ML20213A602
| ML20213A602 | |
| Person / Time | |
|---|---|
| Issue date: | 11/12/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2467, NUDOCS 8702030385 | |
| Download: ML20213A602 (18) | |
Text
OdRS-M47 CERTIFIED MINUTES DATE ISSUED: November 12, 1986
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SUMMARY
/ MINUTES OF THE ACRS SUBCOMMITTEE ON STANDARDIZED NUCLEAR FACILITIES OCTOBER 8, 1986 WASHINGTON, D. C.
The ACRS Subcommittee on Standardized Nuclear Facilities met on October 8,1986 at 1717 H St. N.W., Washington, D. C. 20555 in Room 1046.
The purpose of the meeting was to discuss and review the Draft NUREG-1225 " Implementation of the NRC Policy on Nuclear Power Plant Standardization."
Notice of the meeting 'was published in the Federal Register on September 10, 1986.
The Federal Register notice is in Attachment A.
The schedule for the meeting is in Attachment B.
Sign in sheets of meeting attendees is in Attachment C.
Attachment D contains a list of handouts for this meet-ing. The handouts are filed with the office copy. The entire meeting i
was open to the public. There were no oral or written coments from l
members of the public. Mr. Herman Alderman was the cognizant ACRS Staff Engineer for the meeting.
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8702030385 861112 i
Attendees:
ACRS-2467 PDR l
ACRS NRC Staff l
C. Wylie, Subcommittee Chairman D. Scaletti farbon,-(qarttime)
H. Berkow i b, DESIGNATED ORIGINAL Yb>bY
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C. Michelson T. King J. Ebersole R. Hernan Introductory Statement - Subcommittee Chairman C. Wylie The meeting was called to order at 8:30 a.m.
Mr. Wylie noted the purpose of the meeting was to discuss NUREG-1225 " Implementation of NRC Policy on Nuclear Power Plant Standardization." Mr. Wylie referred to the Committee letter on standardization dated August 12, 1986.
Mr. Wylie referred to specific paragraphs in the standardization letter of August 12. He noted that paragraph 5 of the letter called attention to the necessity for clearly defining with respect to scope and detail the definition of " essentially complete plant design."
Paragraph 6 specified that the NUREG should define the manner in which the requirements for the Commission's policy should be incorporated in the future design, including the future goals, severe accident and advanced reactors and so forth.
Paragraph 8, with regard to design certification by rulemaking, the ACRS recommended that the Coninission should seek public coment in whatever option was used in rulemaking for design certification.
And, then, secondly that the criteria for thresholds for standing and interest for participation in the hearings on rulemaking should be made clear.
Paragraph 9 repeated the necessity for defining " Essentially Complete Design" that it be thoroughly and clearly identified as to complete scope and level of detail of information required for design
y --
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certification.
It also stated that it is important that the scope and level of detail be equally identified for each of the other options specified.
Mr. Wylie than called upon Mr. Dino Scalletti for the presentation.
Dino Scalletti - Standardization and Special Projects Mr. Ebersole noted that he objected to the policy that NRC should not review any product in which NRC took part in the evaluation. He ad-vocated the FAA approach of participating in the evaluation.
Mr. Wylie suggested that this is something that should be discussed in the future, particularly when Chapter 1 of the EPRI requirements docu-ments are reviewed.
Mr. Michelson asked how the Staff defines advanced reactors as opposed to light water reactors.
Mr. Scaletti replied that advanced means something new and different in our technology, a revolutionary step forward rather than an evolutionary change in the existing LWR.
Mr. Scaletti briefly stated background changes in standardization:
o A multitude of plant approvals both preliminary and final
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o Approvals of duplicate plants, replicate plants o
The severe accident policy statement necessitated a change in the 1978 policy statement o
The draft nuclear power plant licensing and stan-dardization act would authorize one step licensing o
The Staff was asked to poll industry groups such as NUMARC, EEI, and EPRI regarding the proposed policy on standardization o
In April 1986 the Staff was asked by the Commission to review the proposed policy statement on standardization o
In May 1986 the Staff responded with their revised policy statement on standardization i
o In August 1986 the Staff received the ACRS comments on standardization l
0 In September of 1986, the proposed NUREG on stan-dardization was sent to EDO.
CRGR has reviewed the NUREG and the Staff is waiting for the CRGR comments.
Mr. Scaletti remarked that the goals of the proposed standardization policy statement, are directed towards the ultimate licensing goal of
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FACILITIES, OCTOBER 8, 1986 MTG, having a certified design utilized on a pre-approved site.
