ML20214P898

Summary of 860828 Meeting W/Ge,Doe & EPRI in San Jose,Ca Re NRC Review & Certification Processes for GE Advanced Bwr. List of Attendees,Meeting Slides & Related Info Encl

ML20214P898
Person / Time
Site:	05000447
Issue date:	09/17/1986
From:	Caruso R Office of Nuclear Reactor Regulation
To:	Bernero R Office of Nuclear Reactor Regulation
References
NUDOCS 8609240093
Download: ML20214P898 (55)

Text

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4 MEMORANDUM FOR: Robert M. Bernero, Director Division of BWR Licensing THRU: Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing FROM: Ralph Caruso, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

SUMMARY

OF AUGUST 26, 1986 MEETING WITH GENERAL ELECTRIC - ABWR On August 28, 1986, members of the staff met with representatives of General Electric (GE) to discuss several issues concerning the staff's review and certi-fication processes for the GE ABWR. The meeting was held in San Jose, CA, at GE's nuclear energy division offices. A list of the meeting attendees is provided as Enclosure 1.

The meeting was held, at the request of GE, to discuss issues which may be included in a Licensing Basis Agreement (LBA) between the NRC and GE. GE had raised the idea of preparing an LBA at an earlier meeting on June 25, 1986, and the August 28 meeting was intended to focus on certain key issues that had been troublesome during the GESSAR II review, and on other areas arising from the relationship between the ABWR and the EPRI ALWR program. In advance of the meeting, the participants discussed a number of agenda talking points, which are included in the package of meeting slides used by GE (Enclosure 2).

Mr. D. Wilkins began the meeting by announcing that GE, DOE, and EPRI had signed a contract on August 27 under which DOE would provide funds for the ABWR'certi-fication process. He discussed the attempts by DOE, the reactor vendors, EPRI, and the utilities to revitalize the nuclear option for the utilities through the standardization and certification of designs and sites, and described the history of the ABWR, from its creation by an international consortium of vendors and A-Es, to its current status as an American-Japanese cooperative effort. He further stated that GE is prepared to make whatever effort is necessary to certify the ABWR design.

This introduction was followed by a description of the GE-Japanese organization and relationship, and the status of the project in Japan, where Tokyo Electric Power Company is expected to begin construction of an ABWR before the end of the decade. The major portion of the meeting focused on the specific agenda items.

In response to a staff question, G. Sherwood of GE stated that the. need for a formal Licensing Basis Agreement had been discussed with senior NRC managers, and is an attempt to anticipate and avoid some of the problems experienced during the GESSAR 11 review. The staff agreed that an agreement might be useful for fy some issues, but reminded GE that the most serious setbacks for GESSAR arose hv

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because of a combination of certain institutional and timing considerations that could not be dealt with in a licensing basis agreement. The staff encouraged GE to meet with the ACRS early in the review cycle, and frequently thereafter, so as to keep everyone informed and to prevent unfortunate surprises late in the review process.

GE and the staff reached essential agreement on several of the agenda items, as discussed in Enclosure 3, and determined that further action by various parties is needed to resolve some other issues. Both GE and the staff members present agreed to follow up on the open items, with the idea of meeting again in October.

Origirst signed by Ralph Caruso, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

Enclosures:

As stated DISTRIBUTION

! Docket File NRC PDR LPDR PD#4 Rdg.

WButler RCaruso OGC EJordan BGrimes ACRS (10)

NRC Participants

• Previously concurred:

PD#4/PM PD#4/D

• RCaruso:lb *WButler 09/16/86 09/17/86

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2 because of a combination of certain institutional and timing considerations that could not be dealt with in a licensing basis agreement. The staff encouraged GE to meet with the ACRS early in the review cycle, and frequently thereafter, so as to keep everyone informed and to prevent unfortunate surprises. late in the review process.

GE and the staff reached essential agreement on several of the agenda items, as discussed in Enclosure 3, and determined that further action by various parties is needed to resolve some other issues. Both GE and the staff members present agreed to follow up on the open item , wit he idea of meeting again in October..  !

h g QAtJLW Ra h aruso, Project Manager BWR P oject Directorate No. 4 Division of BWR Licensing

Enclosures:

As stated i

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NRC/D0E/EPRI ABWR CERTIFICATION MTG

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AUGUST 28, 1986 NAME ORGANIZATION PHONE NO.

Dan Wilkins General Electric (408)925-6555 Joe Quirk General Electric (408) 925-6219 Can Noble EPRI (415)855-2071 Hil Patel General Electric (408)925-1222

John Embley General Electric (408) 925-3463 Ralph Caruso NRC (301)492-9475 R. Wayne Houston NRC (301) 492-4523 Rudy Villa General Electric 408)925-5722 David H. Moran NRC 301) 492-7422 Dan Giessing DOE 301) 353-5501 Glenn Sherwood General Electric (408) 925-5040 Jack Fox GE (408)738-6134 I

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E.scesu, e 2 o a ABWR CERTIFICATION MEETING AGENDA AUGUST 28, 1986 SAN JOSE, CALIFORNIA

1. WELCOME 8:30 AM

2. INTRODUCTION 8:35 AM

3. PURPOSE AND CONDUCT OF MEETING 8:45 AM

4. LICENSING BASIS AGREEMENT 9:00 AM PURPOSE SCHEDULE DOCUMENT TYPE

5. POTENTIAL LBA SUBJECTS 9:30 AM 8/6/86 NRC STAFF MEMO RECOMMENDED APPROACH

6. LUNCH 12:00 N00N

7. POTENTIAL LBA SUBJECTS (CONTINUED) 1:00 PM

8. FORMALIZATION OF LBA 3:30 PM

9. ADJOURN 4:30 PM 4

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- a INTRODUCTION ADVANCED LWR PROGRAMS o INTEGRATED GOVERNMENT / UTILITY / INDUSTRY EFFORTS TO REVITALIZE NUCLEAR OPTION UTILITIES /EPRI DEFINE REQUIREMENTS (EPRI REQUIREMENTS PROGRAM)

INDUSTRY SUPPLIES DESIGNS (U.S. VENDORS ADVANCED LWR DESIGNS)

GOVERNMENT SUPPLIES CERTIFICATION (DOE DESIGN VERIFICATION PROGRAM) o TRADITIONAL REGULATORY RISK REMOVED THROUGH PRE-CERTIFIED DESIGNS o GE ROLE: ABWR CERTIFICATION i

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l INTRODUCTION OBJECTIVES FOR ABWR CERTIFICATION  !

