NUREG-1469, Submits Advanced Comments for Meeting of ABWR GE & ACRS Re NUREG-1469

Submits Advanced Comments for Meeting of ABWR GE & ACRS Re NUREG-1469

ML20056C488
Person / Time
Site:	05200001
Issue date:	11/10/1992
From:	Costner R Advisory Committee on Reactor Safeguards
To:	Elzeftawy M, Michelson C NRC
References
RTR-NUREG-1469 ACRS-CT-2051, NUDOCS 9306240260
Download: ML20056C488 (25)

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? C T- Ao si tw gm/n FILE = COL-ABWR.L01 LETTER on Review of COL Action items in NUREG-1469 TO: Mr. C. MICHELSON, Chairman, ABWR Subcommittee ATTENTION: Mr. Medhat El-Zeftawy US Nuclear Regulatory Commission MS-P315 Washington, DC 20555 FROM: R.A.COSTNER DATE: November 10, 1992 SUBJ: ADVANCE COMMENTS FOR THE MEETING OF THE ADVANCED BOILING WATER REACTORS (GE) SUBCOMMITTEE -- ACRS/NRC MEETING DATE(s): November 19-20, 1992 TOPIC: MEETING OF THE ADVANCED BOILING WATER REACTORS (GE) SUBCOMMITTEE - ACRS/NRC Ref: NUREG-1469, Draft Final Safety Evaluation Report Related to the Design Certification of the General Electric Nuclear Energy Advanced Boiling-Water Reactor Docket No.52-001 October 1992

1. At the end of the last subcommittee meeting in October, you suggested I review the ABWR SSAR Interface requirements to determine how the NRC Staff had dealt with these in their COL Action items.

2. This letter report documents the initial results of that review.

3. The results are contained in three attachments:

O Attachment 1, Review of Regulatory Requirements Applicable to The Future ABWR COL Applicant or Licensce O Attachment 2, Review of Regulatory Requirements Applicable to Quality Assurance During Construction (During the ABWR Subcommittee meeting on October 21,1992, a member questioned the coverage of quality assurance in Chapter 17 and in the NRC Staff Draft Final Safety Evaluation Report.)

O Attachment 3, Review of Regulatory Requirements Applicable to The Future ABWR COL Applicant or Licensee - Site Parameters DESIGNATED ORIGINM, 1 E7 b 9306240260 921110 230070 t\\

PDR ACRS

__CT-2051 P8@

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4 Attachment I deals with Interface requirements, ITAAC, and COL Action items and the associated regulatory requirements. I

5. Attachment 2 concerns information I found as I was reviewing the regulatory requirements for the other issues.

6. Attachment 3 deals with how the site parameters are treated in Interface requirements and COL Action items. (The applicable regulations explicitly address the particular site proposed by a ABWR COL Applicant or Licensee.

Site requirements are the only such topic explicitly addressed. Therefore, those requirements provide unique insight as to the intent of the applicable  !

regulations and as to how GE and the NRC Staff treat them.) l 1

7. There is repetition in the last section of Attachment I and 3 since they both contain the applicable regulations; however, I didn't anticipate they would be in the same section in both attachments.

8. The results of this review are based on 2, Site Characteristics, and of a small amount of 3, Design of Structures, Components, Equipment, and System.

Thus, the results are subject to revision. However, based on this preliminary review I believe the results (Attachment 1, Section 5, Conclusions, and -

Attachment 3, Section 4, Conclusions) demonstrate some significant shortfalls between the requirements of the regulations and the performance to date by the NRC Staff and to a lesser extent by GE.

9. Some key requirements of the regulations can not be demonstrated to date.

Absent the capability to make such demonstrations, it is difficult to understand how the NRC could withstand a legal challenge at either the Design Certification stage or the COL stage. Any opposing group could demonstrate that the results of the NRC Staff evaluation were not in compliance with the regulations.

10. Prior to the meeting on November 19-20, 1992, I will try to have completed the remainder of the reference; however, that review will be in considerable less depth than this one.

Attachment 1 Attachment 2

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Attachment 3 2

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- FILE = COL-A BWR. A01 - November 10,1992 Attachment 1 '!

Review of Regulatory Requirements .;

Applicable to The Future:

t ABWR COL Applicant or Licensee

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1. IntroductiDG  !

