NUREG-0906, Request for OMB Review & Supporting Statement Re NUREG-0906, Guidance for Implementation of SRP Rule, Per 10CFR50.34(g) Amend.Estimated Respondent Burden Is 11,500-h Annually

Request for OMB Review & Supporting Statement Re NUREG-0906, Guidance for Implementation of SRP Rule, Per 10CFR50.34(g) Amend.Estimated Respondent Burden Is 11,500-h Annually

ML20027C706
Person / Time
Issue date:	10/19/1982
From:	Norry P, Scott R NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20027C703	List: NUREG-0906, Request for OMB Review & Supporting Statement Re NUREG-0906, Guidance for Implementation of SRP Rule, Per 10CFR50.34(g) Amend.Estimated Respondent Burden Is 11,500-h Annually
References
RTR-NUREG-0906, RTR-NUREG-906 OMB-3150-0011, OMB-3150-11, NUDOCS 8210270111
Download: ML20027C706 (19)

Text

n RE2UEST FOR OMB REVIEW (drid:t ths P:pstwork R: duction Act and Encutiv Ord:t 12291)

Imp rt:nt - Raad instructi:ns (SF-83A) befora completing this Office of Information and Regulatory Affairs form. Submit the recurrednumber of copies of SF 83,together Offsce of Management and Budget with the materiel for which review is requested to:

Washington. D C. 20503

1. Dipirtment/ Agency and Bureau / Office originating request 3.Name(s) and telephone number (s) of person (s) who can best U.S. Nuclear Regulatory Commission 2.6-digit Agency / Bureau number (firstpart of 11-digit Treasury

4. 3-diget functional code (last part of 11-digit Treasury Account Account No.)

No.)

3 1

5 0

_2_ l_ _fL 5 Tstle of,tntormatson Collection or Rulemaking C. Is this a rulemaking submsssion under Section 3504th) of 6-5117 (Check otte)

NUR$G-0906 Guidance for Implementation of N (Secuen 3sor subrnission) the Standard Review Plan Rule, 10 CFR 2O Yes,NPRM. Expecteddate of publication:

50.34(d. Amnrimmt

6. A.ls enyinformation coIIe 'r'1n (reporting or recordkeeping) 3 O Yes, final rute. Expected date of pubhcation:

involved ? (Check one)

Effective date:

1 g( Yes and proposal is attac'ied for review D. At what phase of rulemakingis this submission made?

2 0 Yes but proposat is not attached - skip to question D.

3 O No - skip to Question D.

1 O Not applicable B. Ars the respondents primarily educationalagencies or 2 0 Major rufe at NPRM stage institutions oris the purpose related to Federaleducation 3 O Maior Final rule for which no NPRM was published programs ?

4 d( Major Final rule, after publication of NPRM O Yes C5 No 5 O Nonmajor rule, at NPRM stage 6 O Nonmajor ruls, at Final stage COMPLETE SHADED PORTION IF INFOrlMATION COLLECTION PROPOS ALIS ATTACHED

7. Current (or former) OMB Number

8. Requested

12. Agency r_eport form number (s)

~

~

' ' ~ ~

3150-0011 Expiration Date NA Expiration Date

13. Are respondt.nts only Federal agencies?

4/30/85 4/30/85

9. ls proposed information collection listed in

14. Type of request (Check one) ths information collection budget?

O Yes 0! No 1 O preliminary plan

10. Will this proposed information collection 2 E new (notprpvrouslyapproved or expiredmore than 6 months

~.. - -

cause the agency to exceed its information ago) collection budget allowance? (Ilyes, attach O Yes IX No 3 0 revision Smendment request from agency head.)

4 0 extension (adjustment to burden only)

11. Number of report forms submitted for approval 5 0 extension (no change) t 6 0 reinstatement (expired wsthin 6 months 1 1 S.

