ML20234D724

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Draft Sys 80R Design Certification Licensing Basis Agreement
ML20234D724
Person / Time
Site: 05000470
Issue date: 07/01/1987
From:
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:
Shared Package
ML20234D380 List:
References
NUDOCS 8707070319
Download: ML20234D724 (46)


Text

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1 DtMFT COPY 1

i DRAFT I

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SYSTEM 80 i

DESIGN CERTIFICATION i

LICENSING BASIS AGREEMENT i

JULY 1, 1987 i

l G707070319 87070P ADOCK05000gO PDR

DRAFT COPY 1.0 ABSTRACT The NRC Staff will soon extend its technical review of Combustion

.s Engineering's System 80 standard design which is being modified'to meet the NRC's Severe Accident Policy Statement and expanded to a Nuclear Power Module which will include, in addition to the NSSS, the emergency feedwater system, containment and control room. Both the NRC Staff and Combustion Engineering believe that the review process will proceed more smoothly if a Licensing Basis Agreement (LBA) is developed before the next phase of the technical review starts. The LBA is intended to-define H

I the review process for the System 80 Nuclear Power Module standard design 1

which will ultimately lead to design certification by the Commission and, thus, will accomplish a significant step toward the stabilization of the commercial nuclear power plant licensing process.

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DRAT: COPY

2.0 INTRODUCTION

Certification of standardized nuclear power plant designs is an important initiative that has the potential-for significantly enhancing the safety, reliability, and availability of future nuclear plants.

In addition,.the combination of certified designs and pre-approved sites can significantly reduce the time and cost required for the licensing and construction of nuclear power plants.

Specifically, once design certification is achieved, a standard f

design could be referenced by multiple utilities for use on multiple

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capable sites without further design review. The design'would be approved for a ten year period, with an option for renewal for an I

additional ten year period. This approach will lead to improved

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plant safety and reliability and will provide substantial cost savings to both the NRC and the utility applicant.

Accordingly, the NRC fully supports the effort by Combustion Engineering to obtain a Design Certification of the System 80 j

standard design and has agreed with Combustion Engineering that this LBA will be used to establish a clear definition of the process and l

administrative matters which will be used to certify the System 80 standard design.

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MAFT COPY Since the objective of this program is to pre-approve the System 80' standard design prior to identification of the utility applicant, the site, or sub-suppliers, it is necessary that the level' of. detail provide sufficient information to enable the Staff to complete its review without posing anti-competitive constraints.

Experience has shown, however, that this should not represent a limitation on.the Staff's ability to complete its review.. Combustion Engineering and the Staff agree that the depth of design information needed to conduct this review is the level which demonstrates compliance with NRC regulations sufficient to close out all open safety issues.

Furthermore, Combustion Engineering and the Staff agree that experience in the previous review of System 80 for its current Final Design Approval (FDA) provides reasonable assurance that the Staff can receive all of the information needed to complete its review of the System 80 changes with a level of detail sufficient to close out all open review issues.

I Consequently, Combustion Engineering will update its standard safety analysis report for the System 80 design, as necessary, to i

accommodate Combustion Engineering's initiated improvements as well as changes required to demonstrate the technical resolution of all applicable Unresolved Safety Issues, the medium-and high-priority Generic Safety Issues, and other issues identified in the Severe Accident Policy Statement. As discussed in the previous paragraph, j

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DMFT COPY Lthese updates will contain sufficient information'to permit the Staff to complete its review and close all open' safety issues.

2.1 BACKGROUND

Combustion Engineering's System 80 standard design is in operation at the Palo Verde Nuclear Generating Station.

System 80 included many technical advancements in its initial development and, therefore, already includes many of the features that are only now being incorporated into proposed Advanced Light Water Reactors.

With the Palo Verde units now in operation, System 80 has " complete" design detail with fabrication, construction, start-up and operating experience fed back into the design.

2.2 CESSAR HISTORY 1

In accordance with the Commission's existing Standardization Policy, Combustion Engineering submitted its preliminary combustion Engineering Standard Safety Analysis Report (CESSAR-P) for staff review. CESSAR-P was subsequently referenced in the construction i

permit applications of seventeen ~(17) units with five (5)'different Balance-of-Plants, located at six (6) different sites (see Table 1).

