The staff believes this provision should be met without recourse to significant additional design engineering. The staff reads this to require, for example, that ranges of values for analyses and tolerances for structures, systems and components be provided in the application.
B.
DESIGN DETAIL TO BE AVAILABLE IF REQUESTED BY NRC i
l Section 52.47(a)(2) requires that information normally contained in certain procurement and construction and installation specifications be available for audit if the NRC needs to review the information in order to make a (e.g., valut ranges and tolerances) quire a level of safety finding. The staff reads this to re refined beyond detd1 1 that included in the application.
The Commissioners C.
DESIGN DETAIL IN THE CERTIFICATION The rule indicates the information required to be in an application and to be developed and available for audit; it is, however, silent on the level of design detail that is to
.t a part of the certification itself. On this point, the
.,catements of Consideration says that "just how much [ design detail] is present will be an issue which will have to be resolved in each certification rulemaking. The Comission does expect, however, that there will be less detail in a certification than in an application for certification, and that a rule certifying the design is likely to encompass roughly the same design features that Section 50.59 prohibits changing without prior NP,C approval." The information pre-4 sent in a design certification will control the degree of standardizction that can be achieved at the design certifi' cation stage.
Some of the information contained in an application for design certification may represent commer-cial, proprietary information.
If information of this type is included in the certification, the material will no longer be considered proprietary; instead it becomes part of the NRC's public requirements.
Thus decisions about level of detail in the certification itself could have important consequences for the commercial value of vendor design information.
D.
ITAAC The applicant nust develop) inspections, tests, analyses, and acceptance criteria (ITAAC and submit them for staff review as specified in Part 52.47(a)(1)(vi).
ITAAC will provide reasonable assurance that a plant which references the design is built and will operate in accordance with the design certification.
ITAAC are not a design tool to be used in lieu of the detailed information needed to satisfy the
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requirements for an application, as discussed above. The subject is discussed further in the enclosure to this paper.
E.
POLICY ISSUE REGARDING "TWO-TIERED" CERTIFICATIONS One other policy issue that is closely tied to the issue of level of design detail is whether the Commission should accept the "two-tiered" approach proposed by industry for design certification.
In this approach, the top tier certified design would include essential safety performance criteria that, once certified, could only be changed by the receiving of an exemption through 10 CFR 50.12. A second tier of material would include more detailed design infor-nation.
This second tier would be associated with the rule certifying the design (but not be part of the certification itself) and woulo include a change process like the current 10 CFR SC.59, that would allow changes without prior NRC revier so long as no unreviewed safety question is presented.
The Commissioners The desired effect is that the approved Tier 2 design detail could not be challenged in the combined license proceeding except under 10 CFR 2.758 or to the extent the design is changed after the rulemaking under the Section 50.59 flexibility provisions. The constraints on backfitting and other provisions of Part 52 intended to foster stan-dardization would not apply to the design approved in Tier 2.
Although the two-tiered concept is presented in this paper in conjunction with the industry approach (Level 3), it may be applied to any of the options.
F.
THE FOUR OPTIONS FOR LEVEL 0F DESIGN DETAIL The rule as promulgated allows for interpretation that could lead to a different body of information in each certification resulting in varying degrees of standard-ization.
The more specific the engineering detail embedded in the design certification rule is, the greater the degree of standardization for that design.
The staff has examined four levels of detail, the corre-sponding degree of standardization achieved, compliance with Part 52, and the safety and economic benefits derived from each. The staff discusses each of these levels in the next few pages. These levels are merely examples of the level of detail that can be included in the application and the degree of standardization that can be achieved through the certifi-cation process and are not necessarily the only options available to the Commission under Part 52.
It is not clear that the design detail necessary to realize a Level 1 degree of standardization is consistent with Part 52 regarding the content of the application.
Notwithstanding a rule change to Part 52, the first level is probably not commercially feasible, because the level of detail required in a Level I certification would make it difficult to assure continued availability of components with all the certified attributes over the life of certification.
Level 2 provides the maximum degree of standardization while avoiding to some extent the aforementioned concern. The third level of detail presented characterizes the industry proposal (incorporating the two-tiered approach) as the staff understands it.
NUMARC are the only ones who can speak definitively on their position. The fourth level of detail (product-line standardization) would not constitute an acceptable applica-tion for design certification under the current provisions of Part 52, because it is not sufficient to allow the staff to reach its final conclusion on all safety issues in a one-step process.
However, it is provided to exemplify a level of detail and standardization achieved under the Part 50 process.
In Levels 1, 2, and 3, the content of the application in terms of information permane to our safety findings is the
The Commissioners same; however, the scope and depth of detail required for Levels 1 and 2 will be beyond what the staff has tradition-ally needed to conduct licensing reviews under NUREG-0800 the Standard Review Plan (SRP). This greater level of detail will be provided for the sake of standardization.
To the extent the greater level of detail is approved by rule in the certification process, there is also an earlier resolution of any safety issue. associated with the design.
Staff licensing review of an application for design certi-fication for all levels will deviate somewhat from tradi-tional practice, with the addition of the ITAAC, and in Levels 1 and 2, the standardization portion of the review as well.