1.1 The future ABWR COL Applicant or Licensee is responsible for demonstrating.

compliance 'with the requirements in the Tier 1 and Tier 2 (ABWR SSAR) and in the DFSER which are within the scope of the ABWR as covered by design ,

certification. l 1.2 The - regulations (i.e., 10 CFR ~ Part 52, Subpart B--Standard LDesign Certifications, and Appendix 0 to Part 52 --Standardization of Design; Staff

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Review of Standard Designs) explicitly cover -' two sets .of secondary requirements for which 'the future ABWR COL Applicant or' Licenseee is responsible. 1 O Interface requirements (ABWR SSAR)

O ITAAC (Tier 1) .

1.3 As the ABWR proceedings have developed there is at least one other set of 1 secondary requirements for which the future ABWR COL Applicant or Licensee g is responsible: '

O COL Action items (DFSER) -l 1.4 . The purpose of the notes in this attachment is to discuss and evaluate:

O Interface requirements, ITAACs,. and COL Action 11tems and their relationship to each other-

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O The associated responsibilities and performance of the General Electric. 1 Company as sponsor the application for certification of a standard design,  ;

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O The associated responsibilities and performance of the NRC Staff. j i

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2. Discussion of Applicable Regulations 2.1 The regulations (see Section 7., below) invoke two of the three of what I have referred to as secondary requirements as follows:

/Ref 2.2/ - definition of ITAAC

/Ref 2.3/ - definition of Interfaces requirements

/Ref 2.4/ - criteria for Interfaces requirements

/Ref 2.5/ - justification of adequacy of ITAACs to demonstrate compliance with Interfaces requirements

/Ref 2.6/ - method of verification of Interfaces requirements to be in ITAACs

/Ref 3.1/ - description, analysis and evaluation of Interface requirements

3. Compliance with the Regulations -- Interface requirements 3.1 The responsibilities of the sponsor of the application for certification of a standard design is (as a minimum) to propose Interface requirements which meet the quoted regulations.

3.2 Absent notice by the NRC Staff (or ACRS) of deficiencies in the interface requirements provided in the SSAR, the General Electric Company (as sponsor of the application for certification of the ABWR standard design) appears to comply with the quoted regulations.

There are, however, some instances in which interface requirements are identified but not explicitly identified as Interface requirements. See for example:

O Section 3.3.3.3 of the ABWR is an Interface section but not formally identified by GE as such.

O The requirement in Section 3.4.3.4 of the ABWR is an Interface section but not formally identified by GE as such.

O The requirement in Section 3.6.4 of the ABWR is an Interface section but not formally identified by GE as such.

3.3 The associated responsibility of the NRC Staff is to evaluate the Interface requirements proposed by the sponsor and to determine the adequacy of those Interface requirements to meet the quoted regulations.

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3.4 The NRC Staff is implicitly evaluating the Interface requirements during i evaluation of the SSAR chapters which include sections identified as interface requirements.

3.5 Absent notice by the ACRS (or the public) of inadequacies in Interface requirements on which the NRC Staff has clearly overlooked, the NRC Staff j appears to comply with the quoted regulations as they pertain to evaluation of'  !

Interface requirements. (There are, however, some indications based on a l

prelimina.y review of the DFSER that in general the NRC Staff has, officially at  !

least, ignored the existence of the Interface requirements as presented in the SSAR.) l

4. Comoliance with the Regulations -- ITAAC 4.1 The responsibilities of the sponsor of the application for certification of a standard design to propose ITAAC which meet the quoted regulations is not as clear as is the responsibility to propose Interface requirements. (The intent of the regulations  !

quoted may be that the NRC Staff was intended to assume a more active role in the proposal of ITAAC.)

l in fact, one provision of the regulations /Ref 2.8/ appears to place the primary I responsibility for preparation of ITAAC on the NRC Staff:

1 The information submitted for a design certification must include performance requirements and design information sufficiently detailed to cermit the preoaration of acceolance_and insoection reauirements by the BBC, and procurement specifications by an applicant. [ Emphasis Added]

4.2 However, in the past the role of the NRC Staff vis-a vis an applicant has always been characterized by an iterative process; both parties have, in effect, interacted to develop licensing material which complies with regulations and regulatory positions, etc.

4.3 In the case of ITAACs, however, both parties appear to fall short of fulfilling their implied responsibilities.

4.4 The General Electric Company (as sponsor of the application for certification of the ABWR standard design) has clearly proposed draft versions of ITAAC in the Tier 1 document. However, GE hasn't complied with the requirement to provide justification of adequacy of ITAACs to demonstrate compliance with Interfaces requirements; see [Ref 2.5/.

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4.5 in fact the GE proposed ITAAC in the ABWR Tier i document are not structured to parallel the Interface requirements in the ABWR SSAR. The interface requirements are structured to relate to the Standard Format for SARs in both content and identification numbering. The ITAAC are structured to relate to plant systems and to plant-wide issues as identified and defined by GE independent of the Standard Format for SARs.