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DRA7T COPY Table 1 Construction Permit Applications ReferencingCESSARd Utility Plant Arizona Public Service Palo Verde 1, 2, 3, 4 & 5 Duke Power Company Cherokee 1, 2 & 3 Duke Power Company Thomas L. Perkins 1, 2 & 3 New York State Electric & Gas New Haven 1 & 2 j

Tennessee Valley Authority Yellow Creek 1 & 2 Washington Public Power Supply System WPPSS 3 & 5 l

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sAAF? COPY Combustion Engineering subsequently submitted a final version of CESSAR and an application for a Final Design Approval'.(FDA). The i

NRC Staff's safety review was co'nducted on the basis - and with the i

expectation - that the design waslto be forward referenceable in i

l accordance with the Commission's August 1978 Standardization

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I Policy.

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After an extensive and thorough' review, Combustion Engineering's System 80 standard design was granted an FDA in December, 1983.

.This FDA was referenced by Palo Verde Units 1, 2, and 3 and WPPSS Unit 3 and formed the basis for the Operating Licenses for Palo

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Verde Units 1, 2 and 3.

The improved System 80 standard design to be submitted for NRC Design Certification will use the basic design covered by the current FDA.

By utilizing this "FDA design", Combustion Engineering will have already demonstrated that the standard design submitted j

for Design Certification complies with all NRC regulations and requirements for existing plants.

The result of the System 80 changes will be a design that is upgraded to fully implement the NRC's Severe Accident Policy Statement and is, therefore, ready for design certification by the Commission.

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MAIPT COPY

2.3 DESCRIPTION

OF DOE DESIGN VERIFICATION PROGRAM In order to ensure the future viability of comercial nuclear energy, a DOE ALWR Design Verification Program has been initiated which will consider the.EPRI Design Requirements (Section 2.4).and other related industry initiatives and proceed to NRC Design Certification with an actual standardized design.(System 80). The-System 80 standard design will be submitted to the NRC for design certification and will thus be setting precedents for the implementation of the 1985 Severe Accident Policy Statement.

The System 80 standard design already meets all NRC regulations and requirements for existing plants. The emphasis in the DOE program, therefore, is on modifications to meet NRC criteria for future plants (i.e., the Severe Accident Policy Statement) and on modifications that improve overall plant safety, reliability and j

availability. The development of these modifications for the System j

80 standard design and their review by the NRC will essentially 1

parallel the development and NRC review of the EPRI ALWR Requirements Document.

To date, the certification process for standard plant designs has not been fully defined by the Commission. The DOE has, therefore, determined areas in which DOE assistance will be required and has established the Advanced Reactor Severe Accident Program (ARSAP) to 2-6

onwr conj provide such assistance. The ultimate goal of the ARSAP program is to facilitate'the certification of standardized ALWRs by assuring severe accident safety issues are resolved.

The following ARSAP objectives are aimed at supporting Combustion Engineering's System 80 Design Certification. effort:

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Identify severe accident technical issues which are l

relevant to the System 80 Nucle'ar Power Module; i

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Achieve consensus on technical solutions to severe i

accident issues; o

Assure experience based improvements are factored into the System 80 Nuclear Power Module (IDCOR, PRAs, research results, licensing experience, and operating experience);

o Assure that severe accident issues are resolved up front -

as they relate to the System 80 Nuclear Power Moduel -

thus contributing to regulatory stability by avoiding backfits; 2-7

3 RAFT COPY

2.4 DESCRIPTION

OF EPRI ALWR PROGRAM The Electric Power Research Institute (EPRI) has begun work on the Advanced Light Water Reactor (ALWR) Program. This program is a utility sponsored and directed effort for the development of the utility requirements for the next generation of nuclear power plants.

It will result in the production of a detailed

" Requirements Document" that will specify the design requirements for future, simplified, standardized, LWR plants (both BWRs and PWRs). Each portion or chapter of the Requirements Document is reviewed by a Utility Steering Committee and an industry review group consisting of nuclear steam supply system vendors and architect / engineers. These chapters are then submitted to the NRC.