O PRE-CERTIFIED ABWR STANDARD DESIGN NO FURTHER REVIEW BY NRC OR ACRS NO CHALLENGE IN LICENSING HEARINGS SUBSEQUENT COMPLIANCE REVIEWS ONLY o MULTIPLE USE DIFFERENT UTILITIES DIFFERENT SITES 0:J0EU44: ET 8/27/86

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INTRODUCTION GE - ABWR ,

o DESIGNED BY INTERNATIONAL BWR DESIGN TEAM o COMBINES BEST WORLDWIDE BWR TECHNOLOGY o TARGETED FOR WORLD MARKETS IN THE 1990s 0 8 YEARS - $250M INVESTMENT o READY FOR LEAD PLANT APPLICATION Q:J0E044: ET 8/27/86

INTRODUCTION ABWR CERTIFICATION PROGRAM o DESIGN CERTIFICATION - OPPORTUNITY FOR U.S. LEADERSHIP o SIMILAR LICENSING SCHEDULE FOR ABWR IN JAPAN i

Q:J0E044: ET 8/27/86

PURPOSE AND CONDUCT AND MEETING o PURPOSE AGREEMENT ON PURPOSE OF LICENSING BASIS AGREEMENT AGREEMENT ON LBA DEVELOPMENT SCHEDULE AGREEMENT ON TYPE OF DOCUMENT o CONDUCT ESTABLISH ISSUES TO BE ADDRESSED IN LBA ESTABLISH ISSUES CURRENTLY IN AGREEMENT IDENTIFY RESPONSIBILITIES FOR RESOLVING FOLLOW-UP ISSUES 0:J0E044: ET 8/27/86

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LICENSING BASIS AGREEMENT o PURPOSE OF LBA DEFINE NRC REVIEW PROCESS AND ACCEPTANCE CRITERIA FOR ABWR DEFINE PROCESS FOR ABWR CERTIFICATION o SCHEDULE FORMALIZE LBA BEFORE TECHNICAL REVIEW 0F ABWR STARTS IN 9/87 o DOCUMENT TYPE NRC LICENSING PROJECT LETTER RULE MAKING d

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l ABWR CERTIFICATION PROGRAM KEY CERTIFICATION ISSUES SEVERE ACCIDENT ACCEPTANCE CRITERIA PRA ACCEPTANCE CRITERIA SABOTAGE ACCEPTANCE CRITERIA l ENVELOPE CONCEPT .

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INTERFACE CONCEPT l

ACRS ROLE & PARTICIPATION FORMALIZATION AND IMPLEMENTATION OF LBA 1

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i POTENTIAL LBA SUBJECTS A. PARTICIPANTS B. PROPRIETARY INFORMATION C. EPRI-ALWR PROGRAM D. FUTURE ISSUES E. SCHEDULING F. REVIEW PROCEDURES G. SITE-SPECIFIC ISSUES H. TECHNICAL ISSUES I. SEVERE ACCIDENT POLICY J. PRA K. ACRS L. ORGANIZATION M. LICENSING FEES N. DESIGN COMPLETENESS

0. CERTIFICATION PROCESS 0:J0E044: ET 8/27/86

8-6-8C NRC STAFF MEMd '

A. PARTICIPANTS

1. THE LBA SHOULD CLEARLY DESCRIBE THE PARTICIPANTS IN THE ABWR PROGRAM,

2. IT SHOULD IDENTIFY THE ENTITY WHICH WILL EVENTUALLY BE GRANTED THE FDA AND THE DESIGN CERTIFICATION.

3. THE ROLE OF DOE SHOULD BE DESCRIBED,

4. IF ISSUANCE OF THE FDA OR THE DESIGN CERTIFICATION WILL BE BASED ON CONSTRUCTION OF A LEAD PLANT BY A FOREIGN ENTITY, THE RELATIONSHIP 0F THE FOREIGN ENTITY TO THE DOMESTIC PARTICIPANTS, AND TO THE LICENSING PROCESS, SHOULD BE DESCRIBED.

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RECOMMENDED APPROACH A. PARTICIPANTS GROUP ROLE o GENERAL ELECTRIC COMPANY o FDA/ CERTIFICATION APPLICANT o DEPARTMENT OF ENERGY o FDA/ CERTIFICATION SPONSOR o ELECTRIC POWER RESEARCH INSTITUTE o INDUSTRY REQUIREMENTS o GE JAPANESE TECHNICAL ASSOCIATES o ABWR TECHNOLOGY PARTNERS

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8-6-86 NRC STAFF MEM0 -

B. PROPRIETARY INFORMATION 4

1. THE EXTENT TO WHICH THE DESIGN RELIES ON PROPRIETARY INFORMATION SHOULD BE DEFINED.

2. BECAUSE THE CERTIFICATION PROCESS WILL INVOLVE A PUBLIC RULEMAKING,

. THE TREATMENT OF PROPRIETARY INFORMATION DURING THE RULEMAKING SHOULD BE ADDRESSED.

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RECOMMENDED APPROACH B.

PROPRIETARY INFORMATION o SUBMITTAL OF PROPRIETARY INFORMATION DURING NRC REVIEW STRICT ADHERENCE TO SECTION 2.790 0F 10CFR PART 2 i

o TREATMENT OF PROPRIETARY INFORMATION DURING RULE MAKING MAINTAIN PROPRIETARY MATERIAL AS DEFINED DURING NRC REVIEW AND AS TREATED IN SER TREAT PROPRIETARY INFORMATION IN SAME MANNER AS ACRS PUBLIC MEETINGS l

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8-6-86 NRC STAFF MEM0 -'

i C.EPRI ADVANCED LIGHT WATER REACTORS (EPRI-ALWR) PROGRAM

1. THE RELATIONSHIP 0F THE ABWR TO THE EPRI-ALWR PROGRAM SHOULD BE DESCRIBED, INCLUDING:

A. TIMING 0F CORRESPONDING EPRI AND ABWR SUBMITTALS.

B. DEGREE OF COMPLIANCE OF THE ABWR WITH THE EPRI STANDARDS.

c. DOCUMENTATION OF AREAS OF NON-COMPLIANCE WITH EPRI " REQUIREMENTS," INCLUDING i

Tile ASSOCI ATED JUSTIFICATIONS.

D. DOCUMENTATION OF EPRI'S POSITION ON NON-COMPLIANCES BY ABWR.

i E. PROCEDURES TO BE USED TO REVISE THE ABWR DESIGN IF THE EPRI STANDARDS ARE REVISED

2. THE LBA SHOULD DISCUSS HOW DECISIONS ON " CASE-BY-CASE" ISSUES WILL BE MADE FOR THE ABWR,

3. THE LBA SHOULD DISCUSS HOW ABWR WILL ATTEMPT TO MEET EPRI " TARGET" STANDARDS, i 4. ABWR MUST STATE THE AREAS WHERE IT DISAGREES WITH EPRI.

5. ABWR SHOULD DEFINE ITS INTERPRETATION OF THE "N0 CORE DAMAGE" TERM USED BY EPRI.

6. THE ABWR SHOULD IDENTIFY ANY AREAS WHERE FUTURE UTILITY APPLICANTS WILL BE ABLE TO CUSTOM i THEIR PARTICULAR PLANT IN A DEPARTURE FROM THE " STANDARD" ABWR DESIGN.