4.6 Thus not only does GE not justify the adequacy of ITAACs to demonstrate compliance with Interfaces reauirements but also there isn't a clear one-for-one relationship between a given interface requirements and a corresponding ITAAC.

In other words justification is neither clearly demonstrated nor easily inferred.

4.7 At this stage the application for certification of the ABWR as a standard design is clearly in non-compliance with the reculations in the area of ITAACs. There is no evidence as to the mechanism by which GE/NRC will document a justification (i.e., " justify the adequacy of ITAACs to demonstrate compliance with Interfaces requirements") of the ITAAC.

4.8 To date this reviewer has seen no drafts of NRC Staff evaluations of the ITAACs in the ABWR Tier i document, Therefore, this reviewer has seen no direct evidence of NRC Staff performance in this area.

4.9 However, as stated in item 3.5, above, there are, indications based on a  ;

preliminary review of the DFSER that in geneml the NRC Staff has not officially taken notice of the existence of the Interface requirements as presented in the SSAR. Rather than documenting the results of their evaluation of the Interface requirements associated with a group of associated SSAR sections, the NRC Staff has chosen to establish their own aooarently indeoendent interface requirements  ;

and designated these as COL Action item. l 1

4.10 Section 6., below, provides as an example a comparison of the differing SSAR/NRC Staff treatment of Interface Requirements.

4.11 At this point in this discussion we should note that the regulation explicitly covers i only (1) Interface requirements and (2) inspection, testing, analysis, and i acceptance criteria. COL Action items and ITAAC (using that acronym) are not  !

explicitly covered; however, "!TAAC" is certainly reasonable to use as if that acronym were covered and all parties seem to concur in its use.

The " inspection, testing, analysis, and acceptance criteria" is included in three different forms:

O " tests, inspections, analyses, and acceptance criteria" [Ref 2.2/;

O " inspection, testing, or analysis" [Ref 2.Sf; and Al-4 l

O " tests, inspections, analysis, and acceptance criteria" /Ref 2.6/.

4.12 However, the intent of the regulation seems clear in one respect; the " inspection, testing, analysis, and acceptance criteria" are intended to be specific requirements to be met by the COL Applicant or Licensee.

For example, /Ref 2.2/ states: " Proposed tests, inspections, analyses, and acceptance criteria which are necessary and sufficient to provide reasonable assurance that, if the tests, inspections and analyses are performed and the acceptance criteria met, a plant which references the design is built and will operate in accordance with the design certification."

5. Conclusions 5.1 For the intent of the regulations to be met there must be a demonstration of a mature degree of completeness of evaluation at the Design Certification stage.

5.2 At present it isn't clear that the NRC Staff plans to treat the ABWR SSAR Interface requirements as candidates for ITAAC. (See Attachment 3.)

5.3 At present it isn't clear that the GE/NRC Staff plans to provide a justification of 1 the adequacy of ITAAC to demonstrate compliance with the ABWR SSAR  !

Interface requirements. l 5.4 The nature of the COL Action items reviewed to date (Attachment 3) is that rather than demonstrating essentially final review they generally demonstnte the  ;

standard pre-FSAR approach used in the past for custom reviews. This in turn tends to demonstrate that the NRC Staff lacks confidence in the capability of the process involving Interface requirements arxi ITAAC 1

5.5 Absent the capability to make such demonstrations, it is difficult to understand how the NRC could withstand a legal challenge at either the Design Certification stage or the COL stage. Any opposing group could demonstrate that the results l of the NRC Staff evaluation were not in compliance with the regulations.

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6. Comnarison of SSAR/NRC Staff treatment of Interface Requirements 6.1 As an example, the ABWR SSAR provides the following sections:

1 3.5.1 Missile Selection and Description 3.5.1.1 Internally Generated Missiles (Outside Containment) 3.5.1.2 Internally Generated Missiles (Inside Containment) 3.5.1.3 Turbine Missiles l 3.5.1.4 Missiles Generated by Natural Phenomeru Al-5 4

3.5.1.5 Site Proximity Missiles (Except Aircraft) 3.5.1.6 Aircraft Haze.rds 3.5.2 Structures, Systems, and Components to be Protection from Externally Generated Missiles 3.5.3 Barrier Design Procedures < < o. 3-23 > >-

3.5.4 Interfaces Section 3.5.4, Interfaces, provides the Interface requirements to be met by the ABWR COL Applicant or Licensee for the entire Section 3.5, Missile Protection, topic structured as follows:

3.5.4.1 Interfaces applicable to Section 3.5.2.

3.5.4.2 Interfaces applicable to Section 3.5.1.4.

3.5.4.3 Interfaces applicable to Section 3.5.1.6.

3.5.4.4 Interfaces applicable to Section 3.5.1.2.3.

3.5.4.5 Interfaces applicable to Section 3.5.1.4.

6.2 The NRC Staff in the DFSER documents the staff's evaluation of sections 3.5.1, 3.5.2, and 3.5.3 in DFSER sections numbered 3.5.1, 3.5.2, and 3.5.3.