16. Classification of Change in Burden (explain in supporting statement) e f.ppronirrete size of umvsrse t r sampses NA No of Responses No of Reporting Hours Cost to the Public NA

a. in inventory 8,423 5,833,004 8

e sm ov sam"

c Estimat+d number of

b. As proposed 8,426 5,821,504 s

re5 pond 1nts or record %,$ ov ve.,

3

c. Ditference (b-a) 3

-11,500 d n2 ports encue'ry ey each Explanation of difference (indicate as many as apply) rsspond3nt relem 25J Adjustments o Totatsanuatresponses taem roc n f 5W

. i 16 d Correction-error I

3

+

+

+

t tie. mated e e age s

e. Correction-reestimate numbe< of hours 4

+

+-$

f. Change in use

(-)3,812 ev eess,se Progrcm changes 0 E stimitso total hours

{8"""{b u'd'" '"

g. Increase

+

3

+

500

+s

'"*"'6"

(-)ll,500

h. Decrease 12.000

-S 8210270111 821020 Standard Form 83 (Rev. 3 81)

PDR ORG EUSOMB For Use Beginning 4/1/81 PDR

17

• bstract-tieeds and uses (50 worqs or(sss) fiRC regulations, sp~ecifically 10 CFR 50.34(g), requires the documentation and evaluation of differences between certain reactor license applications and the acceptance criteria of the Standard Review Plan (flUREG-0800). The proposed " Guidance for Implementation of the Standard Review Plan Rule" discusses the evaluation required, provides a suggested format, and gives illustrative examples.

18 Pelated report form (s) (give OMB number (s),IRCN(s),

20. Catalog of Federat Domestic Assistance Program Number onternal agency report form number (s) or symbol (s))

g4g 10 CFR

21. Small business or organization O Yes 1No

19. Type of affected public (Check as many as apply)

22. Type of activity of affected public-indicate 3-digit Standard 1 O individuals orhouseholds Industrial Classification (SIC) code (s) (up to 10) - if over Io. check O Multiple or O All 2 O state orlocalgovernments 3 O farms 4 C( businesses or otherinstitutions (except farms)

A O

3 23 Brief description of af fected public le g,"retailgrocery stores."" State education agencies.' " households in 50 largest SMSA s")

flew applicants

24. Purpose (Check as many as apply. If more than one. indicate

26. Collection method (Check as many as apply) predominant by an asterisk) 1 CX mail self-administered t rg application for benefits 20 other self-administered 2 O program evaluation 30 telephoneinterview 3 O general purpose statistics 4 O personalinterview 4 $ regulatory or compliance 50 recordkeeping requirement:

5 O program planning or management Required retention period:

years 6 O research 6 0 other-describe:

25 Frequency of Use

27. Collection agent (Check one) 1 i5 Nonrecurring 1 [X requesting Department / Agency Recurring (check as many as apply) 2 O other Federal Department / Agency 2 O on occasiort E O semiannually 3 O private contractor 3 0 weekly 70 annually 4 O recordkeeping requirement 4 O monthly 80 biennially 5 O other-describe:

5 O Quarterly 90 other-describe:

28. Authority for agency for information collection or 30 Do you promise confidentiality?

rulemaking-indicate statute, regulation. judicial decree.

(IIyes. explain basis for pledge etc.

in supporting statement.)

O s

IX No 10 CFR 50.34(g)

I31. Will the proposed information collection create a new or become part of an existing Privacy Act system of records?

29 Resnondent's cbhgation to repty (Check as manyas apply)

(11 yes. attach Federal Register notice orproposed draft of I D voluntary notice )

O Yes 10 No 2 D required to obtain or retain benefit

32. Cost to Federal Government of 3 O mandatory-cite statute. not CFR (attach copy of information collection or rulemaking S 14.000 statutory authority)

COMPLETE ITEMS 33 THRU 35 ONLY IF DULEM AKING SUBMISSION 33.Comphance costs to the public l 34 is there a regulatory impact 35 Is there a statutory or judicial analysis attached?

deadhne affecting issuance?

