ML20071L730
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May 29, 1990 l
r MEMORANDUM FOR:
Commissioner Curtiss FROM:
'Connaughton
SUBJECT:
OVERVIEN DISCUSSION OF NUCLEAR POWER FACILITY DESIGN DEVELOPMENT AND DETAIL Attached is a copy of the crude hierarchy of design documentation t
which I previously provided to you.
The purpose of this memo is to discuss the hierarchy in narrative fashion to give you some further idea of what levels of design detail'are involved with design documents included in the hierarchy.
Encineerina Specifications Engineering design, construction, and installation specifications l
l for nuclear power facilities are typically generated at several levels of detail and are great in number owing to the fact that l
the engineering design cuts across several engineering disciplnes, numerous special engineering design topics, and numerous specialized construction and installation processes.
Engineering design specifications cover equipment performance requirements at the plant, structure, system, and component levels.
Similarly, construction and installation specifications can specify requirements applicable at the plant, structure, i
l system, and component level.
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Desian Drawines Design drawings are also generated at several levels of detail and span the gap between engineering design, construction, and installation specifications (the abstract) and the as-built plant (the physical).
For example, building general layout drawings will show overall building dimensions and other major architectural features which can be known early in the design and which are deemed feasible and compatible with civil / structural engineering design specifications.
As the design matures, more detailed drawings are generated showing, for example, the placement of reenforceing steel in structural concrete, or the details of bolted connections for joining structural steel girders.
As the design matures, it is possible that major architectural features originally proposed may have to be modified.
If so, the general layout drawings would be modified accordingly.
To actually construct the building, design drawings must be extremely well developed -- to-the point that the construction foreman can look at the drawing and know exactly what it is that his crew is building.
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PDR COMMS NRCC i
CORRESPONDENCE PDR
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An analogous situation applies to design drawings pertaining to plant equipment at the system, subsystem, and component levelc.
Upper tier drawings will show mechanical equipment and systems in schematic form.
Similarly, instrumentation may be represented by logic diagrams or process flow charts.
More detailed drawings will show the physical configuration of systems and equipment until, as was the case with the structural drawings discussed above, a construction crew can actually install the equipment knowing, for example, the location of each cable splice, the number and size of anchor bolts and nuts for a particular conduit support, or the exact terminal block and termination screw that a particular control system wire is to be attached.
Design drawings that provide the most detail (the physical configuration) are sometimes refered to as " construction" drawings because they are necessary for construction and are actually used at the job site.
Despite this designation, they are, in the strictest sense, desian drawings which translate j
higher tier design requirements into a complete physical plant design.
ITAAC ITAAC also can be specified at many different levels of detail.
For example, ITAAC may be specified for plant thermal energy or electrical energy output.
ITAAC may simply specify conformance with a given code or standard.
ITAAC may cover the required torque to be applied to bolts on a particular mechanical support (e.a. a pipe hanger).
ITAAC detail therefor mirrors the level of design detail.
If a design is not mature, ITAAC will necessarily be general in nature.
If, on the other hand, a design is complete, ITAAC may be stated in a very specific and concise manner, such as a bolt torque.
Translation of general ITAAC to more detailed ITAAC is also a design engineering function.
It therefor appears that the NUMARC proposed approach to ITAAC does not so much attempt to compensate for a lack of design detail so much as to provide ITAAC which are very generally stated because of a lack of design detail.
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HIERARCHY OF DESIGN REQUIREMENTS RULES AND REGULATIONS I
STANDARD REVIEW PLAN /BTPs REGULATORY GUIDES / CODES AND STANDARDS II.
APPROZINATE HIERARCHY OF DESIGN DETAILI GENERAL ENGINEERING DESIGN, CONSTRUCTION, AND INSTALLATION SPECIFICATIONS (CIVIL / STRUCTURAL, MECHANICAL, ELECTRICAL, HVAC, I&C)
THESE ARE INDEED GENERAL, USUALLY SETTING FORTH GENERALLY APPLICABLE REQUIREMENTS, INCLUDING TOP TIER DESIGN PERFORMANCE REQUIREMENTS, CODES AND STANDARDS, AND QA/QC REQUIREMENTS.