However, the staff documents no recognition of Section 3.5.4, Interfaces.

6.3 The NRC Staff establishes their own interface requirements and designated these as COL Action items. These COL Action items are not by design equivalent to the SSAR Interface requirements. These COL Action items appear in their respective sections (i.e.,3.5.1, 3.5.2, and 3.5.3) with corresponding COL Action Item identification numbers and the existence of the SSAR Interface requirements is not acknowledged by the NRC Staff.

7. Aonlicable Regulations

/RefIf i 52.45 Filing of applications (c)(1) ... a final design approval under Appendix 0 of this part is a prerequisite for certification of a standard design ....

/Ref2/ i 52.47 Contents of applications.

(a) The requirements of this paragraph apply to all applications for design certification.

(1) An application for design certification must contain:

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/Ref 2.1/ (iii) The site parameters postulated for the design, and an analysis and evaluation of the design in terms of.

such parameters;-

/Ref2.2/ (vi) Proposed tests, inspections, analyses,c and:

acceptance criteria which L are _ necessary 4 and sufficient to provide reasonable assurance that, if:

the tests, inspections and analyses .are ' performed and the acceptance criteria meti.a' plant which; references the design'is. built and will_ operate in' H accordance with the design certification.

/Ref2.3/ (vii) The interface requirements to be met by those .

portions of the plant for which um application'does .I not seek certification.'

/Ref2.4f (vii)(continued)

These requirements must be sufficiently detailed to allow completion of the' final safety analysis and design-specific probabilistic' risk assessment required by paragraph (a)(1)(v) of L this section;

/Ref2.51 (viii) Justification that ' compliance with1 the interface requirements.of paragraph (a)(1)(vii) of this section is verifiable through inspection, testing (either in the plant or elsewhere), or analysis.

. [Ref 2.61 (viii)(continued)

The method to be used for verification of interface requirements must be included as; part - of the '

proposed tests, inspections, analysis, and acceptanc'e .

criteria required by paragraph (a)(1)(vi) _of this

, section; and -

/Ref 2.71 (1) An application fl.e., an appikartonfor design cempcaion

- RACf must contain a level of design information sufficient '-

-to enableithe Commission to; judge ..the? applicant's -

proposed means of assurance that construction conforms to the design and to_ reach a fiaal enaclusion on all 'safetv queions associ=W with the <kign before the certification is granted.' [ Emphasis Added)

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/Ref2.8/ (1) (continued)

The information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and insoection recuirements by the NRC, and procurement specifications by an applicant. { Emphasis Added]

/Ref 2.9/ t3) The staff shall advise the applicant fi.e., an applicantfor design certification - RAC/ on whether any technical information beyond that required by this section must be submitted.

/Ref2./0/ 5 52.63 Finality of standard design certifications.

(a)(4) Except as provided in 10 CFR 2.758, in making the findings required for issuance of a combined license or operating license, or for any hearing under i 52.103, the Commission shall treat as resolved those matters resolved in connection with the issuance or renewal of a design certification. [ Emphasis Added]

/Ref3/ Appendix 0 to Part 52 --Standardization of Design; Staff Review of Standard Designs

3. The submittal for review shall include ....

/Ref 3.1/ The submittal shall also include a description, analysis and evaluation of the interfaces between the submitted design and the balance of the nuclear power plant.

/Ref 3.2/ With respect to the requirements of 65 50.34(a)(1) of this chapter, the submittal for review of a standard design shall include the i site parameters postulated for the design, and an analysis in terms of such postulated parameten.

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FILE = COL-ABWR. A02 November 10, 1992

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Attachment 2 Review of Regulatory Requirements Applicable to Quality Assurance During Construction Introduction

1. During the ABWR Subcommittee meeting on October 21, 1992, a member questioned the coverage of quality assurance in Chapter 17 and in the NRC Staff Draft Final Safety Evaluation Report. Specifically, he questioned the lack of coverage of quality assurance during the construction activities.

2. The Staff /GE response was that coverage of quality assurance during construction involved activities in the future; that coverage would be the responsibility of the COL Applicant or Licensee.

