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UNITED STATES
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WASHINGTON, D.C. 20555
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,k g o,L July 30, 1992
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MEMORANDUM FOR: The Chairman 4
j Commissioner Rogers trommissioner Curtiss Commissioner Remick "a,
Commissioner de Planque FROM:
James M. Taylor Executive Director for Operations i
SUBJECT:
QUARTERLY STATUS REPORT OF ADVANCED LIGHT WATER REACTOR l
REVIEWS (MARCH 1992 - MAY 1992)
In a memorandum of June 20, 1991, I directed the staff to prepare quarterly reports outlining the status of the NRC staff's reviews of advanced reactor designs. The enclosed quarterly report is the fourth in the series and covers the period from March 1, 1992, through May 31, 1992.
In this report, the staff addresses the review status of the Electric Power Research Institute (EPRI) Utility Requirements Documents (URDs) for evolution-ary and passive reactors, the General Electric Company (GE) advanced boiling water reactor (ABWR) design, and the Asea Drown Boveri/ Combustion Engineering (ABB/CE) System 80+ design. The staff received the Westinghouse AP600 application on June 26, 1992, and is reviewing it for acceptance.
The staff will describe the status of the AP600 in the next quarterly report.
The report consists of (1) an Executive Summary (Section I), (2) a discussion of technical and policy issues that could affect the schedule for more than one project (Section II), and (3) the status of the review of each advanced reactor project (Section III). The staff assessed the progress toward resolving each technical issue discussed and noted any effect on schedules.
The staff measured the progress in reviewing each advanced reactor project against milestones established in SECY-91-161, " Schedules for the Advanced Reactor Reviews and Regulatory Guidance Revisions." For instances in which significant milestones were not met, the staff estimated the effect on the overall schedules and described recovery actions that could minimize the effect on schedules.
The staff and GE have been meeting frequently to establish specific agreements l
on the scope and depth of GE's efforts to develop the first implementation of
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new regulatory requirements (e.g., inspections, tests, analyses, and accep-tance criteria (ITAAC). Development of ITAAC has been difficult and GE's l
CONTACT:
1 Joseph G. Giitter, NRR 504-1113 I
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The Comissioners i submittal of the complete ITAAC, an updated PRA and other information neces-sary for the staff review was substantially delayed. Therefore, the staff j
proposes to issue a draft final safety evaluation report to the Commission and ACRS by the scheduled date (August 1992) with approximately 350 open items.
j Although GE has indicated that they intend to comit increased resources to address open issues after the draft FSER is issued, based on their past performance, there will likely be a delay in the issuance of the final design approval (FDA) for the ABWR.
The staff's review of the ABB/CE System 80+ Design Certification application remains on schedule; however, ABB/CE was delayed in submitting some important information, which will likely cause the staff to prepare a draft safety evaluation report (DSER) containing approximately 600 open items.
i The staff expects to meet all major SECY-91-161 milestones for the EPRI URD.
1 The staff forwarded the FSER for the EPRI URD on evolutionary LWRs to the j
Comission on May 12, 1992, and sent the DSER for the EPRI URD on passive LWRs j
to the Comission on April 14, 1992.
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mi[W ecutive Director i
for Operations j
Enclosure:
As Stated 1
cc: SECY l
OGC l
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l-ENCLOSURE QUARTERLY STATUS REPORT OF l
ADVANCED LIGHT WATER REACTOR REVIEWS l
MARCH 1992 - MAY 1992 l
I.
EXECUTIVE
SUMMARY
This is the fourth quarterly report to the Commission on the status of the U.S. Nuclear Regulatory Commission (NRC) staff's design certi-i fication reviews of evolutionary and advanced light water reactors (LWRs). The report addresses the Electric Power Research Institute (EPRI) Utility Requirements Document (URD) for evolutionary and i
passive reactors, the General Electric Company (GE) advanced boiling water reactor (ABWR) design, and the Asea Brown Boveri/ Combustion l
Engineering (ABB/CE) System 80+ design.