BUILDING / SYSTEM DESIGN SPECIFICATIONS (INCLUDING PERFORMANCE REQUIREMENTS AND MATERIAL SPECIFICATIONS)
ARCHITECTURAL DRAWINGS (BUILDING LAYOUT)
GENERAL ARRANGEMENT DRAWINGS i
PROCESS FLOW DIAGRAMS, IEC IDOP DIAGRAMS, ELECTRICAL AND I&C IDGIC DIAGRAMS i
P& ids (INCL. HVAC), ELECTRICAL ELEMENTARY DRAWINGS, I&C ELEMENTARIES PIPING /HVAC/ CABLE TRAY AND CONDUIT ISOMETRICS, MAJOR COMPONENT INSTALLATION DRAWINGS, ARCHITECTURAL DRAWINGS (STRUCTURAL DETAIL)
PIPING / CABLE TRAY / CONDUIT /HVAC SUPPORT DESIGN DETAIL DRAWINGS, CABLE PULL SHEETS, ELECTRICAL TERMINATION DRAWINGS, ELECTRICAL AND IEC COMPONENT SCHEMATICS, PIPING / MECHANICAL WELD DETAILS, CABLE SPLICE DETAILS, AND PIPING, CABLE TRAY, CONDUIT, HVAC DUCT, COMPONENT INSTALLATION DETAIL DRAWINGS AS-BUILT (POST-CONSTRUCTION) ARCHITECTURAL, STRUCTURAL, MECHANICAL, ELECTRICAL, I&C, HVAC, DRAWINGS (NOT APPLICABLE TO DESIGN CERTIFICATION).
III. SAMPLE LIST OF PROCEDURES TRANSLATING CONSTRUCTION AND INSTALLATION SPECIFICATIONS -- GENERALLY APPROVED BY THE DESIGNER:
CONSTRUCTION AND INSTALLATION PROCEDURES, INCLUDING REBAR INSTALLATION (TIEING AND CADWELDING), CONCRETE PLACEMENT AND DEAERATION, EMBEDDED BOLT PLACEMENT, STRUCTURAL STEEL ERECTION, MASONRY WALL CONSTRUCTION, EQUIPMENT SETTING, WELDING, SOLDERING, BOLT TORQING, CABLE PULLING, LIFTING AND RIGGING, PROTECTIVE COATING APPLICATION, ROTATING EQUIPMENT ALIGNMENT, ELECTRICAL TERMINATIONS, CABLE TIE WRAP INSTALLATION, LABELING, CABLE SPLICING, SNUBBER INSTALLATION, REBAR CUTTING, EXPANSION ANCHOR INSTALLATION, ETC.
NOTES:
1)
THIS HIERARCHY IS HARDLY EXHAUSTIVE AND TERMINOLOGY VARIES FROM VENDOR /A/E TO VENDOR /A/E.
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THE PSAR/FSAR MAY TOUCH ON ALL ASPECTS OF OF THE DESIGN i
DETAIL HIERARCHY, BUT GENERALLY ONLY SCRATCHES THE SURFACE.
3)
VARIOUS ANALYSES, INCLUDING THE SAFETY ANALYSIS, STRESS ANALYSES, EQ ANALYSES, FIRE PROTECTION ANALYSES ETC. EVOLVE AS THE DESIGN DETAIL IS DEVELOPED.
4)
AS THE DESIGN MATURES, ALL LEVELS OF THE HIERARCHY MAY BE SUBJECT TO MODIFICATION.
5)
DETAILED PROCUREMENT, CONSTRUCTION AND INSTALLATION SPECIFICATIONS EVOLVE WITH THE DESIGN.
6)
BELOW THE DOTTED LINE IN THE HIERARCHY, IT BEGINS TO BE ESSENTIAL (AS APRACTICAL MATTER) THAT YOU KNOW WHAT SPECIFICALLY YOU ARE BUYING FROM WHOM. ADDITIONALLY, YOU MUST GET TO BELOW THE DOTTED LINE IN ORDER TO PREPARE COMPLETE PROCUREMENT SPECIFICATIONS.
7)
IN ORDER TO SATISFY THE OBJECTIVES OF PART 52, IT WOULD APPEAR THAT ALL OF THE LEVELS OF DESIGN DETAIL LISTED ABOVE SHOULD BE INCLUDED IN THE DEFINITION OF " ESSENTIALLY 1
COMPLETE DESIGN".
8)
THE SUBSTANTIVE REQUIREMENTS / ACCEPTANCE CRITERIA OF THE INSTALLATION PROCEDURES, SUCH AS THOSE CITED ABOVE, SHOULD BE CAPTURED BY ITAAC.
THEIR ARE QC INSPECTION AND TEST REQUIREMENTS ESTABLISHED IN THE INSTALLATION PROCEDURES THEMSELVES OR IN STAND-ALONE CHECKLISTS TO PROVIDE INDEPENDENT VERIFICATION THAT ALL NECESSARY REQUIREMENTS ARE i
MET.
Eosterina Standardization Over the years, the Commission has made numerous statements reflecting the Commission's intent to increase the degree of standardization and foster the development of standardized designs.
Such statements are contained in early policy statements on standardization, in the Notice of Proposed Rulemaking on Part 52, and in the Statements of Consideration supporting Part 52.