1 It is intended that reactor designers will use the document to guide the design of future nuclear power plants with the assurance that I

they will meet accepted industry standards, utility needs, and all

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NRC licensing requirements. The first and second chapters of the requirements document were submitted to the NRC for review in July and October, 1986, respectively.

The remaining eleven chapters are scheduled for submittal over a two year period.

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T DPJET COP"i 2.5 DEVELOPMENT OF THE LBA s

Combustion Engineering's submittal of the System 80 standard design for NRC design certification will help establish the basis for the licensing of future nuclear plants.

Because an efficient and timely i

review of the System 80 standard design is essential to this effort, it is important to establish, as early as possible, specific procedures and guidelines for the NRC's certification process.

The need for a formal agreement between Combustion Engineering and the NRC Staff on these guidelines is particularly important because (1) a fully defined standard design certification process has not j

yet been issued by the Commission, (2) System 80 will be the first PWR standard design to proceed to design certification, (3) the System 80 Nuclear Power Module standard design may include features not currently covered by the existing Standard Review Plan, and (4) the System 80 Design Certification schedule and activities must be consistent with those established in the DOE Design Verification Program.

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DRAFT COPY 3.0 PARTICIPANTS 3.1 APPLICANT The applicant will be Combustion Engineering, Inc.

3.2 NRC STAFF ORGANIZATION The NRC Staff review of the System 80 standard design will use the normal matrix management structure.

In this organization, a Senior Project Manager (PM) will be responsible for coordinating the performance of the review by individual reviewers from the technical branches.

Because of the close relationship between the System 80 standard design and the EPRI program, the System 80 PM will work closely with the EPRI ALWR PM.

3.3 DEPARTMENT OF ENERGY PARTICIPATION The U.S. Department of Energy (DOE), through its ALWR Design Verification Program, is participating in the System 80 Design Certification Program.

DOE will not be an applicant for the design, but is to be kept informed of the progress of the certification process.

In the event that hearings are held concerning the Design Certification, DOE will be accorded the right to participate in the hearing process to the extent permitted by 10 CFR 2.715(c) as an interested governmental agency.

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DRAFT COPY i

3.4 DOCUMENT DISTRIBUTION /PUBLIC DOCUMENT ROOM i

The following parties will initially be provided with copies of correspondence regarding the System 80 standard design:

(name-later)

U.S. Department of Energy I

(address - later) l (name - later)

Electric Power Research Institute (address - later) 1 When the actual certification process begins, additional parties may be added to this list.

Since this is a national design no local public document room (PDR) will be established for this project, rather the main NRC POR in Washington, D.C. will be utilized.

Notices to the general public will also be published in the Federal Register, consistent with present regulations.

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4.0 SCHEDULE 4.1 LICENSING SCHEDULE The anticipated schedule for the Final Design Approval Amendment (per section 12.2.B) and Design Certification of the System 80 standard design is shown in Tables 2 and 3 and Figure 1.

Table 2 Overall Licensing Schedule

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o Initiate Discussions on Technical Issues j

and Licensing Basis Agreement December 1986 o

Submittal of Draft LBA July 1987 o

First CESSAR Submittal (See Table 3)

August 1987 o

Major CESSAR Submittals (See Table 3)

October 1987 - June 1989 o

Final Design Approval Amendment June 1990 o

Design Certification September 1991 4-1

M AFT COPY

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Table 3 CESSAR Submittal Schedule Revision Implementation-

~CESSAR Submittal of of Submittal Group Description CESSAR-Chapter EPRI Chapter Date l

A General Descriptions and 1, 10, 17-1&2 August 1987 Requirements, Power Con-Appendices A & B version Systems I

B Reactor. Coolant System, 3(Partial),4, 3 a' 4 October 1987 Chemical and Volume Control 5(Partial)

System, Process Sampling 9 (Partial)

System, and Boron Recycle j

System C

Emergency Feedwater System, 5 (Partial).