O Yes O No O Yes. Enter date O No CERTIFIC ATION BY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify that the information collection or ru:emaking submitted for feview is necessary for the proper performance of the agency's functions, that the proposa.! represents the minimum public burden and Federal cost Consistent with need, and is consistent with applicabfe OMB and agency pokcy directives Signature and title of.

APPHOvhG FoyCv ^F riC' At 8GRA3 DATE SUBuit T:NG OF 8 eCI AL DATE C (NCY8/

NbF Patr' cia G. 11orry

/C[

R S p n c 2_

e

t e

i SUPPORTING STATEMENT FOR

" Guidance for Implementation of the Standard Review Plan Rule (10 CFR 50.34(g)) NUREG-0906",

1.

JUSTIFICATION The Nuclear Regulatory Commission (NRC) is authorized by Congress to have responsibility and authority for the licensing and regulation of nuclear power plants.

To meet this responsibility, the NRC conducts a detailed review of all applications for licenses to construct and operate such facilities.

In March 1982, the NRC adopted a final rule, 50.34(g), which requires that applicants for a construction permit (CP), operating (FDA) license (0L), preliminary design approval (PDA), or final design approval provide, as part of the material currently required by 10 CFR 50.34, an evaluation of the differences from the Standard Review Plan (NUREG-0800) acceptance criteria, for those applications docketed after the effective date of the rule.

NUREG-0906, the subject of this statement, is proposed guidance to applicants to assist them in complying with the rule.

The Standard Review Plan (SRP) reflects the NRC's detailed interpretations of the acceptable means to satisfy the applicable regulatory requirements, which assure that the proposed facilities can be constructed and operated without

~

any undue risk to the health and safety of the public. Because of limited resources, the NRC staff conducts audit reviews of the Safety Analysis Reports (SARs) submitted in accordance with an application, in accordance with the review procedures in the SRP.

The material currently found in SARs does not lend itself to ready identification of the differences from the SRP acceptance criteria. These -

differences are often found in responses to staff questions or during meeting discussions.

Consequently, a concern has been raised regarding the thoroughness of the staff's review and the degree to which the plants conform to the applicable regulatory requirements.

Differences from the SRP acceptance criteria do not necessarily imply nonconformance with regulatory i

requirements; however, they do reflect a departure from accepted practice l

that should receive a thorough staff review.

The objective of the requirement contained in 10 CFR 50.34(g) and of the implementing guidance of NUREG-0906 is to allow the limited NRC staff resources to quickly focus on those areas involving differences from the SRP acceptance criteria in order to make the most effective use of the staff's resources.

Experience has shown that such differences usually involve issues l

of safety significance and require the greatest amount of time to resolve.

i Since the applicants are intimately familiar with thei'r plant's designs, they are in a better position to identify the differences from the SRP acceptance criteria during the normal course of preparing the technical supporting information for an application.

~ The proposed guidance document provides a discussion of the character of issues that ought to be evaluated under the requirement of the rule, a suggested format and illustrative examples of such evaluations. The use of the suggested format is not mandatory and it, like the entire guidance document, is intended to assist applicants in conforming to the rule with a minimum of additional effort.

Applicants are currently performing a similar documentation on an elective basis by complying with the " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," Regulatory Guide 1.70, Revision 3.

This regulatory guide indicates a format and content for SARs that is acceptable to the NRC staff. The SARs contain the technical information to support an application for a construction permit, operating license, or design approval.

Conformance with Regulatory Guide 1.70 is not required; however, SARs using an alternate format and content are more likely to be regarded as incomplete and, subsequently, would be rejected during the acceptance review of an application. Thusfar, the applicants have readily volunteered the information outlined in Regulatory Guide 1.70 in order to ensure an expeditious review by the staff. The proposed guidance provides a suggested format and content guide for addressing the requirements of the SRP rule.