The staff received the Westinghouse AP600 application on June 26, 1992, and is reviewing it for acceptance. The staff will describe the status of this applica-tion in the next quarterly report.
This report also includes a discussion of technical and policy issues that could affect the schedule for more than one project and an assessment and comparison of the progress of project reviews with the schedules listed in SECY-91-161, " Schedules for the Advanced Reactor Reviews and Regula-l l
tory Guidance Revisions," of May 31, 1991.
Responding to a Commission directive (COMKC-90-18), the staff began to define " remote and speculative" consequences in the context of l
severe accident mitigation design alternatives (SAMDAs).
Remote and l
speculative consequences would not be required to be considered in an environmental impact statement pursuant to the National Environmental Policy Act. The staff found no clear benefit in formally defining
" remote and speculative" but found that a working definition could be formed on.the basis of those accident sequences that are beyond consideration in the staff's severe accident rulemaking efforts.
SE substantially delayed its submittal of the complete inspections, tests, analyses, and acceptance criteria (ITAAC), an updated probabi-listic risk assessment (PRA), and other information necessary for the staff review. As a result, the staff is planning to issue a draft Final Safety Evaluation Report (FSER) to the Commission and the Advisory Committee on Reactor Safeguards (ACRS) with approximately 350 open items. Although GE has indicated that they intend to commit increased resources to address open issues after the draft FSER is issued, based on their past performance, there will likely be a delay in the issuance of the final design approval (FDA) for the ABWR.
The staff is reviewing the ABB/CE System 80+ design certification application as planned. The staff has received initial submittals for the fire hazards analysis, SAMDAs, interface requirements, and deviations from the Standard Review Plan (SRP). ABB/CE has not submitted a complete ITAAC; however, it did provide a number of pilot
, ITAAC that were unacceptable. ABB/CE plans to resubmit the pilot ITAAC after making changes based on staff comments. The staff plans to publish the draft safety evaluation report (DSER) in August 1992; however, the DSER will have approximately 600 open items.
The staff also plans to meet all major schedular milestones for the EPRI requirements document. On May 12, 1992, the staff forwarded the FSER for the EPRI URD Volume II (Evolutionary LWRs) to the Commis-sion. On April 14, 1992, the staff sent the Commission the DSER for the EPRI URD Volume III (passive LWRs). On February 20, 1992, the staff provided the Commission with a draft Commission paper describ-ing the major issues for the passive plants and selected issues for evolutionary plants. The ACRS held meetings to discuss this paper.
II.
TECHNICAL AND POLICY ISSUES THAT COULD AFFECT REVIEW SCHEDULES In Items A through D, the staff discusses the status of four major policy issues, including key milestones associated with each issue, that may affect the schedules for reviewing evolutionary and advanced reactor design applications.
Item D. is a new item not previously reported.
A.
NEPA/SAMDAs The staff has previously indicated that the resolution of the National Environmental Policy Act/ severe accident mitigation i
design alternatives (NEPA/SAMDAs) may delay the projected review schedules.
On July 31, 1991, the staff submitted to the Commission SECY-91-229, " Severe Accident Mitigation Design Alternatives for Certified Standard Designs."
In this paper, the staff requested that the Commission approve the staff's recommenda-tions to (1) address SAMDAs for certified designs in a single rulemaking, (2) approve the staff's approach for considering the costs and benefits of reviewing SAMDAs for standard plant design certification, and (3) approve the staff's proposal to advise applicants for design certification that they must assess SAMDAs and provide rationale supporting their decision.
i In a staff requirements memorandum of October 25, 1991, the Commission approved the staff's recommendations and " expressed a desire to be kept informed of the staff progress in defining remote and speculative as it reviews the ABWR submissions."
Remote and Soeculative Pursuant to the United States Code (USC) Title 42 5 4332, an environmental impact statement, such as that required by the l
National Environmental Policy Act (NEPA) does not need to l
discuss consequences that are " remote and speculative."
" Remote and speculative" is not defined within the NRC regula-1 tions and is not clearly defined in case law.