5 March 1988

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Emergency Core Cooling 6 (Partial)

System, Shutdown Cooling System D

Building Design and Site 2, 3 (Partial) 6, 10 September 1988 Arrangements, Instrumentation 5 (Partial) 7 and Control Systems 4-2

DPJdFT COPY Table 3(Continued)

CESSAR Submittal Schedule l

Revision Implementation CESSAR Submittal of of Submittal Group _

Description CESSAR Chapter EPRI Chapter Date E

Fuel Handling Systems, 8, 9 (Partial) 7-13 December 1988 1

Radioactive Waste Systems 11, 12, 13, 14 i

F Safety Analyses, Probabi-6(Partial),15,76, June 1989 listic Risk Assessment, New Appendix Technical Specifications 1

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7 DRAF" COPYI 5.0 CONTENT OF APPLICATION

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5.1 SAFETY ANALYSIS REPORT FORMAT The safety review of System 80 for Design Certification will be performed by NRC reviewers who are accustomed to working with the i

format and organization of the NRC's Standard Peview Plan and Regulatory Guide 1.70 (Standard Format of Safety Analysis Reports).

CESSAR has already been reviewed and approved by the NRC Staff for i

the current FDA.

Combustion Engineering and the NRC Staff agree, therefore, that revisions made to CESSAR for Design Certification will be made in the same format for consistency with past review experience.

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DRAF' COPY 6.0 PROPRIETARY INFORWtTION Proprietary information submittals for the System 80 standard j

design, if any, will be consistent with the requirements of 10 CFR l

2.790.

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7.0 INCORPORATION OF ISSUES 1

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7.1 UNRESOLVED AND GENERIC SAFETY ISSUES The Commission's Severe Accident Policy Statement (see Chapter 10) requires that.all new power plant designs address all Unresolved i

Safety Issues (USI's) and all medium and high priority Generic j

Safety Issues (GSI's).

NUREG-1197 contains a list of those issues and the:r status as of July 1,1986.

The EPRI ALWR Requirements program will propose to the NRC Staff resolutions for the USI's and medium and high priority GSI's.

Consideration of the EPRI proposed resolutions for these issues will serve as the basis for the modifications made to the System 80 standard design and the subsequent revisions to CESSAR.

CESSAR will address these issues as required by the Severe Accident Policy Statement.

It is the intention of the Staff and Combustion Engineering that there will be no open items regarding the resolution of USI's or GSI's for the System 80 standard design at the time the design 13 presented to the Commission for Design Certification.

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DRA!FT COPY 7.2 BACKFIT RULE 1

i All issues will be resolved in accordance with the requirements of the Backfit Rule (10 CFR 50.109),

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DRAFT COPY i

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8.0 REVIEW PROCEDURES

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l 8.1 STAFF REVIEW The System 80 standard design submitted for Design Certification will be based on the standard design encompassed by the current System 80 FDA. This FDA effectively demonstrates System 80's compliance with NRC rules and regulations for existing plants.

The current NRC Staff review of the System 80 standard design will, therefore, cover only those design features which have been revised.

8.2 FORMAT OF SAFETY EVALUATION REPORT (SER)

The Staff's SER for the System 80 standard design will be in the same form used for other reactor licensing applications.

However, because revisions to CFSSAR will be submitted in groups of chapters over a two year period, the SER will be issued in draft form and in sections.

It will be important to carefully document open issues that may be identified in the review process, but which cannot be resolved until the completion of later chapters.

Each draft SER section will contain a full description of such issues and will be issued at the completion of the Staff's review of each submittal.

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-DPAFT COPY 8.3 SUBMITTAL " CHECK LIST" I

With the amendment of each Chapter of CESSAR, Combustion Engineering will provide an updated checklist which identifies outstanding issues 'and the future chapter (s) in_ which resolution is' anticipated.

-This checklist will include a. list of key interfaces between' systems and will track resolutions of these outstanding.. interface issues.

(The checklist will be maintained on an electronic data base compatible with IBM personal computer software.)

8.4 INTEGRATED REVIEW At the completion of the review of the individual CESSAR amendments, the staff will perform an integrated review of the project to ensure all open review issues are resolved.

This review will complement the PRA and safety analysis reviews, in that it will be an overall' assessment of the design. The Staff will issue a composite final SER in accordance with the schedule described in Chapter 5.

It is necessary that there be no open issues at the completion of.the NRC Staff review so that the System 80 standard design can proceed to Design Certification.

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D?JaT COVL

-8.5 QUESTIONS AND RESPONSES As the staff review progresses, there is likely to be a need for additional information from Combustion Engineering to answer staff questions.