If this guidance is issued in final form, it will be ' incorporated in the next revision of Regulatory Guide 1.70.

s As previously stated, Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," provides guidance for the technical information to be provided in support of an application. When this l

guidance document is approved in final form, the NRC. staff will administratively amend Regulatory Guide 1.70 to provide detailed guidance regarding the format and content of the documentation to be provided and to eliminate duplicative information.

The guidance document will delete one item currently treated in Regulatory Guide 1.70.

Presently, Section 1.8 of Regulatory Guide 1.70 calls for a discussion of each applicant's conformance with all applicable regulatory guides. This section of Regulatory Guide 1.70 will be replaced with the format guidance for compliance to the SRP rule. This represents a substantial reduction in paperwork burden since the pre"ent section calls for an affirmative discussion of how compliance with applicable regulatory guides is achieved.

Under the new guidance, discussion is limited to analysis of only the regulatory guide sections identified in the SRP acceptance criteria and of these, only the sections where a non-conformance is identified.

A variety of industry and utility organizations provided comments on the original version of the proposed SRP rule (45 FR 67099).

(As the subject guidance document adds no substantive burden beyond th'e fundamental SRP rule, no additional consultations were sought).

l l

SN w-

a 1 2.

DESCRIPTION The rule will affect all new applications for cps and PDAs, and no More than 13 OL applications for which cps have already been issued and 11 FDA applications for which PDAs have already been issued.

Over the next three year period, the NRC expects no new CP applications and no more than one PDA and eight OL applications which would be affected by this rule.

The rule requires a one-time submittal for all applications docketed after the effective date of the rule, and the Commission has directed that the effective date should be May 17, 1982. The first affected application is expected to be docketed in about October 1982. The NRC expects the documentation to be provided in the SARs submitted with a tendered application; however, for the early affected applications, the staff would accept an amendment to the SAR that is submitted on a schedule commensurate with the staff's review.

Since the underlying rule is effective now and published guidance is not available, the NRC will now accept any reasonable format. After the guidance document is approved in final form, the staff will continue to accept any reasonable alternatives for a period of about one year after the effective date. This will avoidsan undue burdcn on applicants who must begin to prepare their safety analysis during the comment period.

s There is no requirement for a separate report; the reporting requirement is satisfied by additional information in the SAR, a document required as part of the application. The filing requirements for an application including the SAR and distribution of copies was approved by OMB as part of the 10 CFR 50 clearance 3150-0011 expiring-April 30, 1985.

3.

ESTIMATE OF BURDEN The guidance document generates no new, different, or expanded burden over that generated by the fundamental SRP rule. That burden was discussed in detail in the supporting statement for 10 CFR 50.34(g) and was approved by OMB on May 13, 1982 under clearance 3150-0011.

The review of NUREG-0902 and incorporation of the format suggested in the guidance document may result in an additional administrative burden to applicants estimated at one person-month per applicant. The removal of the Regulatory Guide 1.70 section 1.8 requirement discussed above to affirmatively discuss compliance with the regulatory guides results in a reduction in burden estimated by the NRC staff of two person-years per l

applicant.

The combination of the above two items results in a reduction in i

burden per applicant of 23 person-months.

As.,noted above, the staff expects nine applicants in the next three years to come under this rule and guidance document or an average of three per year.

At a fully turdened cost of

$140,000 per person-year, the net result of this guidance document is a reduction in burden of $805,000 per year and 11,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> annually.

l

r

. 4.

GOVERNMENT COST i

The intent of the rule and this guidance is to make more effective ose of the exiting NRC staff resources.

Thus, the long-term resource burden to the NRC staff will be essentially nil. However, approximately one person-month of effort was required to prepare the guidance document and publish it in the Federal Register. Another person-month may be required to incorporate comments and publish the final version. This represents a cost of $14,000.

's 4

4

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f!VCLEAR REGULATORY COMMISSI0il

~

10 CFR Part 50 Proposed Guidance for Implementation of Standard Review Plan Rule AGErlCY:

fluclear Regulatory Conmission.