7. IF AN EPRI REVIEW 0F THE ABWR IS PERFORMED PRIOR TO THE CHAPTERS BEING FILED FOR NRC REVIEW, SHOULD THE STAFF RECEIVE COPIES OF THE EPRI FINDINGS PRIOR TO COMPLETION OF THE STAFF REV OF EACH CHAPTER?

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RECOMMENDED APPROACH C. EPRI-ALWR PROGRAM o TIMING OF CORRESPONDING EPRI AND ABWR SUBMITTALS PER EXHIBIT A, ITEM 3 o RELATIONSHIP TO EPRI PROGRAM EPRI TARGET STANDARD (CDF <1X10-5) WILL BE MET BY ABWR THE EPRI REQUIREMENTS PROGRAM IS AIMED AT ACHIEVING COMPATIBILITY WITH ADVANCED DESIGN EFFORTS ABWR EXCEPTIONS TO EPRI REQUIREMENTS, WHEN NECESSARY, WILL BE HANDLED JOINTLY BY EPRI, ITS UTILITY SPONSORS AND GE (EXHIBIT A, ITEM 1) o ABWR UTILIZES MORE STRINGENT "N0 CORE UNC0VERY" IN PLACE OF EPRI "N0 CORE DAMAGE" o DEPARTURE FROM " STANDARD" ABWR DESIGN BY UTILITY APPLICANT WILL BE IMPRACTICAL BY VIRTUE OF PRE-CERTIFIED DESIGN o EPRI TO RECEIVE COPY OF SUBMITTALS 30 DAYS IN ADVANCE OF SUBMITTAL TO NRC; CONFIRM THAT DESIGN INFORMATION IS CONSISTENT WITH REQUIREMENTS (EXHIBIT A, ITEM 2) 0/ Y> Shk __ __ . __

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8-6-86 NRC STAFF MEMO. .

D. FUTURE ISSUES

1. THE LBA SHOULD DEFINE HOW NEW ISSUES (USIs. OR OTHER INITIATIVES FROM FUTURE OPERATING EXPERIENCE) WILL BE ADDRESSED, A. WILL THEY BE REQUIRED TO BE RESOLVED BEFORE ISSUANCE OF THE FDA, OR THE DESIGN CERTIFICATION, OR NEITHER?

4 B. WILL THEY BE REQUIRED TO BE ADDRESSED ONLY IF THEY ARE FOLDED INTO THE EPRI-ALWR PROGRAM?

C. HOW IS THE DETERMINATION TO BE MADE WHETHER TO INCLUDE THEM IN THE SCOPE OF WORK?

2. ALL NEW ISSUES SHOULD BE DISCUSSED IN STAFF SERs, NO MATTER HOW RESOLUTION IS ACHIEVED.

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3. THE LBA SHOULD INCLUDE A DISCUSSION OF THE RULES TO BE APPLIED FOR RE-0PENING ISSUES WHEN THEY HAVE BEEN REVIEWED AND ACCEPTED BY THE STAFF.

4. REGARDING BACKFITS, WILL THERE BE A CHAPTER-BY-CHAPTER SPECIFICATION OF DATES FOR BACKFIT CONSIDERATIONS?

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i RECOMMENDED APPROACH ,

D. FUTURE ISSUES  ;

i o A NEW ISSUE CUT 0FF DATE WILL BE ESTABLISHED IN THE LBA l

EFFECTIVE DATE OF SRP 6 MONTHS PRIOR TO DOCKETING i

USIs, GSIs ETC. PER SEVERE ACCIDENT POLICY BACKFIT RULE EPRI REQUIREMENTS RESOLUTION o NEW ISSUES SHALL BE DISCUSSED IN STAFF SERs IN CONTEXT OF ABOVE o ALL ISSUES UP TO DATE OF FDA WILL BE CLOSED FOR ABWR 1

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8-6-86 NRC STAFF MEMO l

i E. SCHEDULING

1. THE LBA SHOULD INCLUDE A SCHEDULE FOR SUBMITTAL OF THE FSAR BY GE.

2. IT SHOULD INCLUDE A SCHEDULE FOR REVIEW BY THE STAFF.

30 THE LBA SHOULD DEFINE THE QUESTION AND ANSWER PROCESS BETWEEN GE AND THE STAFF, ALONG WITH TIME LIMITS FOR RESPONSES.

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ABWR CERTIFICATION PROGRAM . . _

SCHEDULE 1986 1987 1988 1989 1990 1991 I l l l i l l f i l l l111111L111Ll Illil l l l l 11 l 1111111111 l l 11111111111 ! I 111111111 TASK 1:  !  !  !  !  !

EPRI heq. Doc Prep.

1. DOE /NRC Lic Basis Ag ree m e n t M , ,']!.,M  ! ,

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. C ABWR !SAR Revh.

TASK 2: l l M Staff hER issufed

2. Nuclear Island j i j i j

o. Reactor / Safety Systems @@@!@@@@ M Nf!Mi$l ..

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b. Bldg Arra n g e m e n ts j@0000000 47d!J8),%l l i

c. Aux. Support Sys and I&C l@0@@@@@@@ gi!!?f,M'dl l

d. PRA/FMEA and Technical l l 5M'if'Ml , l Specifications  !  !  !  !  !

3. Turbine Island l l ,6Mjl!

4. NRC lssue Resol./ Final SER l  !  ! MM'$il  !

5. ' ACRS Review l l l lMl

6. FDA issued  !.  !

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TASK 3: i j j i  !

Rulem a king /Pu blic H ea rin g l l l  ! . jim V

Certifica tion  !  !  !  !  !

SCH2

E. SCHEDULING SU B MITTALS SCHEDULE TOPIC 1987 1988 1989 1986 EPRI REQUIREMENTS ABWR CERTIFICATION Chapter 1 Lic. Basis Agreernent EPRI Requir'ements o Overall ALWR Requirements e Licensing Bos's e Review Schedule Q

o SSAR Details Pmp Review l ABWR Verification

• Requirements Staff SER issued Chapters 3, 4, 5 Chapters 4, 5, 6, 15 o Reactor /Sofety Systems e Fuel e Reactor

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• Safety Systems Prep Review E e Sofety Analysis Checklist Chapter 6 Chapters 1, 3 V/// M //g 1f e Plant Arrangement e Building Arrangements u Prep Review E o Building Design Checklist Chapters 7-12 Chapters 7-9, 11-14, 17

• El et ical Power Sys El et Icol Power Sys e Auxiliary Support Sys Review e Auxillory Support Sys e Rodwoste e Rodwoste. Radiation Prot.

