ML20128G727

Discusses Policy Issues Pertaining to AP600 Design. Staff Request for Policy Decision Considered,Premature

ML20128G727
Person / Time
Site:	05200003
Issue date:	08/27/1996
From:	Mcdonald R ELECTRIC POWER RESEARCH INSTITUTE
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20128G705	List: ML20128G702 ML20128G727
References
NUDOCS 9610090109
Download: ML20128G727 (3)

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Electnc Power Posenng Progress through Innovatne Solutions Research Inststu1e August 27,1996 The Honorable Shirley Ann Jackson, Chairman 3

U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Policy Issues Pertaining To The AP600 Design

Dear Chairman Jackson:

The purpose of this letter is to endorse Westinghouse positions detailed in l' reference 1, submitted to the NRC in response to NRC staff recommendations to the Commissioners regarding AP600 policy issues (reference 2). This endorsement of the Westinghouse positions is provided on behalf of the Advanced Light Water Reactor (ALWR) Utility Steering Committee (USC), w is the body that directs the utility community's financial and technical supp the national effort to develop and certify advanced light water reactor designs.

References 1 and 2 disagree on two policy issues, " Prevention and Mitigatio i Severe Accidents" and " Post 72-Hour Actions", for which near-term decisions the Commissioners are sought by reference 2.

The USC's principal concern is with the following portion of the staff recommendation on " Prevention and Mitigation of Severe Accidents":

h AP600 "Therefore,in light of the enhanced safety that is expected from t e desien. the staff recommends that the Commission approve for the AP60 the use of non-safety-related system (s) to address the uncertainties associated with the passive natural fission product removal mechanisms for design basis analysis . ."

Use of a "non-safety-related" system in the context of a " design basis ana involving fission product removal capabilities required to meet establis regulatory requirements for the protection of publi related" systems, components, and structures for adequacy to meet suc requirements. In addition, such use of a non-safety-related system introduce a potential challenge during the rulemaking phase of the desig certification process.

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The Honorable Shirley Ann Jackson August 27,1996 Page 2 Additionally, the staff request for a policy decision is premature. The staff cannot have completed its evaluation of the latest Westinghouse input on fission product removal in AP600 (reference 3). Reference 3 was submitted by l Westinghouse following its review of relevant information generated by NRC's contractor (Sandia National Laboratory) and oniv very recently made available to Westinghouse. In addition, very recent diset.mr.n between Sandia and l Westinghouse is expected to lead to some refiu ment of the Sandia input to the l NRC. There is a good basis for anticipating that chese continuing interactions  !

willlead to a conclusion that the AP600 passive safety-related features for fission )

product removal are clearly adequate to meet the stringent regulatory requirements.

The USC is also concerned with the following staff recommendation on " Post-72 Hour Actions"-

"Therefore, staff recommends that the Commission approve the position that the site be capable of sustainine all desien basis events with onsite equipment and supplies for the lone-term. After 7 days, replenishme consumables such as diesel fuel oil from offsite suppliers can be credited."

As detailed in the Westinghouse response (reference 1), the AP600 design approach involves a very remote need for a few piec long-term safe shutdown. As documented in the Utility Requirements Document (reference 4), the USC chose to require dependence on off-site resources for this limited case. Such dependence would require maintaining detailed plans for readily and reliably obtaining the specific equipment from array of off-site commercial stocks. (This commitment is included as license information item in the AP600 SSAR.) The USC required off-site over on-site resources to assure an in-depth supply of reliable equipment over an '

extended period of time.

The USC is also concerned that the staff's recommendation on Actions" would reverse NRC's prior acceptance of the relevant clauses of t i ALWR Utility Requirements Document, with which the AP600 complies.

clauses were the result of a thorough assessment by the industry, as to the term reliability of the various options. NRC expressed its acceptance (of  !

of off-site equipment)in its Safety Evaluation Report on the Utility Requirements Document. A withdrawal of NRC's prior acceptance inconsistent with the reference 1 characterization of the extremely low probability (less than one in a billion per year) that the relevant AP would not prove entirely adequate.

,The Honorable Shirley Ann Jackson August 27,1996

- Page 3 The USC respectfully requests your consideration of its concerns on Wese l matters.

Sincerely O

R. Patrick McDona d, Chairman ALWR Utility Steering Committee l

References

1. Brian A. McIntyre, W_, to John Hoyle, NRC, WESTINGHOUSE COMMENTS ON POLICY AND KEY TECHNICAL ISSUES PERTAINING TO THE WESTINGHOUSE AP600 STANDARD P REACTOR DESIGN (SECY-96-128), DCP/NRC0583, Docket No: STN 003, August 201996

2. James M. Taylor, NRC, to the NRC Commissioners, POLICY AND KEY TECHNICAL ISSUES PERTAINING TO THE WESTINGHOUSE STANDARDIZED PASSIVE REACTOR DESIGN, SECY-96-128, June 12 1996

3. Brian A. McIntyre, W_, to T. R. Quay, NRC, POSITION PAPER ON THE REMOVAL OF AEROSOLS FROM THE AP600 CONTAINMENT ATMOSPHERE FOLLOWING A POSTULATED LOCA WITH CO MELT USING ONLY NATURAL REMOVAL PROCESSES OF SEDIMENTATION AND DEPOSITION, NSD-NRC-96-4787, DCP/NRC0568, Docket No: STN-52-003, August 51996

4. EPRI, Advanced Light Water Reactor, Utility Requirements Document

c. Kenneth Rogers, Commissioner, NRC Greta Dicus, Commissioner, NRC James M. Taylor, Executive Director for Operations, NRC Sterling Franks, Director, Light Water Reactors, DOE

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Robert M. Vijuk, Project Manager, AP600 Design Certification, Westing