ACTI0ft:

Request for public comments; notice of proposed guidance for the implementation of SRP rule.

SUMMARY

The Commission published a final rule in the Federal Register on March 18, 1982 (47 FR 11651), entitled "Conformance with the Standard Review Plan (SRP)." This rule requires certain applicants for nuclear power plant operating licenses, construction permits, and standard plant design approvals to include an evaluation of the differences between the proposed facility and the SRP acceptance criteria in their application.

In the notice accompanying the,.. rule, the Commission indicated that guidance documents being developed by the staff to implement the rule would be published for public comment.

This notice presents the staff's recommended

" Guidance for Implementation of 10 CFR 50.34(g)" (flVREG-0906) and invites comments, suggestions, or recommendations on the content of the proposed guidance.

DATES:

Comment period expires [ Leave blank and include date instructions in transmittal memo to SECY].

Comments received after that date will be considered if it is practical to do so, but assurance of consideration cannot be given to comments other than those filed on or before that date.

4

4

-22 ADDRESSES: Written comments, suggestions, or recommendations should be sent to the Secretary of the Comission, U.S. fluclear Regulatory Commission, Washington, D.C.

20555, Attention: Docketing and Service Branch. Copies of comments received may be examined at the NRC Public Document Room, 1717 H Street, N.W., Washington, D.C.

FOR FURTHER INFORMATION CONTACT:

Robert A. Purple, Deputy Director, Division of Licensing, Office of Nuclear Reactor Regu1'ation, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555(301)492-7425.

SUPPLEMENTARY INFORMATION:

Guidance for Implementation of 10 CFR 50.34(g)

[NUREG-0906, For Co'rEent]

s I.

Background

On March 17, 1982, the NRC published a final. rule. in the Federal Regi. ster (47 FR 11651) entitled "Conformance with the Standard Review Plan (SRP)."

This rule requires certain applicants to include in their applicati'o'n an evaluation of all design features, analytical techniques, and procedural methods proposed for a nuclear power facility that are different from those given in the acceptance criteria of the Standard Review Plan (NUREG-0800).

The facilities covered under this rule are those for which an application for an operating license, construction permit, manufacturing license, or preliminary or final design approval for standard plants is docketed after May 17, 1982.

The affected applicants are required to provide an evaluation of the facility against the acceptance criteria of the SRP in effect on May 17,1982(NUREG-0800)orthemostrecentrevisionoftheSRP in effect six months prior to the docketing date, whichever is later.

- ~. - -. -

.n In particular, the applicants are required to identify and describe all differences in design features, analytical techniques, and procedural methods proposed and those corresponding features, techniques, and methods identified in the SRP acceptance criteria. Where those differences exist, an evaluation is r5 quired that discusses how the proposed alternatives provide an acceptable method of complying with the NRC regulations which underlie the corresponding SRP acceptance criteria. The SRP is not a substitute for the regulations, and compliance with it is not required.

It defines methods that are acceptable to the staff for satisfying the relevant regulations and is used by the staff in its evaluation of whether an applicant meets the requirements of NRC regulations.

II. Guidance for Implementation of 10 CFR 50.34(g), NUREG-0906 This document provides guidance for describing the identified differences from the SRP and provides. example evaluations of such differences.

.T.h e Commission invites comments, suggestions, or recommendations on the content of the proposed guidance.

The staff considers these examples to be' acceptable in technical content and level of detail if all other related technical issues have been resolved to the satisfaction of the staff.

These particular examples were chosen to present a range of types of l

differences and acceptable evaluations.

They are not intended to circumscribe an applicant in the type or scope of evaluation to be l

l presented. Applicants are encouraged to meet with the staff during the preparation of their applications to resolve any questions concerning the SRP acceptance criteria.

It should be noted that while the particular examples given may be applicable and acceptable in a number of specific applications, they may not be applicable or acceptable for all applications because of specific design or site characteristics.