The NRC interr:al procedure to;be used is described below. This procedure will be applied to the resolution of all NRC-questions.

In ' addition, to. improve the efficiency of the review, Combustion Engineering and the NRC Staff' encourage informal-communication while assuring that resolution of issues is adequatelyL documented. The s'.eps are as follows:

1.

After a CESSAR amendment is received reviewers will be expected to review the revisions in detail and submit requests for.

additional information (RAls) to the NRC Project Manager (PM).

Key RAI items will be submitted within one month and a complete RAI within two months after the CESSAR amendments have been received.

Some RAls may include requests for information that is not expected to be available until the submittal of a later CESSAR amendment.

These RAls will be deferred to future

' amendment submittals and Combustion Engineering will ensure the

" check list" is updated accordingly.

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The NRC PM will compile the RAIs, and transmit them to Combustion Engineering immediately on an informal basis.

Through informal communications such as conference calls, the RAIs will be further reviewed and,'if mutually agreeable, some may be answered. informally and/or withdrawn. The NRC PM and designated Combustion Engineering coordinator will-then agree.

he r an ue th he e f rev ers f

transmittal to Combustion Engineering will-then be completed ~

within two weeks after the RAIs have been submitted to the NRC PM.

3.

Combustion Engineering and the NRC Staff will mutually agree on the meeting schedule. The meetings are expected to begin 1

within about one month after submittal of each CESSAR amendment and should be completed within about one more month.

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The NRC PM and the reviewer (s) will document the.results of the meetings, and Combustion Engineering will-formally respond to the final RAI within one month.

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Staff reviewers will be expected to complete their sections' of the SER within one more month so that e draft SER for each CESSAR submittal will be available within six months.

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7 DRAFT COPY If the NRC Staff believes a second round of RAIs is necessary, the same procedure will be followed, but it is expected that a shorter schedule will be used.

For the first round of RAls, the above schedule shows a 6 month review for each CESSAR submittal group.

If a second round of RAls is necessary, however, a total of nine months may be required.

8.6 CLOSURE OF OUTSTANDING ISSUES It is the intent of the System 80 Design Certification Program to assure that no open issues remain upon completion of the NRC Staff review so that System 30 can then proceed to Design Certification.

To this end, both the Staff and Combustion Engineering will provide a closure schedule for each outstanding issue compatible with the target date for the final SER.

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DPM T COPY 9.0 ACRS PARTICIPATION One step in the design review of a standard plant is the independent review by the Advisory Committee on Reactor Safeguards (ACRS). The

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NRC PM will keep the ACRS informed of the progress of the review by i

forwarding copies of CESSAR amendments as they are submitted, along with copies of the draft SERs as they are issued.

In addition, the NRC PM will schedule at least one meeting with the ACRS to discuss the final SER.

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y DRAFT COPYj 10.0 SEVERE ACCIDENT POLICY

10.1 INTRODUCTION

l On August 8, 1985, the Commission issued a policy statement on severe accidents (50FR32138, " Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants"). Also published was NUREG-1070, "NRC Policy on Future Reactor Designs."

The policy statement provides criteria and procedures for the licensing of new plants, and sets goals and a schedule for the systematic examination of existing plants. The Commission encouraged the development of new designs that might realize safety benefits and stated that the Commission intends to take all reasonable steps to reduce the chances of occurrence of a severe accident and to mitigate the consequences of such an accident, should one occur.

l The Commission's criteria for new plant designs, as set forth in the Policy Statement, are as follows:

(1) Demonstration of compliance with the procedural requirements and criteria of the current Commission regulations, including the Three Mile Island requirements for new plants as reflected in the construction permit rule, 10 CFR 50.34(f);

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1 DRAFT COPY (2) Demonstration of technical resolution of all applicable j

Unresolved Safety Issues and the medium-and high-priority Generic Safety Issues, including.a special-focus on ensuring the reliability of decay-heat removal ' systems and the reliability of both AC and DC electrical supply systems;.

(3) Completion of a probabilistic risk assessment (PRA) and consideration of the severe accident vulnerabilities that the PRA exposes, along with the insights that it may add to the

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assurance that there is no undue risk to public health and safety; and (4) Completion of staff review of the design with a conclusion of-safety acceptability using an approach that stresses deterministic engineering analyses and judgment complemented by PRA.

