ML20128F139
| ML20128F139 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1992 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| PROJECT-681A SECY-92-403, NUDOCS 9212080271 | |
| Download: ML20128F139 (12) | |
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i POLICY ISSUE December 3, 199_2 The Commissioners For:
James M. Taylor from:
Executive Director for Operations ACCEPTANCE REVIEW 0F GE NUCLEAR ENERGY'S (GE's) APP FOR FINAL DESIGN APPROVAL (FDA) AND DESIGN CERTIFIC S_utdec t :
0F THE SIMPLIFIED BOILING WATER REACTOR DESIGN (SBWR)
To inform the Commission of the results of the staff s accep-tance review of GE's application for FDA and DC for the SBWR
Purpose:
design.
In its letter dated August 27, 1992, GE submitted its applica-tion for an FDA under Appendix 0 to 10 CFR Part 52 and a DC d
BackaroufL:
In under 10 CFR Part 52 for the SBWR standard plant design.
the SBWR design, passive safety systems are used for the All of the safety ultimate safety protection of the plant.
natural forces, such systems are designed to be passive, whera as gravity, natural convection, and stored energy (in the form of compressed gas or batteries), are used as the motive forces The SBWR has a number of unique features of these systems.
that distinguish it from both the current generation of light-water reactors (LWRs) and the evolutionary LWRs.
TO BE MADE PUBLICLY AVAILABLE NOTE:
IN 3 WORKING DAYS FROM THE CONTACT:
DATE OF THIS PAPER Jerry N. Wilson, NRR 504-3145 3 E)003 J, g
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-The Commissioners.
In accordance with 10 CFR 2.101 and the staff requirements memorandum (SRM) dated April 28, 1992, the staff performed an acceptance review to catermine if the SBWR application was complete and if it comolies with the Commission's requirements for the scope of such applications.
This includes addressing the areas defined in 10 CFR Parts 50 and 57, the most recent revision of Reguhtory Guide (RG) 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants,"
and the Standard Review Plan (NUREG-0800).
The staff also considered whether GE addressed other matters that the Commis-sion considers pertinent to the review of such designs.
These matters include policy issues and comparison to the Electric Power Research Institute's (EPRI's) Advanced Light-Water Reactor (ALWR) Requirements Document. The staff reviewed the application primarily to verify that the applicant had addressed all pertinent matters and did not determine if the appiicant's approach to resolving these matters is acceptable.
Making determinations about the latter is the primary objec-tive of the review and evaluation process that follows accep-tance of the application. Enclosure 1 is a detailed discus-sion of the criteria used for the acceptance review.
Discussion:
Results of Acceptance Review The staff has completed its acceptance review of the SBWR application and found it incomplete. Although it includes a considerable amount of design information, the application is missing information either required by 10 CFR 52.47 or con-sidered pertinent to the review. To complete its review of the application for an FDA and DC, the staff needs the infor-mation described below.
The following lists some of the 10 CFR 52.47 requirements for an FDA and DC that were not submitted with the GE SBWR.appli-cation.
This list is not inclusive, but is provided to indicate some areas where the SBWR application is incomplete.
All information necessary to meet the requirements of 10 CFR 52.47 and needed to support the review of the SBWR yplication will be formally requested of GE.