4_

Applicants should include the evaluation required by the SRP Rule in Chapter 1 of their Safety Analysis Reports (SARs) at the time of submitting the SAR. An SAR is required to be included in applications by 10 CFR 50.34(a)or(b)oftheCommission'sregulations.

Guidance for the preparation of SARs is currently available in Regulatory Guide (RG) 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants - LUR Edition," (Revision 3). A future revision of RG 1.70 will identify the specific section of the SAR in which the information required by the SRP rule is to be included.

Section 1.8 of Chapter 1 of RG 1.70 currently calls for a description of the extent to which an applicant intends to comply with all applicable regulatory guides and any proposqd exceptions to the regulatory positions in those guides.

Until RG 1.70 is revised, applicants should retitle Section 1.8 "Conformance With the Standard Review Plan," and should include therein the information described below, rather than that which is presently called for in RG 1.70.

In Section 1.8 of the SAR, applicants should identify and describe, preferably in tabular format, all differences in design features, l

analytical techniques, and procedural measures proposed for a facility and I

those corresponding features, techniques, and measures given in the SRP acceptance criteria. The information should include:

(1) identification of the relevant section of the SRP, (2) a brief summary of the specific SRP criteria for which a difference exists, (3) a summary description of the l

I

nature of the difference, and (4) a page number or subsection reference that identifies where the issue is explicitly evaluated in the SAR.

The required discussion of how each proposed alternative provides an acceptable 4

method of complying with the applicable regulation should be included in the relevant section of the SAR.

The specific acceptance criteria in the SRP are presented as Subsection II of each SRP section.

Subsection II also identifies the underlying regulations for that feature of the facility. Applicants are not required to address the other subsections of each SRP section. These other subsections (Areas of Review, Review Procedures, Evaluation Findings, Implementation, and References) are intended for gse by the staff in conducting its review, and provide a basis on which the staff concludes that the specific feature, technique, or measure meets the acceptance criteria. Applicants may find the material in these other subsections useful in identifying and e aluating differences from the specific acceptance criteria.

l The " evaluation" required by 550.34(g)(2) consists of (1) a review of the proposed design against the applicable specific' SRP acceptance criteria, j

with the results of the review (i.e., any differences) being identified and described, preferably in tabular format, in Section 1.8 of the SAP,as discussed above; and (2) a discussion of each difference in the applicable SAR section that presents the reasons for concluding t, hat the proposed difference is an acceptable method of ccmplying with the regulations.

The specific SRP acceptance criteria are guidelines that define a method i

l

- 6L acceptable to the staff for satisfying the relevant regulations. They are not requirements per se, and other methods can be found acceptable by the staff as long as compliance with the underlying regulations is

~

demonstrated.

In some instances, however, the specific SRP acceptance criteria are identical to the requirements of the regulations.

For these situations the applicant should include in the evaluation required by 550.34(g)(2) a discussion that represents the reasons for concluding that the proposed difference is acceptable from a safety standpoint.

In addition, an application for an exemption from the regulations providing s

all the information needed to make the findings required under 950.12 of the Comission regulations should be separately submitted by the applicant.

~

The following examples show how the above inform'ation should be presented:

i~

i i

1.8 Differences from SRP Acceptance Criteria.

- (Applicant) has reviewed the (plant name) and concludes that it will I

meet all applicable specific acceptance criteria in the Standard

,/

Review Plan (NUREG-0800), except as noted below. The cited text s

references in the following table include discussions that describe the basis by which (applicant) concludes that the underlying i

f regulatory requirements have been satisfied in those instances for which there are differences from the SRP.

0 1

s 4 -* ese i

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.._.y.