In COMKC-90-18, "NEPA Reviews for Design Certification," dated October 29, 1990, the Commission requested the staff to "ex-j piore potential concepts for defining remote and speculative" in connection with NEPA reviews of proposed SAMDAs submitted by design certification applicants.
In SECY-91-229, the staff informed the Commission that it would define " remote and i
speculative" in conjunction with the NEPA review for the ABWR.
Representatives of NRR, RES, and OGC met to discuss an approach to defining remote and speculative.
At this meeting, the staff explored whether or not such a definition should be quantita-i tive or qualitative, and the relationship of this definition to severe accident rulemaking. The staff finds no clear benefit to formally defining " remote and speculative." However, a i
j working definition of " remote and speculative" could be formed
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on the basis of.those accident sequences that are beyond consideration in the staff's severe accident rulemaking effort.
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.The Nuclear Management and Resources Council (NUMARC) -indicated l
that it would like to suggest a definition of " remote and l-speculative" for the staff to consider. The staff will make a 1
final recommendation to the Commission regarding a definition of " remote and speculative" after it considers the views from
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industry.
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1.
MILESTONES FOR LAST QUARTER j
To continue to interact with the applicants to obtain comprehensive assessments of NEPA/SAMDAs.
2.
MILESTONES ACCOMPLISHED The staff met with NUMARC two times during the current period to define the format for prospective SAMDA sub-mittals from the evolutionary plant vendors. The proposed format was outlined in a NUMARC document " Suggested Out-line for NEPA/SAMDA Amendments to 10 CFR Part 51 for ALWR Designs - Technical Support Document." The staff agreed in general with the proposed form and content of the NUMARC document; however, the staff will need to develop guidance for other issues noted during these meetings.
The issues are the consideration of averted onsite costs and the decision of whether or not to go beyond mitigation j
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3.
MILESTONES NOT ACCOMPLISHED i
l None l
4.
EFFECT ON SCHEDULE AND REC 0VERY The. staff is reviewing a document submitted by GE in response to a 10 CFR 50.34(f) requirement. The staff expects to perform the NEPA review of the ABWR using information primarily from this document, which addresses alternative improvements in devices for removing heat from the core and containment.
If the staff receives timely responses to questions it finds during the review of the 10 CFR 50.34(f) issues and SAMDA issues, the SAMDA review should not affect the schedule for ABWR certification.
5.
MILESTONES PLANNED FOR NEXT QUARTER The staff will continue to interact with industry on the need to consider averted onsite costs in SAMDA reviews.
l The staff is following current Commission guidance.
B.
ITAAC At this time, the resolution of the ITAAC is the critical issue in reviewing the evolutionary LWR designs.
1.
MILESTONES FOR LAST QUARTER a.
Review ITAAC submittals from GE and CE as they are received.
b.
Issue the " Status of ITAAC" Commission paper.
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MILESTONES ACCOMPLISHED l
a.
On April 8, 1992, GE submitted 40 system ITAAC and submitted the remaining ITAAC on June 1, 1992. On June 8, 1992, the staff discussed its preliminary comments on the latest submittal at the senior man-agers' meeting with GE.
b.
The staff formed an independent review group known as the "Greybeards" to review the ITAAC and their role in the 10 CFR Part 52 process. The charter of this group of senior NRC managers is to advise the Director of the Office of Nuclear Reactor Regula-1 i
( tion on (1) whether the NRC staff can make a final l
safety decision based on the information available in the safety analysis report (SAR), the Tier 1 description, and the ITAAC; and (2) whether the NRC staff has defined the appropriate scope and level l
of detail for the Tier I design certification pro-cess. The "Greybeards" met for the first time on May 5, 1992. The "Greybeards" also met on May 29, 1992.
c.
On June 11, 1992, the staff submitted a Commission paper on the status of the development of ITAAC for j
standard designs, SECY-92-214.
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CE plans to resubmit 10 pilot ITAAC for the Sys-tem 80+ in July 1992 after incorporating the staff's comments and intends to submit the full ITAAC in October 1992.
3.
MILESTONES NOT ACCOMPLISHED 4
None l
4.