- 1. interface requirements for a standard design
- 2. description of conformance with standard review plan and applicability of codes and standards
- 3. response to TMI-related matters
- 4. failure modes and effects analysis
- 5. water level (flood) design
The Commissioners -
- 6. inservice testing of pumps and valves
- 7. seismic soil-structure interaction analysis
- 8. reactor coolant pressure boundary inservice inspection and testing
- 9. firo protection system
- 10. probabilistic risk assessment (PRA):
Level 1 (external events only), Levels 2 and 3
- 11. severe accident evaluation
- 12. logic diagrams for instrumentation and controls
- 13. Tier 1 design certification material (including inpections, tests, analyses, and acceptance criteria
[ITAAC))
- 14. unresolved safety issues and generic safety issues reso-lution for the SBWR design in addition to the items listed above, the staff identified-additional spec'efic areas where the standard safety analysis report (SSAR) is deficient. 'These included the detailed structural drawings for seismic Category I structures; detailed instrumentation and control hardware design; detailed information on the SBWR test program; resolution of inter-system loss-of-coolant accidents (LOCAs) for SBWR design reflecting the SECY-90-016 position; consideration of passive system failures in Chapter 15 analyses; PRA uncertainty and sensitivity analyses; risk from external events and-during plant shutdown and low-power operation; the conceptual design for each site-specific design feature; the instrumentation and controls design for the remote shutdown system; the bases, criteria, and inventory of controls, displays, and alarms-for the remote shutdown panel; and the description of'the human factors engineering verification and validation program.
The Commission has determined as a matter of policy that the-following information is also needed to support the review of an application for an FDA and DC.
GE has not submitted these items to support the review of the SBWR application. The appropriate references for these items are listed ir, parenthe-ses.
1.
a comparison of the design to the EPRI ALWR Requirements Document with the vendor's reason for deviation (SRMs dated December 15, 1989, and March 5, 1991) a
C The Commissioners 2.
a detailed discussion of the manner in which operational experience was incorporated into the design-(SRMs dated July 31, 1989, February 15 and March 5, 1991) 3.
a discussion of severe accident mitigation design alterna-tives (SAMDAS) required by the National Environmental Policy Act (NEPA) (SRMs dated October 29 and November 16, 1990)
In SECY-91-161, " Schedules for the Advanced Reactor Reviews and Regulatory Guidance Revisions," the staff estimated the -
review schedule for the SBWR on the basis of ALWR applicants' proposed schedules provided in early to mid-1991.
In making these initial schedule estimates for the SBWR review, the staff assumed that it would receive a complete application by August 1992.
In SECY-90-146, " Process, Schedule, and Resources for the Review of Evolutionary and Passive Advanced Light-Water Reactors," the staff stated that it had determined from the experience gained from the review of the GE ABWR and EPRI Requirements Document that a modular review approach is inefficient and is not desirable for future reviews.
There-fore, consistent with our handling of the AP600 application, the staff will not begin the formal review schedule for the SBWR until it receives a complete application.
The staff reiterated this proposed approach to the review process in the enclosure to SECY-91-161 and in SECY-92-120, "NRC Staff Review Schedules for the Westinghouse AP600 and the General Electric Simplified. Boiling Water Reactor Designs."
The staff also continues to endorse its recommendation in SECY-91-210 " Inspections, Tests, Analyses, and Acceptance.
Criteria (ITAAC) Requirements for Design Review and Issuance of a Final Design Approval (FDA)," that the review and approval of ITAAC be completed before issuing an FDA.
The staff's review of evolutionary designs has demonstrated the importance of performing the ITAAC and design reviews concur-rently.
GE stated in its letter dated February 24, 1992, that it intends to submit the remainder of its SSAR, including ITAAC, by February 28, 1993.
Under 10 CFR 2.802 and 10 CFR 52.51, if the missing material is not supplied _in 90 days, NRC may return the petition; in the meantime, the petition is not to be assigned a docket number.
However, because there is no question that the petitioner intends to complete the petition for FDA and DC, the staff intends to conduct some review to give GE early notice of issues and concerns, and proposes to assign a docket number. Assignment of a docket number will
The Commissioners -
facilitate public access to corresponde1,ce and' review informa-tion. The staff will establish its final review schedule for the SBWR application after reviewing this additional infor-mation and determining that the application is complete.
In SECY-92-120, the staff stated that the delay of the formal review schedule does not imply that the staff will ignore.the application until it is complete. The staff will continue to develop and issue requests for additional information (RAls)-
where sufficient information is available to do so.
- However, issuing these requests at this stage of the review is not intended to complete the RAI stage of the review.
The staff's intent is to provide GE with questions to identify initial staff concerns, and provide the opportunity to address these concerns in the completed application.