The Commission further recognized the need to strike a balance between accident prevention and consequence mitigation, through a better understanding of containment performance, with the understanding that new performance criteria for containment-systems might need to be established. The Commission also recognized the importance of potential contributors to severe accident risk such as 10-2 l

DRAN CON I

human performance and sabotage, and determined that these issues j

should be carefully analyzed and considered in the design and operating procedures for the facility.

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epecific discussions of the criteria, listed above, are presented in the following sections.

10.2 CP/ML REGULATION 1

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Combustion Engineering will comply with all regulations applicable to the System 80 standard design which are listed in 10 CFR l

50.34(f).

10.3 RESOLUTION OF USIs and GSIs Refer to Section 8.1 of this Licensing Basis Agreement for the resolution of USI's and GSI's.

10.4 PROBABILISTIC RISK ASSESSMENT 10.4.1 Scope (Later) 10-3

7 DRAFT COFY 10.4.2 Methodology (Later) 10.4.2 Acceptance Criteria (Later) l 10-4

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.j 11.0 ADDITIONAL ISSUES 1

11.1 INTRODUCTION

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As discussed in Section 2.1, Combustion Engineering's System 80

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standard design is currently " complete" in its design detail. With three units now in operation at the Palo Verde Nuclear Generating l

Station (each referencing the CESSAR FDA) Combustion Engineering's j

System 80 standard design has a unique sts Ming at the Nuclear Regulatory Commission. There are a number of specific issues, therefore, that need to be addressed.

11.2 DUAL DOCKET APPROACH 1

i NOTE:

Although the final decision rests with-the NRC -

Combustion Engineering recommends that the following approach be used for the extension of the System 80 design review.

There are now two utilities referencing the current CESSAR FDA. As a result, Combustion Engineering has recommended, and the NRC Staff agrees, that a second (separate) docket will be created which includes all of the existing information and history (including the i

existing Final Design Approval) of the current System 80 docket l

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.1 DRAFT COPY

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(STD-50-470).

It will be the second docket:which will be utilized 1

to achieve the Design Certification.

This approach will allow.

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I current System 80 users to reference the original docket'without the complication of design modifications that arise only as a result.of the System 80 Design Certification effort.

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i 11.3 SITE ENVELOPE PARAMETERS j

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1 The System 80 standard plant already includes.a site envelope which 1

has been found to be adequate to enable the' plant to be sited at most, if not all, US' sites.

[moredetaillater) 11.4 COMPLETENESS OF DESIGN

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CESSAR will _ include the results of sufficient engineering to close all NRC review issues. This will include, as appropriate:

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Design Basis Criteria 2.

Analysis and Design Methods

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Functional Design and Physical Arrangement i

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Plant Physical Arrangements Sufficient to Accommodate Systems and Components i

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DRAFT ODFY 5.

Functional / Performance Specifications for Components and Materials 6.

Acceptance / Test Requirements 7.

Risk Assessment Methodology i

1 Design documentation for systems, structures and components will include, as appropriate:

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Design Basis Criteria l

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Plant General Arrangements of Structures and Components l

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Process and Instrumentation Diagrams 4.

Contrcl Logic Diagrams 5.

System Functional Descriptions 6.

Component Performance Specifications including Acceptance Test Requirements 7.

Construction and Installation Specifications 11-3

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DRIJT COPY 8.

Supporting Design Documentation-l 9.

' Quality Assurance Program

10. Design Related Aspects'for the Emergency Plans l
11. Design Related Aspects of the Physical Security Program
12. ALARA/ Radiation Protection Plan 3
13. Accident Analyses 1
14. Referenceable Technical Specifications

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15. Probabilistic Risk Assessment I

Combustion Engineering will define tests, inspections,. analyses, and-acceptance criteria related thereto which are-necessary to assure j

that equipment is properly installed in the plant ~.

(These tests, inspections, analyses, and acceptance criteria can be implemented in; q

a series of sign-as-you-go reviews by the utility applicant through~

construction and pre-operation. The NRC Staff will monitor the performance of these reviews through its normal construction j

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DRAFT COPY inspection program).