Additional guidance will have to be developed to support staff review. Information normally contained in procurement specifications and in construction and instal-lation specifications and audited will be included or referenced in the application for a design certification-if it is necessary for the staff to make its safety findings.
In Levels 1 and 2 essentfally the entire application will be certified.
In Level 3 the design certification will contain much less detail than provided in Levels 1 and 2, plus the rulemaking approval of Tier 2 along with the l
industry-proposed Section 50.59-type change mechanism.
Using the HVAC system as an example, Table 1 shows how much detail we would expect for each of the four levels.
1 LEVEL 1 The degree of standardization resulting from this level of detail and the certification process will provide identical physical, functional, and performance characteristics of I
all structures, systems and components except for site specific characteristics.
Ir. the Application The application must satisfy the requirements of 10 CFR 52.47(a) and (b)-(invoking Parts 20,50,73,and100) and must provide resolutions for the technical issues dis-cussed in SECY 90-016. The depth of design detail in the i
application for design certification will be all the infor-mation contained in a completely designed plant. This l
includes procurement specifications as well as construction l
and installation specifications for all structures, s and components (not including site-specific details) ystems, I
appro-pricte for soliciting fixed-cost construction bids.
The l
design could be advanced through the procurement specifica-l tion stage for all plant equipment.
In some cases these procurement specifications will need to be more detailed and specific than is current practice to be able to ensure thtt the geotetries, as well as the capabilities, of l
J The Commissioners components are within specified ranges. The application will contain, for example, performance characteristics for all systems and their components; exact piping routing and support details for all systems; and physical location, i
characteristics, configuration, and orientation for all components on those systems.
In other words, for all pumps on all systems not site related, the type (positive displacement or centrifugal), location, and pumping capacity and head will be specified, as well as the exact locations of the inlet and outlet nozzles, weight, size, shape, and mounting / supporting details.
If information obtained during the Staff review question and answer process forms the basis for a safety judgment or contributes to standardization, it will be included in the application.
Available for Audit Information normally contained in procurement specifications and in construction and installation speci-fications will be included in the application. Therefore, audits should not be necessary.
In the Certification The design certification will include essentially all of the material in the amended app (lication, including the ITAAC, necessary for the staff to 1) determine design acceptability, (2) ensure design criteria and performance requirements are satisfied, (3) make a safety (minus site specific aspects) determination,and(4) ensure total plant standardization and its resulting safety benefits.
Remarks To ensure that future plants will have identical physical, functional, and performance characteristics, the design will be developed and certified to a level of detail that includes all engineering data for a completely designed plant except for that data relating to site specifics. The application and design certification process will drive the design development and solidify it to a point where total plant standardization (except for site specifics) is achieved.
As previouly stated, certain procurement specifications will have to be more detailed than is current practice.
In some instances vendors may have to custom build such com-ponents as pumps, to fit the specifications.
To require this much design detail is the most costly (greater than l
$600 million), initially, and may discourage NSSS vendors from entering the market; however, this much design detail will also result in more accurate determination of cost to the customer (utility).
Certifying this level of detail l
l
I l
The Commissioners,
provides the greatest regulatory stability (protection against unwarranted backfits) and early and final resolution of issues through design certification.
Unavailability of i
specific components, resolution of construction deviations, and instances of highly desirable upgrades in technology i
that would provide equivalent or improved functionality or reliability can only be accommodated to a very limited extent through the granting of an exemption to the rule certifying the design via 10 CFR 50.12. The application will include a substantial amount of information beyond that traditionally needed to conduct a licensing ' review in accordance with the SRP.
Staff review will deviate signi-ficantly from traditional practice, with the addition of the ITAAC and standardization portions of the review. Additional staff guidance would need to be developed to support the review of this information.
Because the Level I status of-design may exceed the requirements of part 52, changes.to i
the regulations would need to be considered were this option i
selected.
LEVEL 2 The degree of standardization resulting from this level of detail and the certification process will provide physically similar, and identical functional and performance charac-teristics of all structures, systems, and components l
affecting safety, except for site specific characteristics.
In the Application l
The application must satisfy the requirements of 10 CFR 52.47(a) and (b) (invoking Parts 20,50,73,and100) as well as provide resolutions for the technical issues discussed in SECY 90-016. The depth of design detail i
submitted in the application for design certification will be similar to that of a final safety analysis report (FSAR) at the operating license (0L) stage for a recently l
licensed (1989 - 1990) plant minus site-specific and as-built information.
The application will provide design criteria and bases, system descriptions, performance requirements, and component descriptions and characteristics I
in enough detail for the staff to make its final conclusions on all safety questions; it will also contain information necessary to provide enhanced safety benefits from standardization. This includes a significant amount of design development and information necessary to finalize procurement specifications and construction and installation specifications for structures, systems, and components affecting safety. The application will contain, for example, perforrance characteristics for systems affecting safety and their components; general pipe routing (one line diagrams, such es FLIDs) for systems affecting safety; and relative j
i f
The Commissioners physical location and characteristics of components on those systems.