EFFECT ON SCHEDULE AND REC 0VERY The delays by GE and CE in submitting complete and accept-able ITAAC have severely inhibited the staff in reviewing the designs and may prevent the staff from issuing final design authorizations on schedule.
In SECY-91-210, "In-spections, Tests, Analyses, and Acceptance Criteria (ITAAC) Requirements for Design Review and Issuance of a l
Final Design Approval (FDA)," and during the August 21, l
1991, Commission briefing, the staff stated that the schedule for design certification will be delayed if ITAAC l
submittals are significantly delayed or incomplete.
In a letter of October 23, 1991, the staff informed GE that a i
complete draft ITAAC with sufficient detail had to be submitted by the end of 1991 or the review schedule would be affected.
In August 1992, the staff will submit to the Commission and the ACRS a draft FSER that addresses some of the ITAAC.
The staff will address the remaining ITAAC as GE completes work on the ITAAC open items.
On May 1, 1992, ABB/CE submitted 10 pilot ITAAC for the l
staff to review. The staff concluded that the ITAAC lack i
sufficient detail and specific acceptance criteria for l
Tier 1 material. ABB/CE plans to resubmit the 10 pilot ITAAC in July 1992 after incorporating the staff's initial l
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comments and intends to submit the full ITAAC in October 1992. Although this submittal will be too late for the j
staff to consider in developing the ABB/CE System 80+
DSER, which is scheduled to be issued to the Commission in.
August of 1992, it may not affect the FSER issuance date of July 1993.
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5.
MILESTONES. PLANNED FOR NEXT QUARTER a.
The staff will continue to review ITAAC submittals from GE and ABB/CE.
b.
The staff will-meet with Westinghouse to discuss sample AP600 ITAAC and schedules.
C.
LEVEL 0F DESIGN DETAIL i
l The staff found several areas in the ABWR application in which it needed additional information to resolve its safety con-l cerns.
For a few limited areas of the design, it may be impractical for the designer to provide detailed information, such as detailed specifications for equipment that may become-obsolete in a couple of years' as technology continues to improve.
The staff and GE have agreed to develop design accep-tance criteria (DAC) in lieu of detailed design information for these very limited areas of the design. To accomplish this, the NRC would base its safety determination at design certifi-cation on acceptance criteria that are general and objective.
Check points would be developed to confirm compliance with i
system requirements and the acceptance criteria after the NRC issued the. combined operating license.
GE would document these i
issues in the safety analysis report (SAR) ~ and the ITAAC, _as appropriate. The review and approval of the DAC are especially important to the overall review process since the staff needs l
the DAC to arrive at a final safety determination on certain issues. As the staff completes its review of the DAC, it will forward them to the Commission and the ACRS.
1.
MILESTONES FOR LAST QUARTER The staff was to complete audits of the ABWR main steam feedwater, and safety relief valve (SRV) piping analyses in March and complete an audit of the ABWR seismic design t
in April.
2.
MILESTONES ACCOMPLISHED a.
The staff completed the design audits as planned.
b.
On June 1,1992, GE submitted all of the remaining
DAC except for those regarding human factors.
c.
The staff supported a number of meetings with the ACRS on DAC.
i d.
On May 28, 1992, the staff submitted SECY-92-196, a Commission paper on sample DAC.
3.
MILESTONES NOT ACCOMPLISHED i
None 4.
EFFECT ON SCHEDULE AND REC 0VERY l
The Commission provided guidance on the level of design detail necessary to support a design certification appli-cation (SRM on SECY-90-377, February 15,1991).
GE only recently submitted the information needed for the staff to make a safety determination. This has complicated the review by requiring the staff to issue requests for addi-i tional information (RAI) before the reviews can be com-pleted. This subject is also discussed under project milestones for the ABWR (Section III.a).
5.
MILESTONES PLANNED FOR NEXT QUARTER a.
The staff will continue to review DAC submittals.
l b.
The staff will continue to meet with the ACRS to discuss issues related to DAC.