Prep l

• Testing e Conduct of Operations e Quality Assurance Checklist Chapter 2 e Power Generation Chapters 10, 18, 18 e Steam & Power Conv. 77 gI 3 f Systems e Technical Specifications Prep l Review l e Human Factors Checkli Approach to CP/ML e PRA Rule 3y Severe Accidents (under development) e FMEAs Prep Review l e Severe Accident

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REC 0 MENDED APPROACH E. SCHEDULING (CONTINUED)

.l 0 QUESTION / ANSWER PROCESS ONE ROUND OF QUESTIONS DURING REVIEW PERIOD FOR EACH SUBMITTAL RELY ON TECHNICAL REVIEW EETINGS RESPONSES TARGETED FOR FILING 4 WEEKS PRIOR TO SER ISSUANCE l

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8-6-86 NRC STAFF MEMD .

F. REVIEW PROCEDURES

1. WILL THE STAFF USE THE STANDARD REVIEW PLAN FOR ITS REVIEW?

2. HOW MUCH WILL THE STAFF DEPEND ON GE'S STATEMENT THAT THE ABWR CONFORMS TO THE EPRI-ALWR REQUIREMENTS DOCUMENT?

3. IS THE STAFF ABWR REVIEW TO BE LIMITED TO THE SAME PACE AS THE EPRI-ALWR PROGRAM REVIEW?

4. WOULD THERE BE A BENEFIT TO HAVING THE SAME STAFF REVIEWERS WHO ARE DOING THE EPRI-ALWR REVIEW DO THE ABWR REVIEW?

5. SHOULD THE STAFF ISSUE A SER IN THE SAME FORMAT AS IT DOES FOR CUSTOMER PLANTS, OR IS A DIFFERENT FORMAT PREFERABLE?

6. CONFLICT BETWEEN EPRI-ALWR DOCUMENT STRUCTURE AND 10CFR 50.34(G) (1) (II) REQUIREMENTS FOR FSAR CONTENT AND ORGANIZATION. HOW TO RESOLVE?

7. SHOULD WE PRESCRIBE A SPECIFIC REVIEW ACTIVITY AND ALLOT A SPECIFIC PERIOD OF TIME FOR AN OVERVIEW 0F THE ENTIRE FSAR, ONCE ALL THE CHAPTERS HAVE BEEN FILED?

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O RECOMMENDED APPROACH F. REVIEW PROCEDURES o REVIEW BASED ON THE SRP o GE WILL IDENTIFY ALL ABWR EXCEPTIONS TO EPRI REQUIREMENTS o ABWR REVIEW SCHEDULE INTEGRATED WITH EPRI-ALWR REQUIREMENTS REVIEW SCHEDULE (EXHIBITLA, ITEM 3) o THERE WOULD BE NO DISADVANTAGE IN HAVING DIFFERENT STAFF REVIEWERS FOR BOTH REVIEWS SINCE DEGREE OF CONFORMANCE WILL BE RESOLVED o STAFF WILL ISSUE SER IN FORMAT AS REQUIRED o ABWR SSAR WILL MEET CONTENT AND ORGANIZATION REQUIRED BY R.G. 1.70, REVISION 3 AND NUREG 0800 IN EFFECT 6 MONTHS PRIOR TO DOCKET DATE o GE WILL PROVIDE " CHECK LIST" DURING OR FOLLOWING THE COMPLETION OF EACH REVIEW PACKAGE BASIS FOR COVERING OUTSTANDING INTERFACES AT TIME OF REVIEW CHECK LIST WILL BE UPDATED FROM PACKAGE TO PACKAGE 05d350k . __ _ - - --- -

8-6-86 NRC STAFF MEM0 .

G. SITE-SPECIFIC ISSUES

1. THE LBA SHOULD DEFINE THE EXTENT OF " ENVELOPING" BY THE ABWR DESIGN.

2. ALL AREAS WHERE THE DESIGN ENVELOPES SITE SPECIFIC PARAMETERS SHOULD BE WELL DEFINED, AND THE MARGINS IN THE DESIGN WITH RESPECT TO THESE ENVELOPES SHOULD BE PROVIDED.

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3. DESIGN AREAS WHICH CANNOT BE ENVELOPED AND WHICH ARE ABSOLUTELY SITE-SPECIFIC OR SITE-SENSITIVE, SHOULD BE EXPLICITLY IDENTIFIED, INCLUDING THEIR EFFECT ON THE REST OF THE DESIGN.

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RECOMMENDED APPROACH G. SITE SPECIFIC ISSUES o ABWR SITE ENVELOPE WILL BE INCLUDED IN THE LBA AND WILL AGREE WITH EPRI REQUIREMENT DOCUMENT TABLE 2-1 (ENVELOPE OF ALWR PLANT SITE DESIGN PARAMETERS) o THE ABWR DESIGN ENVELOPE WOULD EXCEED SITE SPECIFIC PARAMETERS IN MOST AREAS OF THE WORLD MARGINS IN ABWR THE SAME AS A CUSTOM PLANT WHEN ALL SITE PARAMETERS ARE THE SAME AS THE ENVELOPE PARAMETERS UTILITY-APPLICANT WHOSE SITE EXCEEDS ONE OR MORE OF THE PARAMETERS MUST DEMONSTRATE DESIGN ADEQUACY l

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H. TECHNICAL ISSUES

1. SHOULD ANY SPECIFIC TECHNICAL ISSUES BE ADDRESSED IN THE LBA?

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2. GE MENTIONED THAT IT WANTED TO START WITH R.G. 1.70 AND NUREG-0800 IN DEVELOPING THE LBA (SEE MFN044-86, 6/2/86). THIS SHOULD BE DISCUSSED.

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RECOMENDED APPROACH H. TECHNICAL ISSUES o IDENTIFY SPECIFIC TECHNICAL ITEMS FOR LBA o USE USIs, GSIs, ETC. NUREG-0800 AND CP/ML RULE AS BASE IDENTIFY SPECIFIC REQUIREMENTS EXCLUDED DUE TO ABWR DESIGN IMPROVEMENTS IDENTIFY ALTERNATE SOLUTIONS TO MEETING REQUIREMENTS MODIFY EXISTING REQUIREMENTS TO REFLECT STATE-0F-THE-ART TECHNOLOGY CONSISTENT WITH EPRI REQUIREMENTS o ESTABLISH FORMAT AND APPROACH FOR TECHNICAL SPECIFICATIONS o ALL DESIGN ITEMS WILL BE CLOSED AT THE CONCLUSION OF THE REVIEW 0 /295NN Y

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8-6-86 NRC STAFF MEM0 -

I. SEVERE ACCIDENT POLICY STATEMENT (SAPS) i

1. THE LBA SHOULD HAVE A CLEAR STATEMENT ON HOW MUCH OF THE SAPS WILL BE ADDRESSED BY THE ABWR,

2. IT SHOULD ALSO INCLUDE AN EXPLICIT DISCUSSION OF ANY DISAGREEMENT BY GE WITH ANY SAPS POSITIONS.

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3. IT S'HOULD ALSO HAVE A DISCUSSION OF HOW THE STAFF EXPECTS THE ABWR TO DEMONSTRATE THAT IT MEETS, OR HOW TO DETERMINE WHETHER THE ABWR MEETS, THE SAPS.