This differs from the Level 1 option which requires the same detail for all systems as well as exact physical location, configuration, and orientation of components and supports.
In other words, for all pumps on systems affecting safety, the type, pumping capacity and head, and certain general physical attributes (e,;., centrifugal pump) will be specified; but the exact locations of the inlet and outlet nozzles, exact weight, and mounting / supporting details will not be supplied.
If information obtained during either the Staff review question and answer process or the audit forms the basis for a safety judgment, it will be included or referenced in the application.
Available for Audit Consistent with Part 52, that information normally contained 1
in precurement specifications and in construction and installation specifications shall be completed and available upon staff request. Audits will be conducted as necessary to support safety judgements and further standardization.
In the Certification The design certification will include all of the material submitted in the initial application, including the ITAAC, necessary for the staff to (1) determine design accept-ability, (2) ensure desi ments are satisfied, (3)gn criteria and performance require-make a safeti determination, and (4) advance standardization and its resulting safety benefits.
Remarks To ensure that plants will have physically similar, and identical functional and performance characteristics, the design must be developed and certified to a level of detail that includes all engineering data necessary to permit the preparation of procurement specifications as well as construction and installation specifications except for data that must be site-specific.
Unlike the Level 1 option that will standardize essentially the entire plant to the component level (with physical attributes, orientation, and location specified), the Level 2 option will result in stan-dardizing component descriptions and performance characteris-tics for all systems affecting safety. Although to require this amount of detail is initially costly (more than $400 million) and may discourage vendors from entering the market, cost can be more accurately determined, a benefit to the custoner (utility).
Certifying this level of detail provides regulatory stability and early and final resolution of issues
i The Commissioners through design certification.
Unavailability of specific components, necessary construction deviations, and instances of highly desirable improvements in technology (and even new technologies) that would provide equivalent or improved functionality or reliability, will, to some extent, require the granting of an exemption to the rule certifying the design via 10 CFR 50.12.
However, pursuant to Section 52.63(a)(2), a change may be made under the pro-visions of Section 50.59 "unless it involves a change to the design as described in the rule certifying the design."
In the Level 2 option, only a small amount of information will not be certified, thus only a small portion will be subject to Section 50.59 changes. The application will include some additional information beyond that traditionally needed to conduct licensing reviews under the SRP, so as to advance i
standardization and provide the safety benefits derived from standardization.
Staff licensing review of the application will deviate somewhat from traditional practice, with addition of the ITAAC and standardization portions of the review.
Additional guidance will have to be developed for these portions of the review.
LEVEL 3 The degree of standardization resulting from this level of detail and the certification process will provide identical functional and performance characteristics of all systems, structures, and components, except for site-specific characteristics.
In the Application The application must satisfy the requirements of 10 CFR 52.47(a) and (b) (invoking Parts 20, 50, 73, and 100) l as well as provide resolutions for the technical issues discussed in SECY 90-016. The depth of design detail submitted in the application for design certification will be similar to that of an FSAR at the OL stage for a recently licensed 1
(1989 - 1990) plant minus site-specific and as-built infor-mation. The application will contain design bases, system descriptions, performance requirements, design criteria, and other information in sufficient detail for the staff to make its final conclusions on all safety questions.
This includes information necessary to permit the preparation of procurement specifications as well as construction and instellation specifications for structures, systems, and components affecting safety.
The application will contain, for example, performance characteristics for systems affecting safety; general piping locations for systems affecting safety; and general physical locations of major components for those systems affecting safety.
Unlike the Level 2 option where vt expect to have information (physical characteristics) for
The Commissioners components on systems affecting safety, in the Level 3 i
approach, we will have performance characteristics on the l
major components for systems affecting safety.
If information obtained during either the staff review question and answer process or the audit forms the basis for a safety judgement, it will be included or referenced in the application.
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Available for Audit Consistent with Part 52, that information normally contained in procurement specifications and in construction and installation specifications shall be completed and avail-able on request. Audits will be conducted as necessary to l
support safety judgments and will not be used to further standardization.
j In the Certification As in Levels 1 and 2, the design certification (Tier 1) and l
the associated approval considered together will include l
all information submitted in the initial application, l
including the ITAAC, necessary for the staff to (1) determine oesign acceptability, (2) ensure design criteria and per-formance requirements are satisfied, and (3) make a safety determination.
Unlike Levels 1 and 2, Tier 2 will include a change mechanism, similar to the Section 50.59 process, to facilitate changes that do not decrease safety. The design material subject to this change mechanism (Tier 2),
will be specified, by reference, and the remaining infor-mation in the design certification (Tier 1) will be changed only through the granting of an exemption via 10 CFR 50.12.
The staff envisions that the material subject to the Section 50.12 process (Tier 1) will include only top level design criteria and performance standards similar to that presented in Chapter 1.2 of an FSAR at the OL stage.
Remarks A significant amount of design information is still required to be submitted in an application for design certification.
However, as a result of introducing the "two-tiered" concept and allowing changes to Tier 2 information similar to those allowed in Section 50.59, the degree of standardization ensured by the regulatory process in this approach will be confirmed essentially to the degree of detail in Tier 1 and will be lower than that realized by the Level 1 and 2 approaches.