Inla limited number of cases where detaile'd design data is not available,. information on methods, procedures, and acceptance criteria will be provided.

To summarize, the level of detail necessary for providing an sufficiently complete design will be that detail which is suitable for assuring conformance to NRC regulations (i.e., vendor / nameplate information is not required). The level.of detail will be

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sufficient to close out all NRC review issues.

11.5 INTERFACES In order to support a more comprehensive and efficient NRC Staff-review of the revised CES$AR chapters, the Interface Requirements:

(irs) will differ from the current CESSAR both in content and location within CESSAR. As compared with the current CESSAR, the individual IR's will be restructured to provide a much more detailed functional description of the non-CESSAR systems and they will be described in the appropriate sections of the SAR.

l Detailed descriptions of the interface requirements provided in CESSAR will reflect the assumptions relied upon to make safety i

determinations for the Htem 80 Nuclear Power Module. This. listing will identify the system., the I&C requirements, reliability

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,, _ S _x assumptions, anc' specific performance criteria.

Combustion Engineering will use the results of the PRA to indicate which interfaces are particularly sensitive to deviations.

11.6 IE BULLETINS I

t EPRI has agreed to include consideration of NRC bulletins in its 1

preparation of the EPRI ALWR Requirements Document.

i 11.7 SAFETY GOAL POLICY STATEMENT On August 4, 1986, the Commission published a Policy Statement on

" Safety Goals for the Operation of Nuclear Power Plants" (51 FR 28044). This policy statement focuses on the risks to the public from nuclear power plant operations.

Its objective is to establish goals that broadly define an acceptable level of radiological risk.

The Commission has established two qualitative safety goals that are supported by two quantitative objectives.

These two supporting objectives are based on the principle that nuclear risks should not be a significant addition to other societal risks.

The Commission has also made it clear that no death attributable to nuclear power plant operation will ever be " acceptable" in the sense that the Commission would regard it as a routine or permissible event.

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i The qualitative safety goals are:

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Individual members of the public.should be provided a:

level of protection from the consequences. of nuclear power l

plant operation so that individuals bear no significant additional risk to life and health.

l (2) Societal risks to life and health from nuclear power plant operation should be comparable to or-less than the risk of generating electricity by viable competing technologies and should not be a significant addition to other societal risks.

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The following quantitative objectives are to-be used in determining achievement of these safety goais:

(1) The risk to an average individual in the vicinity of a nuclear power plant of prompt fatalities that might result from reactor accidents should not exceed 0.1% of the' sum of prompt fatality risks resulting from other accidents to j

which members of the U.S.' population are generally exposed.

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DRAFT COPY (2) The risk to the population in.the area near a nuclear.

l power pl. ant of cancer fatalities. that might. result from nuclear power plant operation should not exceed 0.1% cf the sum of cancer fatality risks resulting from all other

-i Causes.

i The use of the quantitative health effects objective in the s

regulatory decision making process would require specific guidelines

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to use as a basis for determining whether a level.'of safety ascribed j

to a plant is consistent with the safety goal policy.

It is currently envisioned that this guidance from the NRC will address l

such matters as plant performance guidelines, indicators for operational performance, and guidelines for conduct of cost-benefit analyses. This guidance will be derived from additional studies conducted by the staff that result in recommendations to the Commission. The guidance will be based ~on the following. general performance guideline which has been proposed by the Commission for further staff examination:

i Consistent with the traditional-defense-in-depth approach and the accident mitigation philosophy' requiring reliable j

i performance of containment systems, the overall mean frequency I

of a large release of radioactive materials to the environment from a reactor accident should be less than 1 in 1,000,000 per year.of reactor operation.

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DRAFT COPY i

The implementation guidance that is developed by the staff will be applicable to the. System 80 design, consistent with 10CFR50.109.

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12.0 DESIGN CERTIFICATION

12.1 INTRODUCTION

The Commission strongly supports standardization. Although the i

option for licensing new custom plants remains, the Commission encourages the use of pre-approved standard plant designs in all

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future license applications.

The Commission believes that the use of pre-approved standard plant designs can benefit public health and safety by:

1.

Concentrating the resources of designers, engineers, and vendors on particular approaches; 2.

Stimulating standardized programs of construction practice and quality assurance; 3.