Examples of the Commission's expressions of intent in this regard are set forth below.
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Proposed Rulemakina - Licensina of Duplicate Nuclear Power Plants. Review of Standard Nuclear Power Plant Desians (39 FR 13668, 4/16/74) o "On April 28, 1972, the Commission issued a policy statement, which pointed out the contributions that standardization could make to higher operating reliability, maintenance and improvement of protection to public health and safety and environmental values, concentration of safety-related research and development efforts into fewer areas, and greater efficiency in AEC review of plant design.
Industry was encouraaed to explore possible means of achievina creater standardization.
(emphasis added)
Statements of Consideration - Licensina of Duolicate Nuclear Power Plants: Review of Standard Nuclear Power Plant Desians (40 FR 2974, 1/17/75) o "The Commission believes that standardization of nuclear power reactors can make a significant contribution to higher operating reliability, maintenance and improvement of protection to public health and safety and environmental values, concentration of safety-related research and development efforts into fewer areas, and greater efficiency in.AEC reviews of plant design.
Several comments were received to the effect that an environmental impact statement need not be issued by the Commission in conjunction with a rule making proceeding to approve a referenced design since subsequent individual plant i
application reviews will be accompanied by an environmental impact statement.
However, the National Environmental Policy Act and 10 CFR Part 51 require such a statement in a rule making proceeding that involves a major
2 Federal action significantly affecting the quality of the human environment.
Paragraph 7 of Appendix 0 reflects this requirement.
The fact that subsequent individual application reviews may also be accompanied by environmental impact statements does not affect the statutory obligation respecting such statements in a rule making proceeding."
40 FR 2974 at 2975.
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General Statement of Poliev - Standardization of Nuclear Power Plants (42 FR 34395, 7/5/77)
"The Nuclear Regulatory Commission continues to believe that o
the advances of standardization are significant enough to warrant its continuation and extension.
An important advantage is the enhancement of public health and safety due to the concentration of staff and industry efforts on the in-depth review of standard designs.
As a companion result, there is a reduction in the time and resources needed for the licensing review of a utility power reactor application which is based on a standard design, with the extent of the reduction dependent upon the degree to which the plant is j
standardized.
In addition, construction benefits can be realized through earlier availability of final design documents and through construction experience.
We firmly believe that standardization of the design of nuclear power plants continues to be in the interest of public health and safety, and of effective and efficient regulation, and we reaffirm our strona suonort for its continued and exoanded use within the Commission's reculatory activities.
- However, the full benefits of standardization will only be realized if both government and industry management are firm in their commitment to limit changes to an approved standard design tho those clearly needed for public health and safety reasons.
40 FR 34395 (emphasis added),
o "The Commission staff has completed a preliminary assessment of the standardization program to determine what further definition and support of the program is needed on the basis of the accumulated experience to date.
The purpose of this detailed study is to examine and recommend to the Commission various administrative steps, including possible changes in NRC regulations, for encouracina continued and expanded industry suonort for and particioation in the standardization orocram for nuclear oower olants.
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commission has previously recommended and is also now considering possible legislative changes which would encourage and allow fuller benefit to be realized from the
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3 concept of pre-approved sites and standardized facility designs.
40 FR 34395 (emphasis added).
o "The Commission would appreciate receiving comments and other steps that the Commission suggestions.
on...
might undertake to further encourage standardization.
40 FR 34395 at 34396.
Interim Statement of Policy on Standardization (43 FR 38954, 8/31/78) o "On June 29, 1977, the Commission issued a statement that reaffirmed its suonort of standardization and requested comments.
. on other steps that the Commission might undertake to further encourace standardization."
(emphasis added) l l
l Policy Statement on Standardization (52 FR 34884, 9/15/87) o "The policy statement encouraces the use of standard plant desians.
The intent of these actions [is] to improve the licensing process and to reduce the complexity and uncertainty in the regulatory process for standardized plants."
52 FR 34884 (emphasis added).
o "The Nuclear regulatory Commission believes that standardization of nuclear power plant desians is an important initiative that can significantly enhance the safety, reliability and availability of nuclear plants.
The l
Commission intends to improve the licensing process for standardized plants.
(emphasis added).
o "The purpose of this policy statement is to encouraae standardization.
(emphasis added).
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4 "The Commission's primary objectives in issuing a policy o
statement on nuclear power plant standardization are.
To encouraae the use of standard desians in futuie license applications in order to enhance plant safety.
(emphasis added).
o "The Commission believes that Congress should promote nuclear safety by pursuing legislative initiatives to further encouraae the standardization concept."
(emphasis added).