However, at a minimum, Level 3 still provides identical functional and performance characteristics. The initial cost to the applicant ($150 million - $350 million) is low compared to the cost of a developing Level 1 application.
i
i The Commissioners Solicifying only(Tier 1) will yield greater flexibilitythe top level des mance standards l
to modify, via the Section 50.59-type change process, the i
remaining Tier 2 information. This will allow for construc-l tion fit-up changes, and greater opportunity to implement technological improvements after certification. On the j
other hand, this approach will reduce the safety and cost benefits of standardization. Although all issues in Tier 1 and Tier 2, the separation by tier, and the test controlling j
the changes, will be subject to public comment and oppor-tunity for hearing in the certification rulemaking, changes made could be challenged later on the basis that they did
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not satisfy the Section 50.59-type test. The staff's review 1
of a Level 3 application will be more traditional as di-rected by the SRP, focusing on that information necessary to make its safety determination. The staff will not l
request material necessary solely for advancing l
standardization.
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There are three attributes of this approach that bear special attention: (1) it will require substantial amount of design engineering to be completed after certification (This infor-mation may be subject to adjudication at some later time as part of a combined license proceeding or later prior.
to operation (Section 52.103); (2) changes made to the Tier 2 information would be subject to challenge in hearings prior to Commission approval for operation; and (3) there is a potential for customized changes using the Section 50.59-type change mechanism and, therefore, poten-tial for loss of standardization.
LEVEL 4 The degree of standardization resulting from this level of detail and the certification process will provide at least a product line type of standardization.
This degree level of standardization is described here for completeness because it represents a level achieved among i
a group of four plants that nominally used the same " product" plant design offered by a vendor (i.e., the BWR/6-Mark III combination of nuclear steam supply system and containment).
{
The organizations that joined and set their courses to produce these plants were different for each of the four projects, and GE was the only organization common to all projects.
Notwithstanding the fact that these plants are nominally the same " product," they differ in very funda-l mental characteristics of their designs. The power levels vary among the four plants, but the configuration differences are far greater than the different power levels dictate.
Although the design pressure and temperature of the contain-ments were the same for all the plants, completely different
The Commissioners -
construction methods were used, and the containment volumes were all different.
Condensate and feedwater systems are markedly different in the numbers of booster and feed pumps, and the combinations of feed pump drives used.
The degree of standardization achieved by the four BWR/6-Mark III plants is less than would be obtained by the least standardization accomplished under Part 52.
For that reason, Level 4 is not compared further with Levels 1, 2, i
and 3.
Coordination:
The Office of General Counsel has reviewed this paper and has no legal objection.
Recommendations:
(1) The staff recommends that the Commission provide guidance to the staff regarding the level of detail to be required in an application for design certifi-cation and subsequent rule certifying the design under 10 CFR Part 52.
(2) The staff recommends that the Commission provide guidance regarding the two-tiered proposal and the 50.59-type change mechanism described in this paper, and its acceptability as an approach to providing flexibility for a design certification under Part 52.
(3) The staff recommends that the Commission authorize the prompt placement of this paper in the Public Document Room to facilitate the staff discussion of the various options with interested members of the public.
,6 '
9 b
J mes M. Tay1 xecutive Dir ctor for Operations
Enclosure:
Background on Level of Detail i
d i
i,
Commissioners' comments or consent should be provided directly i
to the Office of the Secretary by COB Friday, August 31, 1990.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Friday, August 17, 1990, with an infor-4
- t mation copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical i
review and comment, the Commissioners and the Secretariat should 1
be apprised of when comments may be expected.
This paper is tentatively scheduled for discussion at e.n Open Meeting during the Week of July 16, 1990.
Please refer to the j
appropriate Weekly Commission Schedule for a specific date and time.
SECY understands that the ACRS intends to provide comments following their August 1990 Committee meeting.