Improving the training of personnel; and 4.

Fostering more effective maintenance and improved operation.

The use of such pre-approved standardized designs can also permit more effective and efficient licensing and inspection by the NRC.

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12.2 FINAL DESIGN APPROVAL i

A.

Forward Referenceable FDA Amendment i

I In August 1985, Combustion Engineering officially requested i

that the CESSAR FDA be amended to permit forward.

referenceability in accordance with the NRC Severe Accident Policy Statement. Upon completion of NRC Staff review of that request, the Staff will issue a forward-referenceable FDA Amendment.

B.

Final FDA Amendment When the NRC Staff completes its review of System 80 improvements currently being implemented by Combustion.

Engineering, the FDA will be amended to document the closeout of all NRC review issues (in preparation for Design Certification). The Staff will then use and rely on the FDA and its Amendments in their reviews of future applications for construction permits and pre-approved operating licenses.

It is understood, however, that the FDA and its Amendments are still subject to challenge in individual licensing proceedings.

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a DRAFT COFif 12.3 DESIGN CERTIFICATION CONCEPT The design certification concept provides for certifying a reference system design, such as System 80, through rulemaking.

In this process the Commission would certify a design after rulemaking proceedings are completed. The Design Certification means that the.

System 80 standard design must be relied upon by the NRC Staff, hearing boards, and the Comission in their. reviews of applications that reference the design. A certified design would not be subject to challenge in individual licensing proceedings.

4 Under the Staff proposal, the Commission would certify the System 80 standard design for referencing by utilities for a period of.at least ten (10) years. Renewal of the Design Certification would be granted for an additional period of ten years unless the Commission finds that the design will not comply with the Commission's I

regulations. Utilities may reference the System 80 certified design in applications for cps and pre-approved Ols docketed'during the e

period beginning with the docketing date of CESSAR revisions and ending 10 years from the date of issuance of the Design Certification.

(If a CP is issued within the 10 year period, the-pre-approved OL is automatically covered by the Design Certification.)

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s 12.4 CHANGES TO APPROVED AND CERTIFIED DESIGNS j

l Standardization will be best achieved if changes to approved or 1

i certified designs are kept to a minimum.

Nevertheless, there are

{

situations in which changes may be needed or may be desirable.

For the Design Certification concept 10CFR50.109 will apply. The

)

Commission will require backfitting only when it determines, based upon the analysis required in 10 CFR 50.109, that a substantial increase in the overall protection of the public health and safety

]

or the common defense and security would be derived from the backfit and that the direct and indirect costs of implementation for the

" lead" unit are justified in view of the increased protection.

Combustion Engineering may request modifications to the certified design by applying for an amendment to the Design Certification and getting that modification certified.

Combustion Engineering shall be required to demonstrate that significantly improved performance would result from the requested change before staff approval is I

granted.

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12.6 RULEMAKING

)

Appendix 0 to 10 CFR 50 provides the opportunity for the Commission to approve the System 80 standard design in a rulemaking proceeding.

.]

Upon receipt of a request from Combustion Engineering, a. notice I

would be published in the Federal Register announcing the request i

for a Design Certification for the System 80. As a result of responses to the notice, or on its own initiative, the Commission may then decide to hold hearings on the proposed Design

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Certification.

1 The notice would set out the matters at issue, as specifically as possible, and would request that all persons wishing to participate in a hearing notify the Commission within 30 days. As a conditicin

)

to participating in a hearing, however, interveners would be required to state the issues they wish to have considered'at the hearing, and demonstrate the ability to provide expert testimony on those issues. Written comments and " Limited Appearances" would be invited from those not intending to participate in the hearing.

following any hearing, the Commission would review the complete record of the rulemaking, including both the hearing record and any i

other written comments. The notice of final rulemaking would have l

to include responses to written comments and the resolution of issues considered at a hearing.

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12.7 CERTIFICATION AND RENEWAL The Comission will certify the System 80 standard design for referencing by utilities for a period of 10 years. Additionally, not less than 30 days or more than 6 months before the expiration of the Design Certification, Combustion Engineering may apply for certification renewal. The Design Certification would be renewed for an additional period of 10 years unless a finding is made that the design does not comply with the Comission's regulations.

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