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On July 9,1992, the "Greybeards" met to discuss DAC for ABWR piping systems.
j D.
DIVERSITY OF DIGITAL INSTRUMENTATION SYSTEMS The staff has proposed ~w requirements to address the diversity, reliability, and fault tolerance of the hardware and software in digital instrumentation systems.
For example, if a common-mode failure can defeat a safety function, the designer would be required to provide a diverse means to perform either the same function or a different safety function that provides equivalent protection.
The designer would be required to provide safety-grade displays and controls to actuate and moni-tor systems that perform critical safety functions and to monitor parameters.
These safety-grade displays and controls would be independent of the computer systems and would be located in the control room.
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l l l Neither the GE ABWR design nor the CE System 80+ design meet the staff's proposed requirements.
In a June 3, 1992, meeting with the Commission, GE stated that the current ABWR design has i
adequate diversity and that requirements proposed by the staff l
warranted a policy decision by the Commission.
In a letter of l
May 18, 1992, ABB/CE also disagreed with the staff's position.
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1.
MILESTONES FOR LAST QUARTER l
None (new issue) 2.
MILESTONES ACCOMPLISHED On June 1, 1992, the staff met with CE to discuss the diversity of digital instrumentation systems in the Sys-l tem 80+.
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3.
MILESTONES NOT ACCOMPLISHED l
None l
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4.
EFFECT ON SCHEDULE AND REC 0VERY l
l Although this issue has not yet affected the schedule, it could significantly affect schedules since it could in-volve changes to the control room designs.
If the NRC resolves this issue quickly, it may not affect the sched-ules.
S.
MILESTONES PLANNED FOR NEXT QUARTER l
To obtain Commission resolution of this policy issue.
This matter is currently before the ACRS (see staff memo te ';,9 Commission dated June 25,1992).
l III.
PROJECT HILEST0hc5 l
l A.
ABWR l
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In September 1987, GE submitted to the NRC its initial applica-l tion for certification of the ABWR design.
GE has amended the standard SAR for the ABWR 20 times.
The staff issued requests for additional information from February 1988 through December 1990. GE responded to them through July 1991. The staff has issued the DSER.
1.
MILESTONES FOR LAST QUARTER a.
The staff planned to hold monthly meetings with GE to resolve open issues.
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I b.
The staff planned to conduct design inspection
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audits at GE offices in San Jose, California.
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2.
MILESTONES ACCOMPLISHED a.
NRC senior managers continued to meet with GE rep-resentatives to resolve open issues during the last quarter.
b.
From March 23 through 27, 1992, the staff audited the ABWR main steam, feedwater, and safety relief valve (SRV) piping analyses.
c.
From March-30 through April 3, 1992, the staff audited the ABWR seismic design.
d.
From March 30 through April 2, 1992, the staff audited the design of building structures.
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In April 1992, the staff received a letter from the ACRS on the ABWR DSER.
3.
MILESTONES NOT ACCOMPLISHED The staff indicated that a complete draft ITAAC would have to be submitted by the end of 1991 or the review' schedule i
would be affected. GE completed its submittal on June 1, 1992--6 months late. Other GE submittals, such as PRA, have also been late.
4.
EFFECT ON SCHEDULE AND RECOVERY Because of late GE submittals, primarily regarding ITAAC and PRA, the staff concluded that it had insufficient time to complete its review in these areas, and that it would issue a draft final safety evaluation report to the Com-mission and ACRS by the scheduled date (August 1992) with t
some issues unresolved. These issues include PRA, severe accident closure, ITAAC, USIs/GSIs, IST, and technical specifications.
Although GE has indicated that they intend to commit increased resources to address open issues after the draft FSER is issued, there is a signifi-cant amount of information for GE to provide and for the l
staff to review to support the issuance of the final 1
l design approval (FDA) for the ABWR.
5.
MILESTONES PLANNED FOR NEXT QUARTER The staff will issue the draft FSER to the Commission in August 1992.
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CE SYSTEM 80+
I On March 4, 1991, ABB/CE submitted its application for design certification review.