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RECOMMENDED APPROACH I. SEVERE ACCIDENT POLICY STATEMENT (SAPS) o SEVERE ACCIDENT REQUIREMENTS WILL BE MET BY ABWR CP/ML RULE llDCFR50.34 (F)]

USIs, GSIs PRA COST EFFECTIVE RISK REDUCTIONS BALANCE BETWEEN PREVENTION AND MITIGATION HUMAN PERFORMANCE AND SAB0TAGE (INSIDERS AND OUTSIDERS) o NRC ACCEPTANCE CRITERIA WOULD BE DESCRIBED 0:J0E046: ET 8/7//86

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8-6-86 NRC STAFF MEMO.

. J. PRA

1. THE LBA SHOULD INCLUDE A SPECIFIC, INDIVIDUAL SECTION ON THE PRA.

2. THE PRA SECTION SHOULD DISCUSS THE GROUND RULES FOR THE PREPARATION, REV! W, AND USE OF THE PRA. ,

A. WILL IT INCLUDE INTERNAL AND EXTERNAL EVENTS?

B. WILL IT INCLUDE CONSEQUENCE STUDIES, AND OF S0, HOW ARE THEY AFFECTED BY SITE-SPECIFIC CHARACTERISTICS?

c. THE SITE-SPECIFIC PARAMETERS SHOULD BE WELL DEFINED.

D. THE PRA SHOULD BE ABLE TO BE RE-PERFORMED WITH A DIFFERENT B0P DESIGN IF THE ABWR DESIGN IS NOT COMPLETE. IT MUST ALSO DEFINE THE NSSS/ BOP INTERFACES VERY CLEARLY.

3'. THE LBA SHOULD DOCUMENT THE PROPOSED STAFF PRA REVIEW PROCESS AND HOW THE STAFF WILL MAKE

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USE OF THE PRA.

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RECOMMENDED APPROACH j J. PRA o CONTENTS OF PRA INTERNAL EVENTS EXTERNAL EVENTS (EXPAND LIST) o UTILITY-APPLICANT PRA VERIFICATION PROCEDURE SPECIFICATION OF APPLICATION-DEPENDENT CHARACTERISTICS VERIFICATION METHODOLOGY o STAFF PRA REVIEW PROCESS TIMING

" COMPLETENESS" CRITERIA .

SITE SPECIFIC APPLICATION o IDENTIFICATION OF REQUIRED FMEAs Oid3hNN

8-6-86 NRC STAFF MEMO, ,

K. ACRS

1. THE LBA SHOULD DEFINE HOW THE ACRS WILL PARTICIPATE IN THE REVIEW AND CER cR0 CESS.

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2. WILL THE ACRS BE INVOLVED FROM THE VERY BEGINNING, AND IF S0, HOW?

3. WILL THE STAFF AND GE GIVER PERIODIC BRIEFINGS TO THE ACRS AS THE REVIEW WOULD THE BRIEFINGS CORRESPOND TO THE ISSUANCE OF THE SER, SSERs, QS, OR ANOTHER CRI

4. HOW WILL ACRS COMMENTS BE FACTORED INTO THE DESIGN AND REVIEW PROCESS?

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RECOPMENDED APPROACH i

! K. ACRS o FORMAL MEETINGS SHOULD OCCUR AFTER REVIEW IS COMPLETE o PARTICIPATION SCHEDULE (INFORMAL)

INITIAL BRIEFING BY ST.tFF AND GE PERIODIC BRIEFING BY STAFF AND GE o UTILIZATION OF ACRS COMMLiiTS FDA i

PUBLIC HEARINGS 4

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8-6-86 NRC STAFF MEMG -

L. ORGANIZATION

1. THE GE ABWR ORGANIZATION SHOULD BE DEFINED, WITH THE RESPONSIBLE INDIVIDUAL MANAGERS AND CONTACTS IDENTIFIED.

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2. THE NRC REVIEW ORGANIZATION AND REVIEW STRUCTURE SHOULD BE DEFINED. THE INTERACTION

0F THIS GROUP WITH THE EPRI-ALWR REVIEW GROUP SHOULD ALSO BE DISCUSSED.

3. THE ORGANIZATION AND RESPONSIBLE OFFICIALS OF OTHER ABWR PARTIES (DOE,EPRI, FOREIGN PARTICIPANTS) SHOULD BE IDENTIFIED.

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REC 0fmENDED APPROACH

L. ORGANIZATION GROUP JNDIVIDUAL RESPONSIBILITY .

GE J. F. QUIRK ABWR PROGRAfi MANAGER l

D. R. WILKINS GENERAL MANAGER, ABWR PROGRAM R. VILLA ABWR LICENSING MANAGER G. G. SHERWOOD MANAGER, SAFETY & LICCiiSING OPERATION L. S. GIFFORD MANAGER, REGUILATORY OPERATIONS (BETHESDA)

NRC R. CARUSO NRC LICENSING PROJECT MANAGER FOR ABWR R. W. H,00STON DEPUTY DIRECTOR, DIVISION OF BWR LICENSING R. M. BERNER0 DIRECTOR, DIVISION OF BWR LICENSING 0: JOE 046: ET 8/27/86 _ _____ _____

' 8-6-86 NRC STAFF MEMO-, ,

M. LICENSING FEES

1. HOW WILL LICENSING FEES BE PAID?

2. HOW DOES THE PARTICIPATION OF DOE AFFECT FEES?

3. WILL THERE BE A NEED FOR EXEMPTIONS FROM THE REGULATIONS?

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4 RECOMMENDED APPROACH M. LICENSING FEES i

l l 0 LICENSING FEES WILL NOT BE AN ISSUE IF 10CFR PART 171 BECOMES EFFECTIVE 10/1/86 l

l NO FEES FOR PDA/FDA APPLICANTS l

0 IF PART 171 IS NOT IMPLEMENTED 10/1/86 SEEK EXEMPTION FROM PART 170 o REVISIT AFTER 10/1/86 0: JOE 046: ET l lI#'

~

8-6-86 NRC STAFF MEMO .

N. DESIGN COMPLETENESS

1. THE EPRI-ALWR PROGRAM ENVISIONS THAT 70% OF THE DESIGN WOULD BE COMPLETE BEFORE CERTIFICATION. DOES GE AGREE?

2. THE LBA SHOULD INCLUDE A DEFINITION OF HOW TO DETERMINE THAT 70% OF THE DESIGN IS COMPLETE, ALONG WITH A DEFINITION OF HOW DETAILED THE APPROVED DESIGN WILL BE.