Staff Actions:
1.
Assign a docket number to the SBWR project.
This'will facilitate handling the large amount of technical ques-tions and information that is expected to be exchanged before GE completes the application.
2.
Issue the enclosed letter (Enclosure 2) to GE after three work days from the date of this paper to provide the results of the staff's acceptance review of the SBWR application for the FDA and DC.
3.
Issue RAls where sufficient information is available to do so, and forward them to CE to inform it of the staff's initial concerns without waiting for the complete submit-tal.
Coordination:
The Office of the General Counsel has reviewed this paper and has no legal objection.
A < $t( --
ames M.1491or Executive Director for Operations
Enclosures:
1.
Acceptance review criteria 2.
Proposed letter to GE DISTRIBUTION:
Conunissioners OGC OCid(
OIG OPA OPP EDO ASLBP SECY ACRS
CRITERIA FOR CONDUCTING THE ACCEPTANCE REVIEW 0F THE SIMPLIFIED BOILING WATER REACTOR (SBWR)-APPLICATION The staff conducted an acceptance review to determine if the SBWR application for final design approval (FDA) and design certification (DC) complies with the Commission's requirements for the scope of such an application.
This included addressing the areas defined in 10 CFR Parts 50 and 52, the most recent revision of Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," the Standard Review Plan (SRP) (NUREG-0800), and other areas discussed below.
The staff reviewed the application primarily to verify that the applicant had addressed all pertinent matters and not to determine if the applicant's approach to resolving these matters is acceptable.
Making determinations about the latter is the-primary objective of the review and evaluation process that follows acceptance of the application.
The staff performed the acceptance review on the technical documentation submitted with the application dated August 27, 1992.
The staff evaluated the application to determine if it addressed the areas defined in 10 CFR Part 52, policy papers developed by the staff, and other matters considered pertinent to the review by the Commission of such designs.
The following is a discus-sion of those items that the staff considered during the acceptance review.
1.
The staff evaluated the submittal to determine if it complies with the requirements of 10 CFR 52.47, including a.
technical information that is required by 10 CFR Parts 20, 50 and its appendices, 73, and 100, and which is technically relevant to the design and not site-specific. These areas are defined in I
Regulatory Guide 1.70 and the SRP.
b, demonstration of compliance with any technically relevant portions of the TMI-2 requirements of 10 CFR 50.34(f).
l c.
the site parameters postulated for the design and an analysis and evaluation of the design in terms of these parameters.
d.
proposed technical resolutions of those unresolved safety issues (USIs) and medium-and high-priority generic safety issues (GSIs) that are identified in the version of NUREG-0933, "A Priorization of Generic Safety Issues," current on the date 6 months beforr the application (in the case of the SBWR design, December 1991) and that are technically relevant.
e, a design-specific probabilistic risk assessment.
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f.
proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the tests, inspections, and analyses are performed and the acceptance criteria met, a plant referencing the design'will be built and operated in accordance with the design certification.
g.
the interface requirements to be met by those portions of the plant for which the application does not seek certification, with justifi-cation that compliance with these interface requirements are verifi-able through inspection, testing, or analysis.
h.
a representative conceptual design for those portions of the plant for which the application does not seek certification.
2.
The staff evaluated the submittal to determine whether or not it addresses issues discussed in the staff's policy papers and other matters that the Commission considers pertinent to the review of this design, including a.
a reliability assurance program that addresses the technical specifi-cations, the inservice inspection and inservice testing program, the maintenance program, the plant procedures, and the security program (see SECY-89-013, " Design Requirements Related to the Evolutionary Advanced Light Water Reactors (ALWRs)," and the staff requirements memorandum (SRM) dated June 31, 1989),
b.
design acceptance criteria where detailed design information is missing (see SECY-92-053, "The Containment Performance Goal, External Events Sequences, and the Definition of Containment Failure for Advanced Light Water Reactors " and SECY-92-196, " Development of Design Acceptance Criteria (DAC) for the Advanced Boiling Water Reactor (ABWR)"),
c.
a discussion demonstrating that the design adequately addresses the policy issues discussed in SECY-90-016, " Evolutionary Light Water Reactor (LWR) Certification issues and Their Relationship to Current Regulatory Requirements," and the draft Commission paper dated Feb-raary 27, 1992, d.
a discussion of severe accident mitigation design alternativas required under the National Environmental Policy Act (see SECY-91-229,
" Severe Accident Mitigation Design Alternatives for Certified Standard Designs").