DISTRIBUTION:
Commissioners OGC OIG LSS GPA REGIONAL OFFICES EDO j
HVAC SVSTEM AT VARIOUS LEVELS 1
2 3
4 MFORMATION FOR ALL STRUCTURE / SYSTEMS 1
ANO COMPONENTS'UFECTING SAFE T Y (SCOPE)
A&C A&C N
N INFORMATf0N FOR SAFETY REL ATED AND RISK SIGNIFICMT STRUCTURES / SYSTEMS AND (SCOPE)
COMPONEN ".vNLY A&C A&C
- 1. DEStCN CRITERIA AND BA%ES A&C A&C A&C A&C
-4
-4 3
- 2. SYSTEM FUNCTIONAL DESCRIPTION A&C A&C A&C A&C 3
3 SYSTEM PERFORMANCE REQUl#EMENTS A&C A&C A&C N
]
- 4. FAILURE MODE ANO EFFECTS ANALYSES A&C A&C A&C N
S SYSTEM P&lDe ANO FACILITV L AYOUT ORAWINGS A&C A&C A&C M
- 6. ELECTRfC,AL & D&C SCHEMATICS A&C A&C A&C N
7 COMPONENT DESCRIPTIONS AND CHARACTERtSTICS 3
y l11 M$
q AIR MT AMES (RANGE FOR CAPACITV)
A&C A&C A&F M
k FILTERS (R ANGE FOR EFFICIENCV/ CAPACITY)
A&C A&C A&F M
3 E
4 as DUCTS (R ANGE FOR SIZE)
A&C A&C A&F M
n p
n F ANS (RANGE FOR CAPACITY)
A&C A&C A&F N
N 3
DAMPERS TVPE (RANGE FOR CLOSURE TIMES)
A&C A&C A&F M
M FLOW CONTPOL DEYlCES (TVPE)
A&C A&C A&F M
AIR CONOtTtONING UNITS (RANGE FOR CAPACITV)
A&C A&C A&F M
COOLING COIL TYPE to g., CleLLED WATER)
A&C A&C N
N A4C N
N HEATING COIL TYPE (e g ELECTRtC)
A&C FAN TYPE (e g., VANE AXtAL)
A&C A&C N
N FAN DRfvE te.g tMRECT)
A&C A&C N
N FILTER TYPE (e.g CHARCOAL)
A&C A&C N
N CHILLEO WATER CIRC. PUMPS (RA80GE FOR CAPACITV)
A&C A&C N
N
_ 8. PHYSICAL ATTRIBUTES AND CONFIG. OF EACH COMPONENT A&C M
N N
- 9. GEOMETINC ASPECTS OF SUSPENDEO COMPONENTS A&C M
N N
- 10. COMPONENT ANO STRUCTURAL SUPPORT DATA A&C N
N N
- 11. AS-PROCURED COMPONENT PERFORMANCE DATA N
N N
N A= APPLICATION C= CERTIFICATION F=FLEMISLE/ CHANGE W/O SO.12 N=NOT EXPECTED IN APPLICATION o
b
T Enclosure BACKGROUND ON LEVEL OF DETAIL Standardization as it exists today ranges from plants that are physically and functionally identical (except for site-related differences) to plants with functionally similar principal components only.
The greatest degree of physical and functional standardization, aside from identical units on the same site, is l
exemplified by the SNUPPS plants--Wolf Creek and Callaway. The degree of stan-dardization achieved by those plants was realized through the specific actions
)
and cooperatio.. of the participating organizations. SNUPPS plants were designed and built by an entity acting as an agent for several utilities.
The same architect / engineer (AE) and builder was used, utility input was included in the design, and identical parts were purchased for both plants at the same time--all this contributed to their similarity.
Additionally, individual utility preferences were deferred for the sake of standardization.
Although j
identically built, these plants are operated differently, in part because of differences in ultimate heat sink (e.g., Wolf Creek's higher heat rejection capability allows it to operate more efficiently than Callaway).
Strict control over design and construction does not necessarily ensure that' features initially standardized will remain constant throughout the life of an operating plant.
In order to realize the benefits inherent in the standardi-zation c,f multiple plants owned and operated by several utilities, those utilities will need continuing mutual agreement to work together to share operating data, evaluate events, pler. ano execute identical or similar plant
2 Enclosure modifications, share experience and plans for maintenance and training programs, i
and even to share costs of identical procurement actions.
Upon receiving full-power licenses, the Wolf Creek and Callaway plants began to diverge in design and operating practices.
However, recognizing the potential benefits of standardization, the two utilities decided to coordinate many of their activities.
Currently, the utilities share the costs of certain major modi-fications, lessons-learned, and training of outage personnel for specialized i
outage work.
i i
At the other end of the spectrum, standardization to a point that achieves a functionally similar design is exemplified by the GE -BWR/6-Mark III plants.
l These plants demonstrate a product line type of standardization with only l
containment, major components, and system functionality standardized.
See Attachment I for comparisons between the four BWR/6-Mark III plants.
When these plants were built, standardization was not a high-priority objective, but
[
the vendor sold the reactor type and containment general con-figuration as a
{
l i
generic product in large numbers over a short span of time (more than 40 orders j
l within 2 years; domestic and foreign, some of w'hich were canceled). The vendor recognized the benefits of standardization and established programs to guide l
the company's offering toward a more standardized product at a ' time when utilities wanted greater' power levels.
The result - of utility management's desires for custom-built features and other market forces was a product line standardization that resulted in four somewhat different domestic BWR/6-Mark III plants:
Grand Gulf, Perry, Clinton, and River Bend.
For a comparison of standardi ation as seen today, ne Attachment II.
.,.m a,e.-
4 3
Enclosure DESIGil DEVELOPMEllT In proceeding toward a license under Part 50, certain traditional factors influenced design development and the level of detail to which that design is ta ken.
NSSS vendors and AEs developed the design to the point that there was reasonable assurance of being able to deliver a product that would perform as 4
1 specified for a predetermined cost.
Design was developed to the extent that a manufacturer could provide equipment to meet performance specifications.
The amount of design detail available at any one time during the design / construction process was. dependent upon how critical that information was to continuing design / construction in other areas of the plant.