IT SHOULD BE EXPLICIT IN TERMS OF WHAT WILL HQI BE COMPLETELY DESIGNED.

3. IF THE DESIGN DOES NOT INCLUDE THE BOP, THEN THE NSSS/ BOP INTERFACE MUST BE EXTREMELY WELL DEFINED, ESPECIALLY IF ONLY 70% OF THE PLANT IS COMPLETELY DESIGNED (SEE PRA COMMENTS).

4 8/28/86 14

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l RECOMMENDED APPROACH

, i N. DESIGN COMPLETENESS

(:'

o DESIGN COMPLETED TO THE LEVEL DESCRIBED IN AIF STUDY GROUP REPORT

! (EXHIBIT B) i I

o INTERFACES WILL BE MINIMIZED BY ABWR NUCLEAR ISLAND SCOPE o AN INTERFACE DOCUMENT MAY BE JOINTLY DEVELOPED BY THE NRC AND GE FOR USE IN COMPLIANCE VERIFICATION 4

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0:J0E046: ET 8/77/86

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8-6-86 NRC STAFF MEMO . -

0. CERTIFICATION PROCESS

! 1. THERE ARE SOME PENDING PROPOSALS CONCERNING THE CERTIFICATION PROCESS THAT INCLUDE A l REQUIREMENT THAT A STANDARDIZED PLANT APPLICANT ADDRESS CONSTRUCTION CRITERIA, QA/QC PROGRAMS, AND INSPECTION CRITERIA TO ENSURE THAT THE PLANT IS EVENTUALLY BUILT TO THE DESIGN SPECS, HOW WOULD GE PLAN TO ADDRESS THESE AREAS?

2. OTHER THOUGHTS ON HOW THE CERTIFICATION PROCESS WOULD PROCEED?

t 8/28/86 15 l

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RECOMMENDED APPROACH

0. CERTIFICATION PROCESS

o -CONTENTS OF SSAR SECTION/ APPENDIX ADDRESSING "SSAR-TO-APPLICATION

! INTERFACE REQUIREMENTS" WILL BE DEVELOPED FOR LBA DOCUMENTS CONSTRUCTION CRITERIA QA/QC PROGRAM INSPECTION CRITERIA PRA VERIFICATION CRITERIA o SSAR-TO-APPLICATION INTERFACE REQUIREMENTS WILL INCLUDE GUIDELINES AND CONTENT OF NRC SITE COMPATIBILITY CHECK VERIFICATION REPORT REQUIRING ACCEPTANCE BY NRC PRIOR TO FUEL LOADING j NOTES:

(1) DESIGN INTERFACES ARE CURRENTLY COVERED UNDER SECTION 1.9.1 0F R.G. 1.70 (2) REQUIREMENTS BEYOND CURRENT R.G. 1.70 AND NUREG-0800 REQUIREMENTS l

. STATUS OF LBA SUBJECTS FOLLOW-UP AGREED RESPONSIBILITY A. PARTICIPANTS B. PROPRIETARY INFORMATION C. EPRI-ALWR PROGRAM D. FUTURE ISSUES E. SCHEDULING F. REVIEW PROCEDURES G. SITE-SPECIFIC ISSUES H. TECHNICAL ISSUES I. SEVERE ACCIDENT POLICY J. PRA K. ACRS L. ORGANIZATION M. LICENSING FEES N. DESIGN COMPLETENESS

0. CERTIFICATION PROCESS 0:J0E044: ET 8/2//86 i l

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- E X HIBiT A L

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Dep=L..mt of Energy San Francisco Operations Office 1333 Broadway Oakland, Califomia 94612 ..

3 JUL 195 .

Dr. Bertram Wolfe Vice President & Gene al Manager NT&FD, NEBO General Electric Company 175 Curtner Avenue San Jose, CA 95125

Subject:

Provisions for Integ ation of EPRI ALWR Requirements Program and DDE ABWR Design Verification Program

-4 Desr D . Wolfe:

John Taylor's letter of June 9,1986 forwarded four copies of the subjectDelb

r.ent to DOE /HQ for signature.

forwarded them to DOE / SAN for signature.

This document outlines the provisions for coordination of the EPRI Requirements Document, and the General Electric (GE) ABWR submittals As to the y:u Nuclear Regulatory Comission under DDE's Design Verification Program.

know, these provisions were developed over the past two months in discussions between EPRI, GE and DOE. I concur with these provisions and have signed the four copies. They are fo warded herewith for your concurrence and signature.

After you have signed, please forward all four copies to John Taylor who will

-distribute the signed copies.

We wisn to thank Dr. D. R. Wilkins and Mr. Joe F. Ouirk of your organization who were instrumental in execution of this document.

Sincerely,

/.,- . , W. : -

Thomas F. Heenan Assistant Manager for Energy Research and Technology Enclosure cc w/o enc 1:

Delbert F. Bunch, DDE/HO John Taylor, EPRI

. ].

PROVISIONS FOR INTEGRATION 9E EPRI ALWR REOUIREMENTS PROGRAM AND DOE ABWR DESIGN VERIFICATION PROGRAM

1. BWR Subcommittee: The ALWR Program Utility Steering Committee and EPRI will form a BWR Subcommittee to review the GE ABWR requirements and design, and to work with EPRI and its contractors to develop the BWR portion of the EPRI ALWR Utility Requirements Document.

2. ABWR Briefino: As a first item of business the BWR Subcommittee will receive a comprehensive briefing on the GE ABWR design by the GE Advanced BWR Program staff.

3. BWR Reouirements: EPRI and its contractors will develop BWR requirements as a part of the Utility Requirements Document. G.E.

has performed extensive design work on the ABWR program which is being made available to EPRI and which will be used in the formulation of BWR requirements developed to meet utility needs.

Where GE does not believe a design modification to its ABWR is appropriate, and believes an exception to these requirements is ITsg l warranted, EPRI and its utility sponsors and GE will review the issue and decide upon the course of action to be taken.

4. Licensino Submittals: GE will prepare materials for submittal to NRC for certification of the ABWR design under the DOE ALWR Design Verification Project. The design submitted for certification will be consistent with the actions taken in 3. above. I A copy of the GE UD submittals will be provided to EPRI 30 days in advance of submittal to NRC.I A copy of the EPRI ALWR Requirements Document materials related to BWRs will be provided to GE 30 days in advance of submittal to NRC. In any event, sufficient time will be allowed for coordination, even if this lead time exceeds 30 days, to avoid any delay in the scheduled submi'tal dates of these documents.