3. In answer to that response the member noted that Operations (which was even further in the future) was covered.

Discussion of Apolicable Reculations

1. The primary applicable regulation,10 CFR Part 52, Subpart B--Standard Design Certifications, for the ABWR proceedings states in part:

5 52.45 Filing of applications (c)(1) ... a final design approval under Appendix 0 of this part is a prerequisite for certification of a standard design ..

2. Appendix O to Part 52 -Standardization of Design; Staff Review of Standard Designs, states in part:

3. The submittal for review shall include ....

The information submitted pursuant to il 50.34(a)(7)' of this chapter, shall be limited to the quality assurance program to be applied to the design, procurement and fabrication of the structures. systems. and comoonents for which design review has been requested .... [ Emphasis Added]

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Attachment 2 Review of Regulatory Requirements Applicable to Quality Assurance During Construction (continued):

Conclusions

1. Coverage of quality assurance during the construction activities (" fabrication of the structures, systems") is explicitly required by the applicable regulations.

2. Presumably this requirement could be satisfied by Interface (s), COL Action item (s), or ITAAC(s) rather than a section similar to that provided for operations. l i

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FILE = COL-ABWR. A03 November 10,1992 Attachment 3 Review of Regulatory Requirements Applicable to The Future ABWR COL Applicant or Licensee Site Parameters

1. Introduction 1.1 The applicable regulations explicitly address the particular site proposed by a-ABWR COL Applicant or Licensee.

1.2 Site requirements are the only tooic explicitly addressed.

.3 1.3 Therefore, those requirements provide unique insight as to the intent of these j applicable regulations.  ;

2. Discussion of Anolicable Reculations i 2.1 The regulations (see Section 7., below) explicitly address the particular_ site ,

proposed by a ABWR COL Applicant or Licensee as follows: j

/Ref 2.lf (iii) The site parameters postulated for the design, and an analysis and evsluation of the

. design in terms of such parameters; j

[Ref3.2] With respect to the requirements of il 50.34(a)(1) of this chapter, the submittal for review of a standard design shall include the site parameters postulated for the design, and an analysis in terms of such postulated parameters.

2.2 Thus, the. regulations do not explicitly address Interface requirements and

" inspection, testing, analysis, and acceptance criteria" (or ITAAC) applicable to the actual site.

.2.3 However, having required "the site parameters postulated for the design, and an analysis and evaluation of the design in terms of such parameters" it is hardly reasonable to suppose that such parameters, analysis, and evaluation.were tas A3-1

intended to provide the basis for associated Interface requirements and ITAAC.

2.4 It is more reasonable to suppose, if the site was to be excluded from the requirements for Interface requirements and ITAAC, that exclusion would have been explicitly stated. Note that "The interface requirements to be met by those portions of the plant for which the application does not seek certification * /Ref 2.3/ would certainly include the site.

2.5 One provision of the regulation /Ref 2.8/ appears to place the primary responsibility for preparation of ITAAC on the NRC Staff:

The information submitted for a design certification must include performance requirements and design information sufficiently detailed to oermit the prenaration of accentance and insnection requirements by the HRC, and procurement specifications by an applicant. [ Emphasis Addedj 2.6 It further seems evident that the intent of the regulations is to be able to demonstrate a mature degree of completeness of evaluation at the Design Certification stage.

O /Ref 2.7 / to reach a final conclusion on all safetv questions associated with the desien before the certification is granted.

[ Emphasis Added]

O /Ref 2.8 / a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of accentance and insoection requirements by the NRC, and procurement specifications by an applicant. [ Emphasis Added]

O /Ref 2.10J the Commission shall treat as resolved those matters resolved in connection with the issuance or renewal of a design cenification. [ Emphasis Added]

3. Comoarison of SSAR/NRC Staff treatment of the Site 3.1 The ABWR SSAR provides:

O Section 2.0, Summary, (references Table 2.0-1, which defines the envelope of site-related parameters which the ABWR Standard Plant is designed to accommodate.)

O Section 2.1, Limits Imposed on SRP Section II Acceptance Criteria by ABWR Standard Plant O Section 2.2, Requirements for Determination of ABWR Site Acceptability, A3-2

i and O Section 2.3, interfaces.

1 See Section 5, below.

3.2 The NRC Staff provided COL Action items 2.1.1-1 through 2.5.4-15-1 to address I information to be supplied by the COL Applicant or Licensee regarding the site characteristics.

3.3 The NRC Staff provided in section 2.6, Site Parameter Envelooe, of the DFSER (NUREG-1469) comments concerning ABWR SSAR Table 2.0-1. See Section 6., below.