It asks for essentially complete plants, and would strongly encourage that every-thing except site-related items be provided for certification.
It would ask for the level of detail which would be consistent with an operating reactor review that is currently done.
In the Reference System Design Certification, it would encourage certi-fication of all reference designs.
Mr. Michelson questioned the level of detail meant by " essentially complete" and "FSAR level of detail". He asked if the level is the documentation normally available to the reviewers at the stage when he calls upon the utility to supply it.
Mr. Scaletti concurred that it would be the leveh available to the reviewer when he calls upon the utility to supply it.
The subcommittee discussed the concept of certification of major portions of a design. Mr. Michelson asked for the case when an FDA was issued for a major portion of a design, could a part of the major portion, a RHR System, for example, be extracted claim that this system has been reviewed previously.
Mr. Beckow noted that the staff in that case would have the right to re-review that system.
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Mr. Wylie asked when you talk about a major portion of a system, where are the interface requirements? Listed?
Mr. Scaletti replied that they are spelled out in the Standard Review Plan and in Reg. Guide 170. They are not spelled out in the NUREG.
Mr. Michelson questioned the level of detail required. He quoted from the NUREG:
"An application for an FDA must include to the extent practicable a level of design detail equivalent to that required by 10 CFR 50.34(b) for a final Safety Analysis Report". He noted that all this is provided in terms of a document but not in terms of information.
Mr. Berkow pointed out that as the staff is conducting its review, any additional information that is needed in order to make the conclusions that they need will be requested and obtained.
Mr. Michelson then pointed out that during the rule making, if the staff requests additional information, the applicant could say that that wasn't included in the rulemaking.
Mr. Berkow responded that in a custom plant NRC tells industry all they need to submit in an FSAR, and yet, the staff goes through rounds of questions and other dialogues during the review.
Mr. Wylie suggested a statement in the NUREG to the effect that the supporting documentation and design information should be that which i
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would support any final design for review by the NRC for the final plant approval.
Mr. Wylie asked how the open items on a design certification are han-died? He asked how do you close them out?
Mr. Hernan replied that it wasn't specified anywhere in the way open items are handled for plants of operating reactors that are being licensed now.
Mr. Scaletti next discussed changes to approved and certified design He noted that the Commission realized that one of the benefits of standardization would require limiting the amount of changes to design, both by the NRC and by the applicant for a design approval.
Before any changes, a finding would have to be made that there would be a substantial increase in the overall protection of the public health and safety.
Mr. Scaletti pointed out that if the staff wanted to make any changes they would fall under the "backfit" rule, and would require a cost benefit analysis.
Industry could make changes by providing an application to make an amendment to the final design approval.
However, industry can request a change to forward fit.
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Mr. Michelson asked about~ designer induced changes to which the staff had added additional requirements. He asked if the licensee could then invoke the "backfit" rule.
Mr. Berkow replied it would probably involve rulemaking.
Mr. Scaletti noted that the certification process would define which changes would require a rule change to change & design.
Mr. Scaletti next discussed license fees He noted that 10 CFR Part 170 sets the maximum limit that a vendor would have to pay for a review at 1.4 million dollars for a final design approval. The 1.4 million dollars would be paid at six month intervals.
The billing would be actual expenses, whatever the staff review costs were, up to 1.4 million dollars.
The Standardization Act of 1985 would allow the Staff to collect the review costs, or defer the costs from the vendor, and to charge the users of these designs. The details have not been worked out. The Act has not been enacted yet.
He noted that the Commission, in the Standardization Act, see it as an incentive to standardization not to charge the vendors for the review process.
Mr. Scaletti then discussed Related Policies Regulations
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FACILITIES, OCTOBER 8, 1986 MTG, During the development of ~the NUREG, the Staff was asked to consider all of the related policies and regulations, those that were approved as Ccamission policies or regulations, or those that were in the process of being approved.
The staff addressed the severe accident policy statement, the standard review plan rule, the safety goal policies statement, the Stan-dardization Act of 1985, the source term policy, the advanced reactor policy statement, and early site approvals.
With regard to the Severe Accident Policy Statement, four licensing requirements for future plants are listed.
The Standard Review Plan Rule requires that any application, to document deviation from the Standard Review Plan, which is in effect six months prior to its application, to the NRC for the type of license or approval that it wants.
The Commission has stated in its safety goals what it expects safety goals to be.
It has also indicated that the Staff is developing crite-ria to implement the safety goals.
l Mr. Scaletti pointed out that the NUREG indicates that any future application would have to conform to the criteria that are being devel-oped.
