ML20198E351
| ML20198E351 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1992 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Rasin W NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| Shared Package | |
| ML20198E355 | List: |
| References | |
| NUDOCS 9212070042 | |
| Download: ML20198E351 (4) | |
Text
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UNITED STATE 8
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November 25, 1992 ;
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Mr. William H. Rasin Vice President and Director Technical Division Nuclear Management and Resources Council 1776 Eye Street, N.W., Suite 300 Washington, D.C. 20006-2496 .
Dear Mr. Rasint ,
I am responding to your letter of August 26, 1992, in which you provided your r comments regarding SECY-92-196, " Development of-Design Acceptance Criteria for the Adv5nced Boiling Water Reactor (ABWR)," and SECY-92-214. " Development of for Design Inspections, Tests, Certifications." I amAnalyses, and Acceptance also responding to your lettersCriteria of Octo(ITAAC) ber 5, Novem-ber 5, and November 17, 1992, in which you provided additional comments on generic and programmatic ITAAC. We appreciate the Nuclear Management and Resources Council's (NUMARC's) interest in the implementation of 10 CFR-Part 52, and we commend your efforts in organizing an industry review of the ABWR ITAAC. The staff will continue to work with NUMARC and to use the ABWR s as the lead plant for the development of ITAAC.
1' U The staff was pleased to participate in portions of the NUMARC-sponsored industry review of the ABWR ITAAC and to have met with you on several occa-sions in the last few months to discuss issues related to that review. The staff expects that the lessons learned from its review of the ABWR ITAAC will i provide valuable guidance to the other reactor designers applying _for design
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certification. The following discussion-responds to-some of,your comments on ITAAC.
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i In your letter of August 26, 1992, you raised concerns regarding the use of ITAAC to verify procedural and-programmatic requirements, it is important to
- remember the fundamental requirement for ITAAC, as we continue ovr interac- ,
tions on its development. Specifically, ITAAC must be necessary and suffi-l cient to provide reasonable assurance that the_ facility has been constructed l
, and will se operated in conformity with the-license,- the provisions of the l l Atomic Energy Act, and the Commission's rules and regulations. Durirn !
meetings with you on November =10 and November 19, 1992, the-staff agreed to i
focus its near term efforts upon resolving the _ scope of ITAACs associated with-design certification. We discussed an approach to: quality assurance welding and equipment qualification which appears may resolve your concerns a,nd ensure j that design-certification ITAAC_ meet _the necessary and sufficient standard.
!. The approach for welding and equipment qualification involved incorporation of , i i e
requirements drawing and ITAAC by into the Tier 1 system a walkdown-inspection. design The details of andescription, acceptable the:
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Hr. William H. Rasin November 25, 1992 standard for welding and equipment qualification would be specified in the Tier 2 SSAR. This would include specific code addenda, edition and code cases for welding and non-proprietary description of equipment qualification testing and analysis methods. The functional system drawings would identify ASME boundaries for welding and environmental qualification boundaries. The system ITAAC walkdown inspection already incorpe ated into the system ITAAC would include verification of equipment qualification and welding. This approach would also ensure that the quality of the hardware was incorporated into the ITAAC rather than a generic process. The staff would review conformance to Tier 2 methods for welding and equipment qualification as part of its " sign as you go" inspection activities. The staff will review options and will continue to work with you to identify optimum approaches for other generic requirements.
As stated in SECY-92-287, " Form and Content for a Design Certification Rule,"
the staff believes that various cross references, or "roadmaps," between the standard safety analysis report (SSAR) and the Tier 1 material are more than simply an aid for the review and implementation of the design. These cross references identify analyses that relate to fundamental aspects of the design, including analyses for design-basis and severe accidents, and insights into the design from probabilistic risk analyses. They show where the key analyses have been incorporated into the Tier ' material, thus providing the means to ensure preservation of these insights in a facility that references the design. The staff believes that the cross references should be submitted for staff review as part of the SSAR and should be retained in the design control i
document to aid combined license (COL) applicants and licensees in the change process.
- The staff's position on cross references is consistent with the staff require-t ments memorandum on SECY-90-377, " Requirements for Design Certification Under
! 10 CFR Part 52 " in which the Commission directed the staff to ensure that i the "50.59-like" process considered preservation of various insights that l are part of the staff's review. The cross references provide a clear roadmap to a COL applicant or licensee, showing what design features and supporting analyses in the SSAR must be considered before making any changes to a l
, facility, thus ensuring preservation of these insights.
You also restated your reasons for separating the review of ITAAC from the final design approval (FDA) for certification of a standard design. Part 52 clearly requires ITAAC to support a certification FDA. During the review of the ABWR, it has become apparent to the staff that the review of the Tier 1 material cannot be separated from the review of the SSAf< ano the technical.
specifications because the development of the Tier 1 material has generated changes to the SSAR material. Also, the acceptance criteria in ITAAC must be consistent with the supporting analyses in the SSAR and the basis for the staff's approval of the design in the final safety evaluation report (FSER).-
For the ABWR, the staff does not have a final, quality assurance-certified
- version of either the Tier 1 material, the SSAR, or the technical specifica-l tions. In addition, the draft FSER for the ABWR contains approximately
Mr. William H. Rasin November 25, 1992 400 open items, about half of which are related to the ITAAC. Therefore, the staff feels that it cannot make its safety determination for a certification FDA without review and approval of ITAAC. While progress on the development of ITAAC has been iterative, it is important to take the time necessary to do the lead review correctly, since the ABWR ITAAC will set the precedent for succeeding applications.
Your letter of August 26, 1992, also referred to a Part 50 inspection process.
The NRC's inspection program verifies compliance with applicable regulations, not just Part 50. For plants licensed under Part 52, the NRC's inspection program will verify compliance with ITAAC. The staff will continue to consider the additional comments in your letters in its ongoing development of ITAAC and other Part 52 implementation issues.
Sincerely, Origbal Shned 9y.
Dennis M. Crutchfield, Associate Director for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation cc: See next page D1SJ_RJfR!1103:
Central File (w/inc.) PDST GT/F (w/inc.) JTaylor PDR (w/inc.) JSniezek JBlaha HThompson DCrutchfield TMurley/FHiraglia, 12G18 WTravers RPierson TBoyce JNWilson JMoore, 15B18 GGrant, EDO BToms PMagnanelli PShea EBeckjord,RES OPA OCA NRC Mailroom (EDO GT068047) (EDO YT0920229 and YT0920251))
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