Additionally, the utility's contracting preferences and design traditions were accommodated during the design process under Part 50.
The FSAR was developed during construction as an output of the design and licensing process, constantly being revised to reflect the progress of design and construction at the facility.
At the time of licensing, the FSAR reflected a completed design and contained a considerable amount of as-built detail, i
l Interviewing various industry representatives revealed the same traditional f actors discussed above and some new factors influencing design development and level of detail in an application for a design certification under Part 52.
In contrast to the traditional Part 50 design and licensing process in which the FSAR was a prcduct of ongoing design and construction and contained as-built details, under Part EP the Standard Safety Analysis Report (SSAR) will act es input to the final design document.
Potential applicants for design l.
i 4
Enclosure certification are developing their design to the point at which they are confident they can deliver a product suitable for licensing that will perform as specified for a predetermined price.
Costs to reach this level are considered reasonable investments by potential applicants.
However, there remains a considerable amount of engineering to finalize the design.
COST In order to gain a perspective on the cost of design certification and degree l
of engineering completeness, the staff examined the engineering costs and accomplishments associated with various milestones of a recently licensed plant.
At this facility, by the time the construction permit was issued, approximately 600,000 man-hours or 4% of the total engineering hours had been expended (42 million 1990 dollars).
Approximately 9 million engineering man-hours or 60% of the total engineering hours were expended by the time the FSAR was first
]
docketed (630 million 1990 dollars), and 15.6 million engineering man-hours were required to develop a complete plant (1.092 billion 1990 dollars).
" Engineering" as used here, refers to total AE and utility engineering (design and design implementation) to the point of fuel load, not including site and QA/QC engineering.
On the basis of staff discussions with industry representatives, it appears that the prospective applicants for design certification of evolutionary 1fght-water reactors expect certification will require 50% - 60% of all design to be
l l
5 i
Enclosure j
complete for a cost of $150 million - $350 million.
Certain applicants believe that they currently have or will have more engineering completed than is necessary to support certification.
This appears to vary with the amount of outside participation the applicant has been able to attract.
Certain prospec-tive applicants have designs unoer way for evolutionary LWRs to be built overseas that afford them the AE and utility funding to develop more design detail based on a complete design on a specific site.
Some of the applicants have entered into joint ventures with AEs to provide engineering design.
i One of the prospective applicants now developing an advanced design for certi-fication expects completion of certification will require approximately 40% of design engineering to be completed for a cost of about $135 million.
This applicant also expects utility participation approximately two years before the design is certified.
It shoulo be noted in considering the percentage of engineering complete, the industry believes a large portion of the safety-significant engineering associated with the design will be completed earlier under Part 52 than in the i
traditional Part 50 process.
Although a considerable amount of detailed l
engineering design will remain to be translated into specifications and con-struction drawings after design certification, more design information will be developed and translated into engineering drawings, specifications, and analysis at the time of certification, than is now in a first-docketed FSAR under the Part 50 process.
l usp-m f'+9p g
+'5-
6 Enclosure ITAAC Inspections,
- tests, analyses, and acceptance criteria (ITAAC) must be developed by the applicant and submitted for staff review as specified in Section 52.47(a)(1)(vi).
ITAAC will provide reasonable assurance that a plant which references the design is built and will operate in accordance with the design certification.
Under Appendix B to Part 50, which is invoked by Part 52, design and construc-tion attributes will be verified by various processes.. The design of the facility will be validated by the design and document control process, procure-ment and construction verification will be performed as part of the applicant's construction quality assurance / quality control program, system performance will be verified through preoperational and start-rp tests, and deviations between the as-designed and as-built facility will be evaluated and dispositioned through the design reconciliation and corrective action process.
What is unique to the Part 52 process is the preconstruction identification of key elements of these programs that, in the past, evolved during the course of construction.
As defined in Part 52, the ITAAC must be necessary and sufficient to provide reasonable assurance that a plant that references the design is built and will operate in accordance with thc design' certification.
Depending on how
f 7
Enclosure the terms " reasonable assurance" and "necessary and sufficient" are interpreted, the ITAAC scope can range from the verification of every design and construction attribute included in the design certification to verification of directly measurable process parameters (e.g.,
flow, temperature, pressure, voltage, current) that demonstrate system performance / functionality.
For the Level 1 i
option, the ITAAC at or,e end of the spectrum, could be very detailed, since they may entail verification of a large number of design and construction l
attributes, i
Given that ITAAC will functionally duplicate other programs that verify hundreds if not thousands of design and construction attributes, the scope of ITAAC can be restricted to a set of principal attributes that are necessary and sufficient to provide reasonable assurance at the design certification stage that the plant will be built and will operate consistent with the design l
certification.
It is the staff's view that the ITAAC were not meant to be a one-for-one check of detailed design and construction attributes (e.g., the l
embedment length of anchor bolts) that are verified in the quality programs l
l already in place.
i Basically, there are two types of ITAAC.
The first includes direct verification of performance and construction attributes through field inspections, measurerrents, and tests; for example, pump operability tests includine pump flow and discharge pressure measurements.