3.4 However, the NRC Staff's approach to these issues appears to treat the COL Action Items completely separate from the Interface requirements, in addition the NRC Staff report is silent concerning ITAAC which should flow from COL Action items and Interface requirements.

3.5 in addition, how ABWR Section 2.2 interrelates with the COL Action items, etc.

isn't clear. Depending on the legal standing of the Tier 2 document it would appear necessary for the Staff to include the requirements of ABWR Section 2.2 and 2.3 in a COL Action item.

3.6 Since Interface requirements are explicitly covered by the regulations and COL Action item are not, it is possible that ABWR Section 2.3 could take legal precedence over the COL Action Items.

3.7 It is possible that some requirements in ABWR Section 2.3 could conflict with -

some of the COL Action items 2.1.1-1 through 2.5.4-15-1. If so, legal precedence of ABWR Section 2.3 could preclude the NRC Staff from enforcing some of the COL Action Items.

4. Conclusions 4.1 The NRC Staff appears to be following a " business as usual" approach in that many of the COL Action items are consistent with the traditional " bring me a rock" information requests.

4.2 There is no evidence in Section 2, Site : Characteristics, of the DFSER (NUREG-1469) that the NRC Staff intends to comply with the intent of the regulations.

4.3 If the remainder of the DFSER (NUREG-1469)is consistent with the NRC Staff approach in Section 2, there is little indication that the NRC Staff intends to A3-3

4' demonstrate a mature degree of completeness of evaluation at the Design Certification stage. (See item 2.6, atmve.)

4.4 Absent the capability to make such a demonstration, it is difficult to understand how the NRC could withstand a legal challenge at either the Design Certification stage or the COL stage. Any opposing group could demonstrate that the results of the NRC Staff evaluation were not in compliance with the regulations.

5. ABWR SSAR Treatment of Interfaces Anolicable to Site NOTE: The numbering of sections and subsections within this portion of these notes (e.g., 2.0, 2.1, 2.3.1.1) is that of the ABWR SSAR.

ABWR SSAR Chapter 2 Interfaces 2.0 SUMM ARY [ Amendment 16]

This section defines the envelope of site-related parameters which the ABWR Standard Plant is designed to accommodate. These parameters envelope most potential sites in the U.S. A summary of the site envelope parameters is given in Table 2.0-1. (Table 2.0-1 is Amendment 21]

2.1 LIMITS IMPOSED ON SRP SECTION II ACCEP'TANCE CRITERIA BY ABWR ' STANDARD PLANT / Amendment 16]

This section defines limits imposed on SRP Section 11 acceptance criteria by (1) the envelope of ABWR Standard Plant site design parameters given in Table 2.0-I and (2) the assumptions, both implicit and explicit, related to site characteristics employed in the evaluation of the ABWR design. These limits are presented in -

Table 2.1-1 for the following five SRP Section 11 categories of site characteristics.

(1) Geography and Demography; (2) Nearby Industrial, Transportation and Military Facilities; .

(3) Meteorology; (4) Hydrology Engineering; (5) Geology, Seismology and Geotechnical Engineering.

See subsection 2.3 for interface requirements.

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/ Table 2.1-1 consists offourpages asfollows:

page 2.1-2 is Amendment 6 page 2.1-3 is Amendment 9 page 2.1-4 is Amindment 9 page 2.1-5 is Amendment 20]

2.2 REQUIREMENTS FOR DETERMINATION OF ABWR SITE ACCEPTABILITY / Amendment 16/

This section provides the requirements for the determination of ABWR site acceptability. Acceptability is required from the standpoint of both design bases events and severe accident.

2.2.1 Design Bases Events {too lengthy to quote here}

2.2.2 Severe Accidents {too lengthy to quote here}

Table 2.2-1 Dose Related Goals [ Amendment 15]

Table 2.2-2 CRAC 2 Data input Listing / Amendment 15/

2.3 INTERFACES [ Amendment 18] {too lengthy to quote here}

2.3.1 Envelope of Standard Plant Design Parameters 2.3.1.1 Non-Seismic Design Parameters 2.3.1.2 Seismic Design Parameters 2.3.2 Standard Review Plan Characteristics 2.3.3 CRAC 2 Computer Code Calculation APPENDIX 2A INPUT TO CRAC 2 COMPUTER CODE FOR DETERMINATION OF ABWR SITE ACCEPTABILITY

[APPENDEX 2A consists of17 tables on pages 2A-1 through 2A-46 asfollows:

page 2A-1 through 2A-10is Amendment 20 page 24-11 through 2A-15 is Amendment 22 page 2A-16 through 2A-46 is Amendment 20]

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6. COL Action Items Applicable to Site 6.1 COL Action item 2.1.1 The COL applicant shall provide site-specific information related to site location, including political subdivisions, natural and man-made features, population, highways, and other significant features of the area. (These topics appear to be properly treated and don't appear adaptable to Interface requirements and ITAAC.)