In a letter of May 1, 1991, the staff informed the applicant that it had reviewed and docketed the
'ABB/CE System 80+ design certification application.
- However, this application did not include ITAAC, the reliability assur-ance program, or a detailed analysis of fire hazards.
1.
MILESTONES FOR LAST QUARTER a.-
Review the fire hazards analysis to be submitted in March 1992, and the SAMDAs and ITAAC scheduled to i
be issued in May 1992.
b.
Begin writing the ABB/CE System 80+ DSER, scheduled i
to be sent to the project manager (PM) on June 23, i
1992.
2.
MILESTONES ACCOMPLISHED l
a.
The staff held many meetings with ABB/CE represen-tatives during the last quarter. -Most recently the i
staff met with ABB/CE to provide comments on the pilot ITAAC-submitted by ABB/CE and to discuss diversity for the System 80+ digital. instrumenta-tion system. The timely resolution'of the last issue will be necessary in order for the staff to reach a certification decision on schedule for the l
ABB/CE System 80+ design.
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b.
ABB/CE has submitted information on fire hazards analysis, SAMDAs, interface requirements, and devi-ations from the SRP. ABB/CE also submitted 10 pilot ITAAC for the staff to review. However, ABB/CE plans to resubmit the 10 pilot ITAAC, after incorporating staff comments, in July 1992. ABB/CE I
plans to submit the complete ITAAC in October 1992.
c.
The staff began preparation of the ABB/CE System 80+ DSER.
3.
MILESTONES NOT ACCOMPLISHED The 10 pilot ITAAC submitted by ABB/CE were unacceptable.
The staff awaits responses to questions on shutdown risk.
ABB/CE informed the staff that it will provide responses to questions on shutdown risk in August 1992.
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4.
EFFECT ON SCHEDULE AND RECOVERY The staff plans to issue the DSER to the Commission by August 26, 1992, consistent with the schedule. However, the DSER will not address ITAAC, PRA, USIs/GSIs, and shutdown risk, primarily because CE did not provide timely, high quality information to the staff in these areas. The staff will address these open issues in the FSER.
5.
MILESTONES PLANNED FOR NEXT QUARTER ~
a.
Continue to review ABB/CE ITAAC (10 pilot ITAAC scheduled to be resubmitted in July 1992).
b.
Review the shutdown risk report due in August.
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c.
Issue the DSER in August 1992.
C.
EPRI UTILITY REQUIREMENTS DOCUMENT (URD) FOR EVOLUTIONARY REACTORS f
l 1.
MILESTONES FOR LAST QUARTER j
Issue the FSER to the Commission and ACRS.
2.
MILESTONES ACCOMPLISHED l
On May 12, 1992, the staff forward the FSER on the EPRI Evolutionary URD to the Commission. On May 14, 1992, the staff forwarded the FSER to EPRI and the public.
3.
MILESTONES NOT ACCOMPLISHED None l
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EFFECT ON SCHEDULE AND RECOVERY The staff met the scheduled date of May 13, 1992, for providing the FSER to the Commission and the ACRS.
5.
MILESTONES PLANNED FOR NEXT QUARTER i
a.
Continue to meet with the ACRS to discuss the staff's review of the EPRI URD on evolutionary i
LWRs.
b.
Issue the FSER to EPRI by August 18, 1992.
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D.
EPRI UTILITY REQUIREMENTS DOCUMENT FOR PASSIVE REACTORS 1.
MILESTONES FOR LAST QUARTER Provide the DSER to the Comission and ACRS.
2.
MILESTONES' ACCOMPLISHED On April 14, 1992, the staff. submitted the DSER to the l
Comission and the ACRS.
3.
MILESTONES NOT ACCOMPLISHED None l
4.
EFFECT ON SCHEDULE AND REC 0VERY J
The staff met the scheduled date of April 14, 1992, for i
submitting the DSER to the Comission and.the ACRS.
5.
MILESTONES PLANNED FOR NEXT QUARTER a.
Issue draft policy and technical issues paper-
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(" Grandson' of SECY-90-016") to the Comission in
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June 1992.
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