7_,

_,,.,yy._.-.,

_,_,,,.,x,

, -,.._ _., _,,,,,,____r,_

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Table 1.8.1 Summary of Differences From SRP Specific SRP Summary SAR Section SRP Acceptance Description of Where Section Criteria Difference Discussed 5.3.1 II.6.c.(1)-

Surveillance specimens 5.3.1.6.2 (Rev.1)

Surveillance not taken from actual specimens production plates 6.2.4 II.c. and d.-

Manually operated 6.2.4.3.2 (Rev.2)

Containment containment isolation isolation valves provisions for CRD withdraw lines 15.4.6 II.S.b. -

Operator action 15.4.6.2 (Rev. 1)

Operator action, within 13 minutes in a boron dilution event during hot standby, minimum time 15 minutes Discussion in SAR Section 5.3.1.6.2 RPV Material Surveillance Test Specimens (excerpt 1/)...AcceptancecriterionII.6.c.(1)ofSRPSection5.3.1 provides that the material for surveillance test specimens representing the reactor vessel beltline welds be prepared from actual production plates.

This criterion is derived from Appendices G and H ll In this and the other examples that follow, the material presented.

is an excerpt from a section of the SAR assumed to have been developed in accordance with Regulatory Guide 1.70. Thus, the examples have been prepared.on the assumption that complete and adequate information on technically related features of the plant is available in the SAR provided by the applicant.

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to 10 CFR Part 50, which requires that surveillance specimens be taken from locations alongside fracture toughness test specimens and that fracture toughness specimens for the reactur vessel beltline region to be taken directly from excess material and welds in the vessel shell courses.

l The welding test specimens for (plant name) will be prepared from i

plates of the same "p" number and, same filler material, as those used in the corresponding actual shell material. The welding conditions will be the same for the test specimens and the production welds, and the qualification procedures conform to the requirements of NB 4330 of the ASME Code.

- s.

s Based on these similarities between the belt line region test samples and production materials, the technical requirements of Appendix H are satisfied since this provides equivalent test specimens for the

/

material surveillance program for the reactor pressure vessel.

S/ ote that an exemption to the regulatio'n (Appendix H to 10 CFR N

Part 50) would be required in this instance, and that a request for the exemption should be submitted separately by the applicant.

S.* wee g

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1 9_

6.2.4.3.2 Containment Isolation Design Basis for CRD Withdraw Lines (excerpt)... In SRP Section 6.2.4, acceptance criterion II.d.-

provides, in part, that the isolation provisions for lines used in systems neede'd for safe shutdown of the plant that penetrate primary containment and are part of the reactor coolant pressure boundary nonna11y consist of one automatic isolation valve inside and one automatic isolation valve outside of containment. Acceptance criteria II.c. states that remote-manual valves may be used instead of automatic valves for such lines, provided that provisions are made to detect possible leakage from the lines outside containment. The underlying regulation for these criteria ls' General Design Criterion (GDC) 55 which requires such containment is'olation provisions unless it can be demonstrated that other provisions are acceptable on some other defined bases.. - -

The Control Rod Drive (CRD) withdraw lines penetrate the primary containment and communicate with the reactor coolant pressure boundary (RCPB) through the CRD assemblies.

However, as can be seen in Figure 4.6 the CRD assemblies are composed of a series of seals and l

l mechanical restrictions, so that the CRD withdraw lines r'epresent a l

unique kind of extension of the RCPB as defined in 10 CFR 50.2(v).

l Because of the unique function and features of these lines, the usual automatic or remote-manual isolation valves are not provided.

ll :,,

10 _

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's

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w' Specifically,. contrary to the SRP acceptance criteria describe;i above, the CRD withdraw lines are provided with manually operated isolation valves as' described in Table 6.2.4-X 'instead of automatic or i

remote-manual isolatio,n valves, and there are no specific provisions r se 7

for detection.of leakage from these lines outside the containment.