6.2 COL Action Item 2.1.2 The COL applicant shall provide site-specific information related to activities that may be permitted within the designated exclusion area. (This topic appears to be adaptable to Interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.3 COL Action item 2.1.3 The COL applicant shall provide population data for the site environs. (This topic appears to be adaptable to Interface requirements ,

and ITAAC in the form of bounding population within specified adjacent areas. l The NRC Staff should justify failure to do so.) 1 6.4 COL Action Item 2.2.1 The COL applicant shall provide information with  ;

respect to industrial, military, and transportation facilities and routs to establish

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the presence and magnitude of potential external hazards. (These topies appear to be properly treated. Because these topics cover such ' exceptional" issues, it probably could be argued that treatment in Interface requirements and ITAAC isn't cost beneficial.)

6.5 COL Action Item 2.2.3 The COL applicant shall identify potential accident situations in the vicinity of the plant and the bases for which these potential accidents were or were not accommodated in the design. (This topic appears to be adaptable to Interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.6 COL Action Item 2.3.1-1 .... Therefore external impact hazards will have to be reviewed on a site specific basis. (This topic appears to be adaptable to Interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.7 COL Action Item 2.3.2 Since local meteorology is specifically site related, the staff will review local meteorology for individual applications referencing the ABWR design on a case-by-case basis. (This topic appears to be adaptable to Interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.8 COL Action Item 2.4.5 The COL applicant shall provide the basis for the hydraulic design of canals and reservoirs used to transport and impound plant cooling water and for protection od safety-related structures. (These topics appear A3-6

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to be properly treated. Because these topics cover such

• exceptional" issues, it probably could be argued that treatment in Interface requirements and ITAAC isn't cost beneficial.)

6.9 COL Action item 2.4.6 The COL applicant shall provide site-specific information related to channel diversion. (These topics appear to be properly treated. Because these topics cover such " exceptional" issues, it probably could be argued that treatment in Interface requirements and ITAAC isn't cost beneficial.)

6.10 COL Action item 2.4.7 The COL applicant shall provide site-specific information related to flooding protection requirements. (This topic appears to be adaptable to Interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.11 COL Action Item 2.4.8 The COL applicant shall identify natural events that may reduce or limit the available cooling water supply and ensure that an adequate water supply will exist to operate or shut down the plant as required. (1 won't try I to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.12 COL Action Item 2.4.9 The COL applicant shall provide information on the  !

ability of the surface water environment to disperse, dilute, or concentrate I accidental releases. Effects of these releases on existing and known future use of surface water resources shall also be provided. (These topics appear to be l properly treated. Because these topics cover such " exceptional" issues, it I probably could be argued that treatment in Interface requirements and ITAAC l isn't cost beneficial.) l 6.13 COL Action Item 2.4.10 The COL applicant shall establish the technical specifications and emergency procedures required to implement flood protection l for safety-related facilities and provide assurance of an adequate water supply to shutdown and cool the reactor. (These topics appear to be properly treated and l don't appear adaptable to Interface requirements and ITAAC.) j 6.14 COL Action Item 2.5.1 The COL applicant shall provide site-specific information related to regional and site physiography, geomorphology, stratigraphy, lithology and tectonics. (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.15 COL Action item 2.5.2 The COL applicant shall provide site-specific information related to seismicity, geologic, and tectonic characteristics of the site and region, correlation of earthquake activity with geologic simeture or tectonic A3-7

provinces; maximum earthquake potential; seismic wave transmission characteristics of the site; safe shutdown earthquake (SSE), and operating basis earthquake (OBE). (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

3 6.16 COL Action item 2.5.3 The COL applicant, therefore, should develop site-specific information to ensure that no potential exists for surface faulting affecting the site. (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.17 COL Action item 2.5.4 The COL applicant shall demonstrate. that the envelope of structural response with fixed soil depth will cover completely the cases for which the soil deposit depths and properties are different from that in the SSAR. (This topic appears to be adaptable to Interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.18 COL Action Item 2.5.4.1 The COL applicant will provide a detailed description of the site conditions and geologic features and demonstrate the site characteristics are enveloped by the 0.3g horizontal peak ground acceleration (PGA) for the SSE. The description will include. site topographical features and the ' location of various Category I structures and appurtenances (pipeline, channels, and so forth) with regard to the source of normal and emergency cooling water. (Some aspects of this topic appear to be adaptable to Interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.19 COL Action item 2.5.4.2 The COL applicant shall discuss the type, quantity, extent, and purpose of all field exploration. Logs of all borings and test pits . .

