SECY-18-0093, VR-SECY-18-0093: Recommended Change to Verification of the Design Reliability Assurance Program
| ML19220A107 | |
| Person / Time | |
|---|---|
| Issue date: | 08/07/2019 |
| From: | Commissioners NRC/OCM |
| To: | Annette Vietti-Cook NRC/SECY |
| References | |
| SECY-18-0093 | |
| Download: ML19220A107 (6) | |
Text
UNITED ST ATES NUCLEAR REGULATORY COMMISSION WASHINGTON , D.C . 20555-0001 August?, 2019 SECRETARY COMMISSION VOTING RECORD DECISION ITEM : SECY-18-0093 TITLE: RECOMMENDED CHANGE TO VERIFICATION OF THE DESIGN RELIABILITY ASSURANCE PROGRAM The Commission acted on the subject paper as recorded in the Staff Requirements Memorandum (SRM) of August 7, 2019.
This Record contains a summary of voting on this matter together with the individual vote sheets, views and comments of the Commission.
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Secretary of the Commission
Enclosures:
- 1. Voting Summary
- 2. Commissioner Vote Sheets cc: Chairman Svinicki Commissioner Baran Commissioner Caputo Commissioner Wright OGC EDO PDR
VOTING
SUMMARY
- SECY-18-0093 RECORDED VOTES NOT APPROVED DISAPPROVED ABSTAIN PARTICIPATING COMMENTS DATE Chrm. Svinicki X X 07/31/19 Cmr. Baran X X 10/16/18 Cmr. Caputo X X 08/02/19 Cmr. Wright X X 08/01/19
NOTATION VOTE RESPONSE SHEET TO: Annette Vietti-Cook, Secretary FROM: CHAIRMAN SVINICKI
SUBJECT:
SECY-18-0093: Recommended Change to Verification of the Design Reliability Assurance Program Approved XX Disapproved --
Abstain - - Not Participating COMMENTS: Below XX Attached None I approve the staff's recommendation to discontinue the use of inspections, tests, analyses, and acceptance criteria - referred to as ITAAC - to verify the effectiveness of the design reliability assurance program (D-RAP) . While our predecessors who established the current implementation approaches to the certification of advanced light water reactors and the verification of compliance with the terms of combined licenses captured much wisdom in their thinking, they could not have foreseen every aspect of how the pieces of these processes would ultimately fit together in practice. Based on its current experiences, the staff has concluded that, when the D-RAP is fully described, the ITAAC related to D-RAP play no useful role and provide no substantive safety benefit. I approve the recommendation to discontinue their use.
IGNATURE 011? / 119 DATE Entered on "STARS" Yes _j_ No_
NOTATION VOTE RESPONSE SHEET TO: Annette Vietti-Cook, Secretary FROM: Commissioner Baran
SUBJECT:
SECY-18-0093: Recommended Change to Verification of the Design Reliability Assurance Program Approved X Disapproved --
Abstain --
Not Participating COMMENTS: Below X Attached None In this paper, the NRC staff recommends discontinuing the use of inspections, tests ,
analyses, and acceptance criteria (ITAAC) to verify the effectiveness of an applicant's design reliability assurance program (D-RAP). According to the staff, the scope of the D-RAP is fully described in both a design certification application and a combined license application . As a result, the staff has concluded that ITAAC for D-RAP "are unnecessary and provide little value ."
Based on my review of the single D-RAP ITAAC for the AP1000 design and other designs, I agree that the ITAAC is not necessary to verify the effectiveness of the D-RAP when the design certification application or combined license application al ready fully describes the program . For example, the substance of the AP1000 design D-RAP ITAAC is separately covered by NRC's quality assurance program requirements . I therefore approve the staff's recommendation .
Entered in "STARS" Yes X $(NATURE
/t:J/1' /1 J' No DATE
NOTATION VOTE RESPONSE SHEET TO: Annette Vietti-Cook, Secretary FROM: Commissioner Caputo
SUBJECT:
SECY-18-0093: Recommended Change to Verification of the Design Reliability Assurance Program Approved -X- Disapproved - - Abstain - - Not Participating COMMENTS: Below X Attached None In this paper, the staff seeks the Commission's approval to discontinue the use of inspections, tests, analyses, and acceptance criteria (ITMC) to verify the effectiveness of the design reliability assurance program (D-RAP). I agree with Commissioner Saran's assessment. The scope of the D-RAP and its implementation are fully described in the application for a design certification (DC) and again, modified as necessary, in each combined license (COL) application. Staff experience acquired from the reviews of several DC applications and the issuance of multiple COLs has demonstrated that the D-RAP ITMC are unnecessary, provide little value, and if maintained, would impose an unnecessary burden on COL holders and the staff, without commensurate safety benefit.
Based on the staff's information, I agree that ITMC are not necessary to verify the implementation of the D-RAP provided the program is fully described in design certification or combined license applications. Therefore, I approve the staff's recommendation .
In addition, as part of the ongoing Part 52 lessons learned project, the staff should assess whether there are efficiencies to be gained in the design reliability assurance program.
Entered in STARS Yes X Sig No Date
NOTATION VOTE RESPONSE SHEET TO: Annette Vietti-Cook, Secretary FROM: Commissioner Wright
SUBJECT:
SECY-18-0093: Recommended Change to Verification of the Design Reliability Assurance Program Approved X Disapproved Abstain - - Not Participating COMMENTS: Below X Attached None I approve the staff's recommendation to discontinue the use of inspections, tests, analyses , and acceptance criteria (ITAAC) to verify the effectiveness of the design reliability assurance program (D-RAP).
The staff determined that the D-RAP was fully described in design certification (DC) and combined license (COL) applications. The staff has also inspected the D-RAP at new reactor sites under construction and concluded that the program has been implemented in a manner consistent with the program description in the applications. Based on the results of its reviews and inspections, the staff concluded that the objectives of the D-RAP are already being accomplished and that the D-RAP ITAAC would therefore "impose an unnecessary burden on COL holders and the staff without commensurate safety benefit. " Discontinuing the use of the D-RAP ITAAC is also consistent with prior Commission direction . Specifically, the Commission previously directed that ITAAC for a program should not be necessary if the program and its implementation are fully described in the application and found to be acceptable by the NRC at the COL stage. Therefore , I approve the staff's recommendation to discontinue the use of the D-RAP ITAAC provided that the program is fully described in the application.
Entered in STARS Yes /
~ Signature
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No
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