+

Autcinatic or remote-manual isolation valves are not used fiAce the~CRD systemperformsanessentialsafetyfunctionandtheaddiinof f

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automatic isolation capability could compromise that safety function.7 t

Moreover, since leakage from any break in one of the CRD withdraw li$1es is withih the capabilities of the reactor coolant makeup systems i

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r (Feedwater and RCIC), the risk associated with having an automatic or

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remote-manual isolation valve fail closed in th'ese lines 49 efore i

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ichileving a successful reactor scram in emergeni:y. situations'.hould

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4 si ex"ceed the risk [aspeciatedpiQ not isolating such a line should it.."#

a a _ ;....

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rupture.

In addition, the CRD withdraw litics are designed to high

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quality standards as described in Section 3.2.2 and the preservice x

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5.2.5-X will asiuEe that the #1delihood and cc3 sequences of breaks in %

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the CRD withdraw lines are smal[1. The leakage ~ monitoring capabilities j

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i referred to include:

(a) CRD high temperatbre alarms, (b) [RD t;i c.

s position indication, (c) Elevel instruments in the secondary.\\. s AV s

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containmentsump,and(d) area,cadiatiohmonitorsthatindicqteAnd l

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alarm in the' control room.

Sh6ufd primary system water begin flouh

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A out of a broken CRD withdraw line, these monitors will provide the operator with timely information that would permit effective corrective actions.

The design features described above constitute an "other defined basis" of acceptability of the containment isolation provisions for theCRDwithdrawlines,aspermittedbyGDC55.2/

15.4.6.2 Boron Dilution Events During Hot Standby (excerpt).... In Section 15.4.6, acceptance criterion II.S.b specifies

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that if operator action is required during hot standby to terminate a transient resulting from a boron dilution event, a minimum time period of 15 minutes must be available between the time the first alarm annunicates to alert. t_he operator, and th.e t_ime that all shutdov{n margin is lost and criticality occurs. The underlying regulatory requirements for this acceptance criterion are GDC 10,15 and ':26 which I

ccliectively require that the reactor core, reactor coolant and associated auxiliary systems, reactivity control systems, and the i

reactor protection system be designed with appropriate margin to assure that specified acceptabh fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded during any condition of normal operation, including anticipated operational occurrences.

2/ ote that in this instance an exemption to the regulation is not N

required.

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i The technical specifications for the (plant name) will require that the reactor be shutdown by at least 2% k/k (i.e., K,ff = 0.98) while in hot standby. Our analysis of the most limiting boron dilytion event during this operational mode, described in Section 15.2.4, assumes an initial reactor shutdown condition of this amount.

It was also assumed that all control rods are withdrawn in order to max the initial boron concentration and subsequent dilution effects.

Approximately 13 minutes after the dilution begins, a high source range count alarm, which is set at twice the initial source level, would occur.

Our analysis then shows that 13.4 minutes would be available for the operator to take appropriate action to terminate the boron dilution event between the time of annunication of this 3

alarm and the time of reaching criticality.s The difference between the calculated minimum operator action time to terminate this event (13.4 min.) and the SRP acceptance criterion (15 min.) is small, and the reliability of the 5ource range count alhrms is high since they

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are redundant and of high quality, as described in Section 7.4.1.X.

lie conclude, therefore, that for the most limiting baron dilution event during hot standby, the relevent portions of GDC 10,15 and 25 are satisfied since fuel damage limits and the design conditions of the reactor coolant pressure boundary will not, with considerable margin, be exceeded during this event.

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r PAPERWORK REDUCTION ACT STATEMENT:

Prior to publication of the final versionoftheguidancedocument(NUREG-0906),thereportingportionshave been submitted to the Office of Management and Budget for clearance as required by the Paperwork Reduction Act of 1980 (Pub. L 96-511).

LIST OF SUBJECTS IN 10 CFR PART 50 Antitrust, Classified information, Fire prevention, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting requirements.

The Authority Citation for this document is:

Sec. 161, Pub. L.83-703, 68 Stat. 948, as amended (42 U.S.C. 2201).

s Dated at Washington, D.C., this day of

, 1982.

For the Nuclear Regulatory Commission.

1 I

i Samuel J. Chilk, Secretary of the Commission.

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• ese I

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