5. Schedule for Licensino Submittal:

• EPRI has accelerated the schedule for submittal of its Utility Requirements Document Chapters to NRC by about 14 months, and the GE project in the DOE ALWR Design Verification Program has delayed its schedule by about 15 months to allow these two programs to be l coordinated. The following schedules are agreed to in order to

~ allow a 3 month period of NRC review of the EPRI ALWR Utility i Requirements Document Chapter bef_ ore the correspondino GE licensing certification submitd:a1 is made.] In the event of schedule slippage l

on Ine part of one o" the parties, the other will continue according to the schedule shown below. (It is understood that major plant l

arrangement features necessary to the discussion of reactor and safety systems may be submitted by GE with Chapter 3, 4 and 5 material).

EPRI Requirements Document GE Licensing Certification Topic Submittal Schedule Submittal Schedule Chapter 1 6/86 9/86 gg3 j Overall Requirements Chapter 2 9/86 12/86 Power Generation 9/87 Chapters 3, 4, & 5 6/87 Reactor & Safety Systems Chapter 6 12/87 3/88 Plant Arrangement Chapters 7, 8, 9, 11 & 12 3/85 6/88 Auxiliary Systems Chapter 10 3/88 6/88 I&C Concur: L; N 4~ <

/. 4 tl._J.d aylor ,

ElectricPo)werResearchInstitute Concur: I -- -. 7 d'd'I T. F. Heenan Department of Energy San Francisco Concur: $!S[b6 D. F. Bunch Department of Energy, Hd;trs.

Concur: ._A 7 !(i M 'Holf e Jj i l i General Electric Co.

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' vaoM 'P os tTi ON PA ps yt. ON sTAwDARDM,ATtow PREPAR.sD GV l

. AIF STUDY G R OUP , M AR C H t986 DC applications will contain sufficient design in- the benefits of standardization and are not in con-formation to enable the staff to reach a conclusion flict with, and would not detract from, a successful on matters encompassed therein that construction standardization policy based upon the preapproval and operation of a facility utilizing the reference of reference designs. la particular, the duplicate design will provide reasonable assurance of ade- and replicate plant concepts have been quate protection of the health and safety of the demonstrated to be effective means of reducing public and the common defense and security. DCs the staff and applicant resources required for j should be conclusive on matters encompassed licensing reviews.

therein with regard to staff, ACRS, Commission and hearing board reviews of license applications, We recommend that the Commission regulations and must not be subject to challenge in individual relating to the duplication, replication, and manu-licensing hearings. We believe that, ultimately, facturing license options be revised and updated certified designs will become the most favored by in a manner consistent with the preapproved refer- l the industry in view of their substantial stability. ence designs. Accordingly, Preliminary and Final Moreover, this should lead to a process that Duplicate Design Approvals (PDDA and FDDA) allows approval, reference and multiple use of and manufacturing licenses should be effective Design Certifications in COL proceedings. for a period of 10 years from the date of issuance.

Applications for replicate plants should be accept-DCs should be allowed to be referenced from their ed for periods of 10 years from the date of is-date of docketing and should be effective for peri. suance of the applicable SER supplement for the ods of 10 years, renewable by the Commission base plant. Manufacturing licenses should be for additional periods of no less than five years, renewable for additional periods of no less than nor longer than 10 years. These requests for five years, nor longer than 10 years.

renewal must be submitted no earlier than 36 months prior to the expiration date of the certifica. In the review of license applications based on tion. The Commission is expected to grant these these options, the staff and the ACRS should uti-renewals unless it determines, based on significant lize and rely upon the prior reviews and approvals new information, that the design will not comply of the designs to the maximum extent possible, with the Commission's regulations for the protec. The staff and ACRS reviews should focus only on tion of the public health and safety or the those portions of the applications which diffor

• common defense and security, applied in accor. from the previously approvey designs.

dance with the Commission's backfit rule. Addi-tional hearings should not be mandated for the DESIGN INFORMATION REQUIREMENTS Commission to grant a DC renewal, and DCs FOR FINAL DESIGN APPROVAL AND would remain in effect while awaiting Commission DESIGN CERTIFICATION APPLICATIONS issuance of the renewals. The expiration of a DC We urge the Commission to indicate its intent to should not affect the use of the reference design provide a high level of discipline to the licensing in applications that referenced the DC prior to its process by not allowing standard designs to be expiration. An OL application should be allowed to rereviewed unless the staff determines, based on reference an expired DC if it was also referenced significant new information, that the designs will in the CP application. not provide reasonable assurance of adequate pro-tection of the public health and safety or of the STANDARDlZATION OPTIONS IN .

E * '" "' # * * * " " 8 "'

COMMISSION'S 1978 POLICY STATEMENT review process that will allow the staff to reach While reference designs are developed and ap- the required health and safety determinations,it is proved, we urge the Commission to retain for use necessary that the applecations include all the in-  !

in the near term the duplication, replication, and formation necessary to properly define and char- I manufacturing license options. These options are acterize the construction and operation of the l desenbed in the Commission's 1978 policy state- designs.

ment on standardization, and in NRC regulations, particularly Appendices M and N to 10 CFR Part For FDAs and DCs it is expected that essentially

50. We beheve that these options offer many of 1 I complete design information will be provided l l

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Ik However, the term " essentially complete" needs tions, the staff should stress that in the limited i l-to be defined. cases where design information is not available, in-formation on methods, procedures and perfor-FDA and DC applications should define the major mance criteria, rather than the detailed description design components and include the results of pre- of specific pieces of equipment sometimes provid-liminary engineering to identify as appropriate: ed in OL applications, would be acceptable. This guidance should also be consistent with recent

- Design basis criteria Commission emphasis on less prescriptive and

- Analysis and design methods more performance oriented regulations.

- Functional design and physical arrangement of auxiliary, BOP, and NSSS systems Applications for FDAs ar,d DCs should define the tests, inspections, analyses, and acceptance en.te-

, - Plant physical arrangements sufficient to ac- ria related thereto necessary to assure that the

commodate systems and components designs are properly installed in the plant. These

- Functional / performance specifications for tests, inspections, analyses, and acceptance crite-components and materials sufficiently na would be implemented in a series of sign-detailed to become a part of associated pro- as-you-go reviews through construction and pre-curement specifications operation.

- Acceptance / Test Requirements The degree of design detail necessary for provid-

- Risk Assessment Methodology ing an essentially complete design will generally

,, be that detail which is suitable for obtaining Design documentation for systems, structures and specific equipment or construction bids. As

• components should include as appropriate: detailed "name-plate" information becomes available during the procurement and construction

- Design basis criteria process, refinement of the reference design may

- Plant general arrangements of structures be desirable. To take such refinements into ac-and components count, the holder of a license utilizing a reference design may submit, as applicable, a proposed pro-

- Process and instrumentation diagrams gram of NRC auditing of the refinements against

- Controllogic diagrams- the detailed approved design, utilizing the accep-tance criteria which are part of the FDA or DC.