The second type l
l 8
Enclosure l
4 validates performance and functional requirements that do not lend themselves to direct measurements; for example, the validation of' containment performance analyses results (e.g.,
maximum temperature and pressure under postulated l
accident conditions) by direct measurement of analyses assumptions, such as containment net-free volume.
As the level of detail available at design certification becomes more specific (i.e., standardization at Level 1), the ITAAC can, to a greater degree, call for verification of a greater number of
(
specific numerical, values of design and construction attributes, since these would be available. The proportion of named attributes for which quantitative l
values could be identified will be less at Levels 2 and 3.
However, as. discussed above, the ITAAC for Levels 1, 2, or 3 can contain the same attributes to be verified.
For all three levels, actual values determined during the post combined operating license (COL) construction period would be reconciled with system design requirements through ITAAC at the post COL stage.
l 4
ITAAC at the most detailed level will not provide additional verification of
^
design or construction beyond that achieved in the construction phase of a 1
project licensed under Part 50.
However, an adjunct and important function of j
the ITAAC is to ensure, at the design certification stage, the integrity and credibility of a one-step licensing process.
i p
9 Enclosure The ITAAC becomes an early, binding commitment to elements of existing quality
~
programs and serves as an independent final check, similar to the independent design verification programs (IDVPs) and readiness reviews that were conducted on recent operating license applications.
The ITAAC, like the IDVPs and readiness reviews provide additional assurance that th'e design and construction processes and the quality programs functioned adequately.
From this approach to ITAAC, several objectives are attained: (I) reasonable assurance is provided at the design certification stage that design and construction processes will be conducted and the plant will operate in accordance with the certification; (2) during and following construction, the principal performance criteria specified in the ITAAC will provide highly visible checkpoints for measuring and ensuring the as-built facility is in accordance with the certified design; (3) through a progressive and sequential implementation of the ITAAC, problems will be promptly identi'ied and addressed; and (4) throughout the plant's operating life, the ITAAC will ensure the design remains consistent with the certification.
i l
l
i i
ATTACHMEilT I L
BWR/6-fiARK III The BWR 6/ Mark III plants that are compared on the chart are in many areas similar with a pattern of differences due to an increase in power output on j
later models.
Examples are noted below for each of the areas on the comparison
{
charts.
Reactor Vessel and Internals:
Clinton and River Bend are virtually identical.
Perry and Grand Gulf are
]
notably larger and higher rated. Void coefficients, fuel temperature, doppler, minimum critical power ratio, initial U-235 enrichment, etc. are-slightly different.
diam.
Thick Height Rating Clinton 18'2" 5.3" 69" 2894 MWt River Bend 18'2" 5.3" 69" -
2894 MWt Perry 19'10 6.0" 70" 3579 MWt Grand Gulf 20'11 6.14" 73" 3833 MWt Fuel / Control Rods:
Although the fuel elements and control rods are similar, the same pattern of increhsing quantity is evident.
Fuel Assemblies Control Rods LPRfis Clinton 624 145 132 River Bend 592 145 132 Perry 748 177 164 Grand Gulf 800 193 176 1
1 ATTACHfiENT I l
l-i l
l l
l BWR/6-MARK III l
l Reactor Coolant System-Similar with the same increase pattern.
l l
- Jet Pumps Retirc Pump Flow (gpm)
Clinton 20 32,500 P.iver Bend 20 32,500 l
Perry 20 42,000 Grand Gulf 24 44,900 I
l Main Steam:
l l
l Only noted difference was an increase in pipe diameter.
l i
Clinton 24" River Bend 24" l
Perry 26
l-Grand Gulf 28" l
l Condensate and Feedwater:
The differences in the design of these were more significant than the previous areas as noted below.
- Cond.
- Cond.
- Feed.
Feed Pump Pumps Booster Pumps Drive Types Clinton 4
4 3
2 Turbine /1 Motor River Bend 3
0 3
All Motor j
Perry 3
3 3
2 Turbine /1 Motor Grand Gulf 3
3 2
Both Turbine l
2 i
I.
l l
l w
+mr P
m
i 4
ATTACHbEllT1 BWR/6-MARK III l
Containment:
Although the design pressure and temperature were the same for all four plants, the style of construction varied significantly.
Clinton Reinforced concrete cylindrical structure with hemispherical dome, steel lined, enclosing drywell and suppression pool.-
River Bend Cylindrical freestanding steel with ellipsoidal head.
Perry Cylindrical freestanding steel with ellipsoidal head with reinforced concrete shield building.
Grand Gulf Similar to Clinton Leak Rate (%/ day)
Volume (E6 ft3)
Clinton 0.65 1.55 i
River Bend 0.26 1.19 Perry 0.20 1.14 Grand Gulf 0.35 1.4 Reactor Protection System:
Clinton is significantly different from the others since they have the solid state reactor protection system.
l l
l i
l I
5
\\
l
__ ~.-
ATTACHMENT I BWR/6-f! ARK III Radwaste System: Gaseous Process Treatment
- Beds Release point Clinton Chilled charcoal 2
199.5' River Bend Chilled charcoal 8
190' Perry Recombiner &
8 134' chilled charcoal Grand Gulf Chilled Charcoal 8
31.5' Eletrical systems:
Clinton River Bend Perry Grand Gulf
- Offsite 4(1 units) 6(2 units) 5 3(1 unit)
Circuits 4(2 units)
- Aux Power 2 Aux, 4 Unit Aux.