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The draft Standardization-Act allows one step licensing.
It sets approval times for certified designs for 10 years.
It encourages pre-approved sites.
The Source Term Policy recognizes that this policy is being developed and that source terms might change. Accident source terms may change to reflect guidance from the Staff when the Source Term Policy is devel-oped.
Under the Advanced Reactor Policy, Mr. Scaletti noted that the Staff foresees the Standardization NUREG to be applicable to advanced reactors.
It is anticipated that the advanced reactors would have to do more if they wanted to be considered a standard design.
For example, a prototype would be expected for an advanced design.
Mr. Scaletti discussed the renewal process The proposed legislation allows for renewals of design certification up to a period of 10 years.
Final design approval can be approved for up to five years.
The preliminary design approval can be renewed for good cause. Good cause may be that you could show that you had a pending application that was going to reference your design.
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For the other standardization options, replication, duplication and the manufacturing license, there are no renewal processes. The construction permit and operating license could be extended.
The Subcommittee discussed what type of PRA would be required. An ordinary PRA or a severe accident PRA? The Staff responded that there was only one type of PRA and it was all encompassing.
Mr. Michelson asked about the technical resolution of the USI's.
Mr. Scaletti responded that if there is a generic resolution prior to certification during the review process then it would be expected that the design would meet the generic resolution.
If there wasn't a generic resolution, then it would still have to be resolved.
Mr. Scaletti remarked that this concluded this presentation.
Mr. Wylie asked if the subcommittee had any more comments or questions.
There wasn't any response.
Mr. Wylie asked about participation and public hearings, his question was, would there be a revision to the regulations for participation in public hearings?
Mr. Scaletti responded that for a construction permit, there is a mandatory hearing.
For an operating license, there is a mandatory
MINUTES / STANDARDIZED NUCLEAR 12 FACILITIES, OCTOBER 8,1986 MTG.
notice of hearing, although they do not have to hold a hearing.
For a full operating license, a hearing would not have to be noticed.
Mr. Berkow added the thresholds for intervention at various stages would be tightened.
The Subcommittee had a brief caucus and decided to write a draft letter outlining their concerns and present this letter to the full Committee.
The meeting was adjourned at 12:02 p.m.
NOTE:
A transcript of the meeting is available in the NRC Public Document Room, 1717 H Street, N.W., Washington, D.C. or can be purchased from ACE-Federal Re20001 (202) porters, 444 N. Capitol 347-3700.
Washington, D. C.
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t REVISION 1 October 6, 1986 TENTATIVE SCHEDULE ACRS STANDARDIZED NUCLEAR FACILITIES SUBCOMMITTEE MEETING OCTOBER 8, 1986 8:30 a.m., Room 1046, 1717 H St. NW.,
Washington, D.C.
8:30 a.m.
Introductory Statement, Subconnittee Chairman 8:40 a.m.
NRC Presentation, Introductory Connents 9:00 a.m.
Standardization Concepts Design Certification Concept Reference System Concept Duplicate Plant Concept Replicate Plant Concept Manufacturing License Concept 9:20 a.m.
Completeness of Scope and Design Reference System Concept Preliminary Design Approval Final Design Approval Design Certification Concept Duplicate Plant Concept Replicate Plant Concept Manufacturing License Concept 10:30 a.m.
BREAK 10:45 a.m.
10:45 a.m.
Changes to Approved and Certified Designs NRC Changes Holder Changes 11:00 a.m.
Related Policies and Regulations Severe Accident Policy Standard Review Plan Rule Safety Goal Policy Regulatory Reform Source Term Policy I
Advanced Reactor Policy Early Site Approval 12:00 - 1:00 p.m.
LUNCH
[
Standardiz:d Nuclear Facilities 2
i Subcommittee Mtg. October 8, 1986 1:00 p.m.
Rulemaking Rulemaking Options Notice and Written Comments Notice and Comment with Opportunity To request Legislative Hearing On the Records Proceedings 1:30 p.m.
Renewals of A) proval Certified )esign Approvals Final Design Approvals P,reliminary Design Approvals 2:00 p.m.
Policy Statement'on Nuclear Power Plant Standardization 2:30p.m2' Subcommittee Discussion
[ Note that 30 Minutes bas been alloted for a Subcommittee report at the 318th meeting.
(5:00 -
5:30 p.m. on Friday, October 10,1986)].
3:00 p.m.
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Presentation by D. Scaletti
" Draft NUREG 1225, Implementation of NRC Policy on Nuclear Power Plant Standardization
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