- System functionaldescriptions

- Component and procurement specifications industry organizations experienced in developing including acceptance test requirements license applications are available to work with the

• NRC staff to develop and document detailed guid-

- Construction and installation specifications ance describing the design information to be

- QA program included in FDA and DC applications.

- Emergency plans CHANGES TO STANDARD DESIGNS

- Supporting design documentation such as We urge the Commission to reiterate its endorse-site data and calculations sufficient to sup. ment of regulatory actions that will strongly en.

port the above level of design detail courage and assist the industry in the pursuit of

- Security standardization in future reactor designs. In the past, regulatory practice has resulted in the rere.

- ALARA/ Radiation Protection view and backfit of designs in a manner that un-

- Accident Analysis dermined the basic concepts of standardization.

To ensure a more disciplined and predictable

- Draft Technical Specifications review and licensing process, the staff and ACRS

- Risk Analysis should be directed not to rereview any feature of an approved standard design unless they deter-In developing detailed guidance describing the in- mine, based on significant new information, that formation to be included in FDA and DC applica- the design will not provide reasonable assurance 8

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Agenda Item Synopsis Enclosure 3 A. ABWR Participants.

GE discussed the participants in the ABWR program, including)its foreignpartners (T how EPRI and DOE are participating as supporters of the standardized plant concept. GE made it clear that any FDA or design certificate that would be issued would be to GE alone, as the applicant-licensee, and that the role of DOE and EPRI was limited to one of program support. GE's foreign part-ners would have to make a separate application on their own if they wished to become ABWR certificate holders.

B. Proprietary Information GE expects that over 90% of the ABWR design information will not be pro-prietary. It does not have any problem with releasing the proprietary information to intervenors during the course of any possible certification hearings, if the intervenors agree not to disclose the information. How-ever, it agreed to check with its foreign partners about their positions on such releases of information, because some of the information used by GE in its application may be derived from those foreign partners.

C. EPRI-ALWR Program GE described its relationship to the EPRI ALWR standardization program. It knows of no disagreement between it and EPRI with regard to any standards in Chapter 1 of the EPRI requirements document. GE does believe that there are some minor disagreements in Chapter 2, but they are supposed to be minor. GE and EPRI(D. Noble) both stated that they believed that there would not be any substantial problems between the two programs, because GE has been working closely with EPRI in developing the requirements documents.

As a final check, GE will submit the appropriate chapters of its SSAR to EPRI for its review and comment before they are submitted to the NRC. Both EPRI and GE agreed that a formal method of resolving differences should be established, and that the NRC staff will be informed of areas where the GE design does not conform to the EPRI requirements.

D. Future Issues GE stated that it does not want to have any open licensing issues at the time of licensing. The staff inquired whether GE was incorporating issues raised by IE Information Notices and Bulletins into its design, and GE stated that it had not, but that it would investigate it. The staff asked how other future issues would be addressed, and it was suggested that the staff use the procedure established for the EPRI-ALWR review by DSR0 for the ABWR. The staff agreed to study that procedure. GE reiterated that it wants to resolve all generic issues before licensing, and that it will work to accomplish that goal.

E. Scheduling GE presented its proposed schedule for submittal of the ABWR SSAR. It is integrated with the EPRI-ALWR program schedule, and contemplates completion of the staff review in late 1990. All parties agreed that' one round of formal questions during the review period for each submittal'would be suf-ficient, if additional technical review meetings are held to stimulate the flow of information.

y r

O F. Review Procedures The parties agreed that the staff review would be based of the NRC Standard Review plan. It would also consider the EPRI requirements, and GE will identify all ABWR exceptions to those requirements and provide justifica-tion for the exceptions. The staff would issue an SER in draft form for each portion of the SSAR, and would issue a final integrated SER at the end. GE agreed to provide a check-list for each review package that will document any outstanding interfaces between different packages at the time of submittal. The checklist would be updated from package to package.

Because the SSAR would be submitted in pieces, the staff agreed to discuss the review process internally, to define it better and avoid a circular review process.

G. Site Specific Issues.

The parties discussed the degree of enveloping which would be provided. GE stated that the margins in the ABWR would be the same as in a custom plant when all site parameters are the same as the envelcpe parameters. The staff asked GE to document how sensitive the design would be to changes in those parameters, and to provide parametric analyses for different combinations of those parameters.

H. Technical Issues.

The attendees agreed that the LBA might include some definition of certain technical issues, such as the USI's, and GSI's. It may also identify the exclusion of some other requirements due to the design of the ABWR, or alternative solutions to other requirements.

I. Severe Accident Policy GE stated that it would meet all requirements of the Severe Accident Policy Statement (SAPS). The staff agreed to investigate the status of the develop-ment of the specific acceptance criteria for determining whether the ABWR meets those requirements.

J. PRA The ABWR PRA will consider both internal and external events. It will include the means for a future utility-applicant to verify that the GE PRA is applicable and valid for the utility's particular facility. The staff agreed to investigate the current staff position on the uses of the PRA as part of SAPS, the relevant acceptance criteria for input values, and accep-table boundary conditions and definitions. The staff encouraged GE to submit the PRA as early in the review process as possible, to allow the identification of potential plant improvements. GE responded that it had used PRA techniques throughout the design of the ABWR, and had improved various components and systems as a result, so it did not believe that any significant areas of improvement would be identified by the final, overall l PRA.

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K. ACRS Participation The parties agreed that the ACRS should participate in the review process from the earliest stages. It was also agreed that frequent meetings with subcommittees and with the entire committee might be valuable. Attendees agreed to consider the specific timing of such meetings, such as whether they should occur when new SSAR sections are submitted, or after draft SEP.s are issued, or any other criteria.

L. Organization GE, DOE, and EPRI discussed their organization for the ABWR review.

M. Licensing Fees The meeting attendees discussed the proposed new licensing fee regulation (10CFR171) and its effect on licensing fees for applications for standard-ized plant designs. Because there is some question about the final form of the regualtion and its effective date, GE stated that it is considering the possibility of applying for an exemption from the fees. The staff suggested that GE file such a letter as soon as possible, to allow sufficient time for review of its request. The DOE representative at the meeting confirmed that none of the DOE financial assistance to GE for the ABWR certification process could be used to pay for licensing fees.

N. Design Completeness Meeting attendees discussed the degree to which the ABWR design would be complete at the time of docketing and at licensing. The staff inquired what standard GE would use to determine design completeness, and GE replied that it intended to use a standard proposed by an AIF study group in March, 1986. The staff agreed to study the proposal and this will be a future follow item.

O. Certification Process The meeting then discussed the certification process itself. All partici-pants realize that the final process is not well defined, and that there are several proposals before the Commission, and also some licensing change legislation before the Congress.

P. LBA Document Type The meeting also discussed the several forms which could be taken by the LBA. These included a NUREG, an office letter, or a paper specifically approved by the Commission. The scope and depth of the document also remain to be decided on.