Frequently, the Commission points to the potential for enhancing safety as a basis for its desire to foster standardization.
o "Use of certified reference designs should enhance plant safety.
o "The Commission believes that the use of certified standardized designs can benefit the public health and safety by concentrating resources on specific design approaches without stifling ingenuity; by stimulating standardized programs of construction practice, quality assurance, and personnel training; and by fostering more effective maintenance and improved operation.
Standardization is expected to further improve the performance of future plants."
o "In stronalv endorsina the concept of standardization, the Commission acknowledges that there can be drawbacks.
The most significant is that specific problems may potentially affect a large number of reactors.
However, on balance, the Commission believes that the enhanced safety of reactor operation should far outweigh any disadvantages."
(emphasis added).
o With regard to maintainina standardization under the future regulatory framework, the Commission indicated that it
" expects that backfits to the design certification rule would be applied uniformly to all plants referencing the certified design.
Similarly, amendments to the design certification rule initiated by the holder of the design certification would also be applied uniformly to all plants referencing the standard design."
5 Proposed Rulemakina on Early Site Approvals.
Standard Desian Certifications - Part 52 "The Nuclear Regulatory Commission has long believed that o
standardized nuclear power plant designs.
could significantly enhance the safety and reliability of nuclear plants.
The considerable variation in the design, construction, operation and maintenance of nuclear plants has led to an operating reactor population of great variability and diversity, even amoag reactors from the same vendor.
[T]he "one-of-a-kind" approach may also have hindered the growth of significant economies of scale of benefit to safety and to the efficiency and predictability of regulation.
Standardization of reactor designs should result in greater accumulation of construction and operating experience with a given design, easier transfer of that experience from one reactor to another and more easily maintained qualified vendor support, all of which should advance safe and reliable operation."
o "In the face of.
experience with a population of unique plants, there have long been fundamentally only three alternatives for Commission action.
either make no effort to bring about an increased degree of standardization or propose legislation on standardization or enact by rulemaking as much of a scheme for oromotina standardization as the Commission's current statutory authority permits.
The Commission has for some time concluded against the first alternative, having decided that a substantial increase in standardization would enhance the safety and reliability of nuclear power plants and require fewer resources in safety reviews of plants.
The Commission has therefore pursued standardization both by proposing legislation -
without success - and by promulgating rules.
Lacking legislation on standardization, the Commission believes that the most suitable alternative for encouracina further standardization is to fill out and exoand the Commission's regulatory scheme for standardization.
Therefore, the Commission now proposes a new set of regulations to be placed in a new Part, 10 CFR Part 52."
(emphasis added) l i
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"For the past several years, the Commission has pursued Congressional affirmation of the goals of standardization in the form of a Nuclear Power Plant standardization and Licensing Act.
However, much of what this proposed legislation would provide can be put into effect now under the Commission's existing statutory authority."
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[The] structure [of the proposed rules] reveals the overall purpose of Part 52:
to improve reactor safety and to streamline the licensing process by encouracino the use of standard desians and by permitting early resolution of (emphasis added) environmental and safety insues.
o "In order to encourace standardization, the Commission will give priority among applications to those which reference standard designs and pre-approved sites." (emphasis added)
The Commission also indicated that it would look for special provisions to maintain standardization:
o In an attempt to ascertain what mechanisms might best preserve a standard design, the Commission asked for public comments on the following:
"In order to prevent continual regression from standardization among plants initially built according to the same design, should stricter standards than those in 10 CFR 50.12 be applied to requests for exemptions from a design certification rule?"
o "The stability of a certified standard design is essential to the concept of standardization.
For this purpose
[ proposed] 5 52.63 contains provisions whose purpose is to preserve design stability against three possible sources of change [ design changes imposed by the NRC, design changes requested by the holder of the design certification, design changes requested by an applicant for a CP/OL].
[T]he Commission believes that the benefits of standardization will not be fully achieved unless significant site-specific variation among plants referencing a given certified design is kept to an irreducible minimum."
o "The Commission believes that the proposed rule's restrictions on changes in certified designs should assure a lasting and high degree of standardization."
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Statements of Consideration - Part 52 (54 FR 15372, 4/18/89) 4 o
"The commission has lona souaht nuclear oower olant
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standardization and the enhanced safety and licensing reform which standardization could make possible."
(emphasis added) o On the matter of maintaining standardization:
" Standardization has the double aim of enhancing safety and making it possible to resolve design issues before construction.
Of these two aims, enhanced safety is the chief.
Achievement of the-enhanced safety which standardization makes possible will be frustrated if too frequent changes to either a certified design or the plants referencing it are permitted.
The final rule [with its restrictions on changes to the certified design) thus provides greater assurance that standardization and the concomitant safety benefits will be preserved."
10 CFR 52.63(b) specifically requires that the Commission consider and weigh the reduction in standardization that would result from an exemption from the certified design before it authorizes such an exemption.
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