4 Unit Aux 3 Service Sources 1 Rsrv Aux 1 Startup/
1 for ESF 1 Emerg.
4 Rsrv Aux.
Unit t Preferred Pwr 2
2
-2 3
to ESF Buses
- ESF Buses 3
3 3
3
- Stby A-C Pwr 3
6 6
6 Supplies (1/ESF)
(1/ESF)
(1/ESF)
(1/ESF) l i
- 125 V DC Systems 3 6
6 6
t
ATTACHMENT T BWR/6-MARK III Safety Systems:
ECCS are similar in design but again sized up.
Total LPCS(gpm)
HPCS(gpm)
RCIC(gpm)
ADS SRVs Clinton 5010 1400 600 7
16 River Bend 5010 1400 600 7
19 Perry 6000 1550 700 8
19 Grand Gulf 7115 1650 800 8
- Pumps LPCI (gpm/ pump)
J Clinton 2
5050 River Bend 2
5050 Perry 2
6500 Grand Gulf 4
7450 Emergency Service Water Systera:
Design of load allocation varied significantly from plant to plant resulting in a significant difference in ESUS flows.
Clinton 34,100 gpm River Bend 34,100 gpm Perry 22,700 gpm Grand Gulf 25,300 gpm 5
a ATTACHt1ENT I f
BWR/6-MARK III Ultimate Heat Sink:
Varied based on location.
- Circ. Water Pumps Clinton Lake 3
River Bend River 4
Perry Lake Erie 3
Grand Gulf River 2
Seismic / Structural Design:
Clinton River Bend Perry Grand Gulf SSE horiz. g 0.25 0.10 0.15 0.15 vert. g 0.25 0.10 0.15 0.10 OBE horiz. g 0.10 0.075 0.075 vert. g 0.10 0.075 0.050 Wind Speed 85 100 90 90 (mph)
Tornados (mph)
Transl.
70 70 70 60 Tangen.
290 290 290 300 Technical Specifications:
All 1S are unique hybrids incorporating BWR standard TS and plant specific designs.
6
G ATTACHMENT II
.i l
STANDARDIZATION SEEN TODAY SYSTEM DESCRIPTION SNUPPS BYRON /BRAIDWOOD BWR/6-MARK III
)
llolf Creek Grand Gulf Callaway Perry Clinton-River Bend Reactor Vessel and Internals I
I S
Fuel / Control Rods I
I C,RB:S GG,P:D Reactor Coolant Systen incl. ftajor Components Pumps / Valves /SG I
I C,RB:I' GG,P:S Main Steam I
I C,RB:I GG,P:S Condensate and I
I D
l Feedwater Main Turbine and I
I D
Control Valves 1
l Containment and flafor Components I
I GG,C:S P,RB:S 1
1
ATTACHMENT fI STANDARDIZATION SEEN TODAY I
SYSTEM DESCRIPTION SNUPPS BYRON /BRAIDWOOD BWR/6-MARK III Wolf Creek Grand Gulf Callaway Perry Clinton I
River Bend 4
l Reactor Protection RB,GG,P:S l
System I
I C:D Radwaste System I
I C,RB:S GG,P:D i
j Electrical System 5
S D
i (diff. lines)
(diff. lines)
AC/DC Onsite I
I RB,P,GG:S C:D Safety Systems ECCS I
I C,RB:I GG,P:S SLIC/RCIC NA NA C,RB:I GG,P:S AFW I
I NA RHR System I
I C,RB:I GG,P:S
l 1
ATTACHMENT II i
j i
i STANDARDIZATION SEEN TODAY l
SYSTEM DESCRIPTION SNUPPS-BYRON /BRAIDWOOD BWR/6-MARK III i
I Wolf Creek Grand Gulf.
Callaway Perry Clinton River Bend l
t Process Control Turbine I
I D
I D
I S
Service Water Systems D
D D
~
l Component Cooling Water D
D D
D D
l
(
1 l
l
\\
1 C = Clinton GG = Grand Gulf RB = Rive-9end P = Perry I = Identical S = Similar D = Different 3
ATTACHMENT II 1
J l
l STANDAP.DIZATION SEEN TODAY SYSTEM DESCRIPTION SNUPPS BYRON /BRAIDWOOD BWR/6-MARK III j
1 Wolf Creek Byron Grand Gulf NSSE W
W GE AE Bech S&L Bech CONST Dani CWE Callaway Braidwood Perry W
W GE Bech S&L Gil i
Dani CWE Kais i
Clinton GE S&L Bald i
River Bend GE S&W S&W GE:
Westinghouse Bald: Daldwin Associates Bech: Bechtel CWE: Commonwealth Edison Dani: Daniel International S&L:
Sargent and Lundy S&W: Stone and Webster 4