This discussion substitutes for one addressing areas defined in the Environmental Standard Review Plan (NUREG-0555) as required for applications for construction and licensing permits.
e.
a comp:irison of the SBWR design against the EPRI ALWR Utility Require-ments Document (see the SRM dated December 15, 1989).
f.
a detailed discussion of how operational experience was incorporated into the design (see the SRMs dated February 75 and March 5,1991).
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Docket No.52-004 (Previously Project No. 681)
Mr. Patrick W. Marriott, Manager Licensing & Consulting Services GE Nuclear Energy 175 Curtner Avenue San Jose, California 95125
Dear Mr. Marriott:
SUBJECT:
RESULTS OF ACCEPTANCE REVIEW FOR GE NUCLEAR ENERGY'S (GE's)
APPLICATION FOR FINAL DESIGN APPROVAL (FDA) AND DESIGN CERTIFICA-TION (DC) 0F THE SIMPLIFIED BOILING WATER P.EACTOR (SBWR) DESIGN In a letter dated August 27, 1992, GE submitted its application for an FDA and a DC under 10 CFR Section 52.45 for the SBWR standard plant design.
The contents of the application were made in conformance with the requirements of 10 CFR 52.47 and included the standard safety analysis report (SSAR) for the
- design, in accordance with 10 CFR 2.101, the staff performed an acceptance review to determine if the SBWR application was complete and found that the application is incomplete. The missing information is either required by 10 CFR 52.47 or considered pertinent to the review by the Commission. The following lists some of the information the staff requires to complete-its review of your application.
1.
interface requirements for a standard design 2.
description of conformance with standard review plan and applicability of codes and standards 3.
response to THI-related matters 4.
failure modes and effects analysis 5.
water level (flood) design 6.
. inservice testing of pumps and valves 7.
seismic soil-structure interacticn analysis 8.
reactor coolant pressure boundary inservice inspection and testing DRAFT I
ll DRAFT Mr. Patrick W. Marriott.
9.
fire protection system 10.
probabilistic risk assessment (PRA):
Level 1 (external events only),
levels 2 and 3 11.
severe accident evaluatico 12.
logic diagrams for instrumentation and controls 13.
Tier 1 design certification material including ITAAC 14.
unresolved safety issues and generic safety issues resolution for the SBWR design In addition to the items listed above, the staff identified additional specific areas where the SSAR is deficient. These include detailed structural drawings for seismic Category I strr +ures; detailed instrumentation and control hardware design; detailed ii. formation on the SBWR test program; resolution of intersystem loss-of-coolant accidents (LOCAs) for SBWR design reflecting the SECY-90-016 position; consideration of passive system failures in Chapter 15 analyses; PRA uncertainty and PRA sensitivity analyses; risk from external events and during plant shutdown and low-power operation; the conceptual design for each site-specific design feature; the instrumentation and controls design for the remote shutdown system; the bases, criteria, and inventory of controls, displays, and alarms for the remote shutdown panel; and the description of the human factors engineering verification and validation program.
The Commission has determined as a matter of policy that the following information is also needed to support the review of an application for an FDA and DC.
GE did not submit these items in the SBWR application.
The appropri-ate references for these items are listed in parentheses.
1.
a comparison of the design to the Electric Power Research Institute's (EPRI's) Advanced Light-Water Reactor (ALWR) Requirements Document with the vendor's reason for deviation (SRMs dated Deramber 15, 1989, and March 5, 1991) 2.
a detailed discussion of the manner in which operational experience was incorporated into the design (SRMs dated July 31, 1989, February 15 and March 5, 1991) 3.
a discussion of severe accident mitigation design alternatives (SAMDAS) required by the National Environmental Policy Act (NEPA) (SRMs dated October 29 and November 16,1990)
The staff will issue a more detailed description of the missing and deficient information under separate cover.
