ML20214K080
| ML20214K080 | |
| Person / Time | |
|---|---|
| Issue date: | 08/12/1986 |
| From: | Ward D Advisory Committee on Reactor Safeguards |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1211, NUDOCS 8608180042 | |
| Download: ML20214K080 (4) | |
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WASHINGTON, D. C. 20555 August 12, 1986 Honorable Lando W. Zech, Jr.
Chaiman U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Zech:
SUBJECT:
ACRS COMMENTS ON PROPOSED NRC STANDARDIZATION POLICY STATEMENT During its 316th meeting, August 7-9, 1986, the Advisory Committee on Reactor Safeguards reviewed the Comission draft of April 10, 1986 and the NRC Staff response of May 14, 1986 on the Proposed Standardization requested by Chairman Palladino's memorandum of Policy Statement as June 18, 1986.
In this review, we had the benefit of briefings by the NRC Staff during the 315th ACRS meeting, July 10-12, 1986, as well as during the meetings of our Subcommittee on Improved Light-Water Reactor Designs on March 12, 1986 and August 5, 1986.
We agree that standardization of nuclear power plant designs is desir-able and may lead to enhanced safety if properly implemented in accor-dance with other Comission policies, particularly those on safety goals and severe accidents.
For this reason, we believe that the plans and directions for implementation that will be provided in a forthcoming Staff report (NUREG) are crucial. We expect to review this report when it becomes available.
As the result of our review, we offer the following detailed coments and recommendations:
1.
We recommend that the title of this policy statement be changed to
" Policy Statement on Certification for Nuclear Power Plant Standard Designs."
We believe that the policy statement should focus on standardization of the design of nuclear power plants.
We do not recomend including in the policy statement a coment on standard-ization of procurement, construction, installation and quality assurance practices, training and emergency operating procedures, or maintenance procedures.
To require standardization of these items would be overly prescriptive, although certain elements of these practices and procedures will become standard as a beneficial result of the standardization of design.
2.
It is our opinion that the first sentence of the Comission's draft policy statement dated April 10, 1986 best represents the Com-minion's policy on certification of nuclear power plant standard designs.
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'd Honorable Lando W. Zech, Jr. August 12, 1986 3.
We do not recomend including a comment in the policy statement "that standardized nuclear power plants should be used to satisfy the ultimate licensing goal of certified designs constructed on preapproved sites." This is an overly restrictive statement of the purpose for standardized nuclear power plants.
4.
We believe the policy statement should make clear that this state-ment supersedes the Comission's previous policy on standardization issued in 1978. This is necessary because the 1978 policy contains obsolete provisions and does not reflect present Comission regu-lations and policies.
5.
Considering the above coments, we submit for your consideration the following revision of the heading and the first two paragraphs of a proposed policy statement:
POLICY STATEMENT ON CERTIFICATION FOR NUCLEAR POWER PLANT STANDARD DESIGNS The Nuclear Regulatory Comission believes that standardiza-tion of nuclear power plant designs is a very important initiative that has the potential for significantly enhancing the safety, reliability, and availability of nuclear plants.
The focus of this policy is the reference system design certification.
The goal of standardization should be an essentially complete plant design with respect to both scope and level of detail, which then can be referenced in indi-vidual license applications.
This policy statement supersedes the Comission's previous I
" Statement on Standardization of Nuclear Power Plants,"
published August 31, 1978.
Details of the issues and topics that are important to the execution of this policy and other short-term licensing transition options are discussed in NUREG-XXXX, including the definition of scope and detail of an essentially complete plant design required for certifica-tion.
Applications not referencing a certified design will be processed in accordance with existing Comission regu-lations and policies, as discussed in NUREG-XXXX.
l 6.
We recomend including in the policy statement a reference to Comission policies on safety goals, severe accidents, and advanced reactors, as well as reference to other Comission policies pertinent to future nuclear plant designs and the manner in which the requirements of these policies in future designs should be defined in the accompanying NUREG.
7.
Former Chaiman Palladino's coments regarding the need for empiri-cal infomation on safety features that differ from those in 1
d Honorable Lando W. Zech, Jr. August 12, 1986 existing plants and for prototypical tests of " entirely new de-signs" raise questions of considerable interest and importance. We are not prepared to comment on these matters at this time, but expect to consider them further and to discuss them with the NRC Staff during our consideration of the anticipated Staff NUREG.
8.
It is our understanding that design certification rulemaking options will be discussed in the proposed companion NUREG.
It is not clear whether that NUREG will be published for comment; there-fore, it is not clear if or at what time the public will have an opportunity to provide comment on these options.
We believe that the Commission would benefit from and should seek public coment on design certification rulemaking options.
If informed comment is to be obtained, we think that the criteria and thresholds for standing and interest for participation in the legislative or adjudicatcry rulemaking hearings should be made clear.
9.
The proposed outline of the NUREG appears satisfactory.
- However, it is important that the definition of " essentially complete" design be thoroughly and clearly identified as to the complete scope and level of detail of information required for design certifications.
It is also important that the scope and level of detail be equally identified for each of the other options.
With the above comments and recommendations taken into account, we believe that the policy statement should be issued for public coment.
Additional comments by ACRS Member David Okrent are presented below.
Sincerely, 4
.\\
David A. Ward Chairman Additional Comments by ACRS Member David Okrent I wish to indicate first that I am a strong supporter of standardiza-tion.
In fact, I would take such steps as are legal to limit severely the number of certified standard reference designs to be approved by the l
NRC.
Second, I wish to support fonner NRC Chairman Palladino in his position that standardization should ideally encompass essentially complete design of the entire plant and that empirical infonnation or proto-typical testing of new features is important for certified reference plants.
e Honorable Lando W. Zech, Jr. '
Third, I believe that future U.S. plants should be considerably improved in safety over current U.S. plants and that this should not be left to the whims of the designer or the vagaries of PRA.
I believe that the '
Commissioners should explicitly state that they will seek a higher level of safety and that specific safety features and performance goals are to be included in the design of certified standard reference plants. These safety features and goals would best be specified prior to adoption of a new standardization policy statement.
References:
1.
Memorandum dated April 10, 1986 from Samuel J. Chilk, Secretary, to Victor Stello, Jr., Executive Director for Operations,
Subject:
Standardization Policy Statement 2.
Memorandum dated May I4,1986 from Victor Stello, Jr., Executive Director for Operations, to Commissioners,
Subject:
Standardiza-tion Policy Statement
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