ML20153D254
| ML20153D254 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| NUDOCS 8809020130 | |
| Download: ML20153D254 (5) | |
Text
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AUG 2 61988 o NEMORANDUM FOR: Eric S. Beckjord, Director Office of Nuclear Regulatory Research FROM: Thomas E. Murley, Ofrector Office of Nuclear Reactor Regulation
SUBJECT:
00MMENTS ON SEVERE ACCIDENT POLICY IMPLEMENTATION FOR FUTURE DESIGNS The staff has reviewed the proposed Comission paper and finds it generally acceptable to NRR and, therefore, concurs. We do, however, offer the following coments for your consideration when developing your final version of the paper: 1. On page one of the transmittal memorandum, your coment that use of Part 52 would propagate problems like those currently existing on the Mark I containments seems to be somewhat strong. Although Part 52 was not meant to stand alone, it dees have the weight of Comission Policies on severe accidents, standardization, and safety goals as h well as licensing review bases between vendors and NRR to assure a thorough review and a safe design. 2. On page two of the paper, your statement in support of developing new regulations, that Part 52 does not cover "all possible future olant a)plications," should be verified with OGC. It is our understanding t1at Part 52 covers the current generation of ALWRs, the near term passive ALWRs, future concepts such as the DOE-sponsored advanced designs and custom plant applications; whereas, this proposal addresses only the current generation of ALWRs. C. On page two under Discussion - The Severe Accident Policy Statement direction referred to was for operating reactors that had not been evaluated for severe accidents. That direction was not for future plant re';iews. The guidance for future plants centered on the t form, purpose and role of the PRA in severe accident reviews. l 4. Page 3, first paragraph - It should be noted that only combustion Engineerirg's System 80+ is involved in the ARSAP program. n
- 5., items (1)&(2)shouldbewrittentobeconsistentwith gj the Comission's Severe Acddent Policy Statement.
For example, the F policy requires "... technical resolution of all applicable Unresolved Safety Issues and the medium-and high-priority Generic Safety Issues"* O merely addressing adequately would not be sufficient. Furtherrnore, (: h,) i 10 CFR 50.34(f) is n need of major revisions. The plans to make it consistent with current practices should be stated in this paper. Y I
Contact:
D. Scaletti, DRSP M( x21104 i 8809020130 000026 PDR OHG NRRDPNU
F AUG 2 61993 Eric Beckjord *
- 6. Item (3) seems to be an integral part of the required input necessary to do a PRA for a plant design and therefore should be included under Item (1). In Item (3)(b), it should be made clear that design inprovements should be an integral part of the PRA process and not an after-the-fact analysis.
7. Enclosures 2 & 3 - The need for two regulations in dealing with severe accidents is questionable. Both the procedural and the performance requirements could be combined in one rule which would make it easier to understand and to enforce. 8. Finally, the schedule for the severe accident requirements does not seem compatible with the ALWRs presently under staff review. It is questionable that a final rule can be promulgated in time to support rulemaking for design certification of the ALWRs in mid 1990. Ae Thomas E. Hurley, Director Office of Nuclear Reactor Regulation
A UO 2 0 1988 Eric Beckjord *
- 6., Item (3) seems to be an integral part of the required input necessary to do a PRA for a plant design and therefore should be included under Item (1). In Item (3)(b), it should be made clear that design improvements should be an integral part of the PRA process and not an after-the-fact analysis.
7. Enclosures 2 & 3 - The need for two regulations in dealing with severe accidents is questionable. Both the procedural and the performance requirements could be combined in one rule which would make it easier to understand and to enforce. 8. Finally, the schedule for the severe accident requirements does not seem compatible with the ALWRs presently under staff review. It is questionable that a final rule can be promulgated in time to support rulemaking for design certification of the ALWRs in mid 1990. Original signed by I Thoma:) E. Y.urlcY Thomas E. Murley, Director i Office of Nuclear Reactor Regulation DISTRIBUTION / Central _Ftle~ i NRC & Local TDRs i PDSNP Reading D. Crutchfield D. Scaletti J. Sniezek L. Rubenstein i F. Miraglia i T. Hurley
- See previous concurrence sheet
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Eric Beckford -
- 6., Item (3) seems to be an integral part of the required input necessary to do a PRA for a plant design and therefore should be included under Item (1). In Item (3)(b), it should be made clear that design improvements should be an integral part of the PRA process and not an after-the-fact analysis.
7. Enclosures 2 & 3 - The need for two regulations in dealing with severe accidents is questionable. Both the procedural and the performance requirements could be combirje'd in one rule which would make it easier to understand and to e orce. 8. Finally, the schedule fer the sever accident requirements does not seem compatible with the ALWRs pr ently under staff review. It is questionable that a final rule n be promulgated in time to support rule making for design certifi tion of the ALWRs in mid 1990. homas Murley, Director Office of Nuclear Reactor Regulation DISTRIBUTION Central File NRC & Local PDRs PD4 r/f DCrutchfield GHolahan DScaletti J.Sniezek
- See previous con trence sheet
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DScaletti CM111er LRubinstein DCf0"tchfield F a 08/19/88 08/19/88 08/19/88 08/2.f88 08/jp8 D/NRR Hurley 08/ /88 i
Eric Beckjord *
- 6., Item (3) seems to be an integral part of the required input necessary to do a PRA for a plant design and therefore should be included under Item (1). In Item (3)(b), it should be made clear that design improvements should be an integral part of the PRA process and not an after-the-fact analysis.
7. Enclosures 2 & 3 - The need for two regulations in dealing with severe accidents is questionable. f Both the irocedural and the perforrance requirements could be combine in one rule which would make it easier to understand and to enf ce. 8. Finally, the schedule for the severe ccident requirements does not seem compatible with the ALWRs pres tly under staff review. It is questionable that a final rule ca e promulgated in time to support rule making for design certifica on of the ALWRs in mid 1990. Th as Murley, Director 0 fice of Nuclear Reactor Regulation DISTRIBUTION Central File NRC & Local PDRs PD4 r/f DCrutchfield GHolahan DScaletti J.Sniezek LRubenstein TMurley PDSNPV)A PDSNP @ NRR/DRSP AD/DRSP 4 DScaletti -{v CM111er DCrutchfield FMiraglia 08/lg/88 08/n/88 08/ /88 08/ /88 4 D/NRR AD 4 Murley LRdbdnstein 08/ /88 08/17/88 i I - - -. _}}