In addition, the design of the SBWR must l
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Mr. Patrick W. Marriott -
also be consistent with the final agency positien) inat have not yet been established on applicable policy issues that will be identified during the staf f's reviews of ALWRs.
The staff has assigned Docket Number 52-004 to the SBWR project to facilitate public access to correspondence and review information.
However, in the enclosure to SECY-91-161, " Schedules for the Advanced Reactor Reviews and Regulatory Guidance Revisions," the staff stated that the staff...has deter-mined from the experience gained from the review of the ABWR and EPRI Require-ments Document that a modular review approach is inefficient and is not desirable for future reviews. Therefore, consistent with our handling of the AP600 application, the staff will not begin the formal review schedule for the SBWR until a complete application is received by the staff.
Therefore, the staff will establish the formal review schedule for the SBWR only after determining that the application is complete.
In the application, GE stated that it will submit all of the ITAAC information by February 28, 1993. The staff does not yet have an estimate for submittal of the other missing information. is a copy of the notice relating to the application that has been sent to the Office of the Federal Register for publication.
In SECY-92-120, "NRC Staff Review Schedules for the Westinghouse AP600 and the General Electric Simplified Boiling Water Reactor Designs,"-the staff stated that the delay of the formal review schedule does not imply that the staff will ignore the application until it is complete. The staff will continue to develop and issue requests for additional information (RAls) where sufficient information is available to do so.
However, issuing these requests at this stage of the review is not intended to complete the RAI stage of the review.
The staff's intent is to provide GE with questions to identify initial staff concerns, and provide the opportunity to address them when you complete the application.
If you have any questions or comments concerning this matter, you may contact C. Poslusny or J.N. Wilson at 504-1118.
Sincerely, Dennis M. Crutchfield, Associate Director for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation
Enclosure:
As stated
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hhh United States Nuclear Reaulatory Commission GE Nuclear Enerav Receiot of Application for Desian Certification Notice is hereby given that the Nuclear Regulatory Commission (the Commission) has received an application from GE Nuclear Energy (GE) dated August 27, 1992, filed pursuant to Section 103 of the Atomic Energy Act and 10 CFR Part 52, for design certification of the Simplified Boiling Water Reactor (SBWR) Standard Plant Design.
A notice relating to the rulemaking pursuant to 10 CFR 52.51 for design certification, including provisions for participation of the public and other parties, will be published in the future.
The SBWR is a 670 MWe boiling water reactor in which passive safety systems are used for the ultimate safety protection of the plant. All of the safety systems are designed to be passive, where natural forces, such as gravity, natural convection, and stored energy (in the form of compressed gas or batteries), are used as the motive forces of these systems.
The SBWR has a number of unique features that distinguish it from both the current generation of light water reactors and the evolutionary light water reactors.
The SBWR application includes the entire power. generation complex, except those elements and features considered site-specific, and is not a modular design in which major components are shared.
The application is incomplete in several important respects, and cannot, therefore, be accepted formally as a rulemaking petition for design certifica-tion. However, the NRC staff plans some review activities at this early stage to give GE notice of issues and concerns. Therefore, Docket Number 52-004 i.
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is being assigned to the application to facilitate public access to correspon-dence and review information.
No formal review schedule has been-established.
The staff will establish its review schedule for final design approval after GE supplies the missing material.
A copy of the application is available for public inspection at the Commission's Public Document Room, the Gelman Building, 2120 L Street, N.W.,
Washington, D.C.
Previous correspondence on this application was filed under Project Number 681.
The new docket number established for this application is52-004.
Dated at Rockville, Maryland this day of 1992.
FOR THE NUCLEAR REGULATORY COMMISSION Robert C. Pierson, Director Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation Q