(These topics appear to be properly treated. Because these topics cover such

" exceptional" issues, it probably could be argued that treatment in Interface requirements and ITAAC isn't cost beneficial.)

6.20 COL Action item 2.5.4.3 The COL applicant shall provide tables of the number and type of laboratory tests and the location of samples and discuss the results of laboratory tests on disturbed and undisturbed soil and rock samples obtained from field investigations. (I won't try to make a judgement; however, I sotne aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.21 COL Action Item 2.5.4.4 The COL applicant shall investigate and define the

' subsurface conditions and provide .... The COL applicant shall define in detail the static and geotechnical engineering properties used for validating the design ..

(I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

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6.22 COL Action Item 2.5.4.5 The COL applicant shall provide site-speci6c soil thickness and properties (if any) between the base of the foundation and the underlying rock. .... The COL applicant shall discuss, as appropriate, excavating and dewatering methods, .. (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.23 COL Action Item 2.5.4.6 The COL applicant shall analyze the ground water condition for tie specific site and demonstrate its compatibility with the ABWR  !

design e.csumptions. . .. (This topic appears to be close to being framed as Interface requirements much of which could be drafted as an ITAAC. The NRC Staff should justify failure to do so.)

6.24 COL Action Item 2.5.4.7 The COL applicant shalljustify the selection of the soil properties used in the liquefaction potential evaluation .... (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.25 COL Action Item 2.5.4.8 The COL applicant shall establish and document site-specific geotechnical properties and to demonstrate their compatibility with the conditions used for the seismic design envelope discussed in Section 3.7.2 of this report. (This topic appears to be close to being framed as Interface requirements much of which could be dmfted as an ITAAC. The NRC Staff should justify failure to do so.)

6.26 COL Action Item 2.5.4.9 The COL applicant shall provide the site-specific maximum soil pressures along with the supporting calculations and compare them with the allowable values. (This topic appears to be close to being framed as Interface requirements much of which could be drafted as an ITAAC. The NRC Staff should justify failure to do so.)

6.27 COL Action item 2.5.4.10 The COL applicant shall provide a discussion and evaluation of static and dynamic lateral carth pressures and hydrostatic ground l pressures acting on plant facilities to the extent necessary and demonstrate that these pressures meet the design bases for the ABWR and to address all facilities outside the ABWR scope. (This topic appears to be close to being framed as l Interface requirements much of which could be drafted as an ITAAC. The NRC Staff should justify failure to do so.)

1 6.28 COL Action Item 2.5.4.11 The COL applicant shall provide and justify the l

soil properties used for the seismic analysis of seismic Category I buried pipes and electrical conduits. (Some aspects of this topic appear to be adaptable to Interface 1 requirements and ITAAC. The NRC Staff should justify failure to do so.) l A3-9

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6.29 COL Action Item 2.5.4.12 The COL applicant shall analyze all safety-related facilities to the extent necessary to demonstrate that their stability meets the ABWR design bases and to address all plant facilities outside the ABWR scope.

Them analyses may include ... Assumptions made in stability analyses shall be confirmed by as-built data. (Some aspects of this topic (e.g., " meets the ADWR design bases *} appear to be adaptable to interface requirements and ITAAC. The NRC Staff should justify failure to do so.)

6.30 COL Action Item 2.5.4.13 The COL applicant shall describe instrumentation, if any, proposed for the surveillance of the performance of the foundations for safety-related structures. .... The COL applicant shall discuss, as appropriate, excavating and dewatering methods, excavation depths below, .... (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.31 COL Action Item 2.5.4.14 The COL applicant shall provide information about the static and dynamic stability of all soil and rock slopes, the failure of which could adversely affect the safety of the plant. The staff will evaluate the stability of all slopes at the site, using the state-of-the art orocedures available at the time of anolication. (Emphasis Added - So much for a Standard Design!] (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.32 COL Action Item 2.5.4.15 The COL applicant shall provide information about the static and dynamic stability of all embankments and dams that impound water required for safe operation (and shutdown) of the ABWR design if embankments and dams are used. (I won't try to make a judgement; however, some aspects of this issue appear to be adaptable to Interface requirements and ITAAC.)

6.33 This concludes the COL Action Items in the DFSER (NUREG-1469) which are applicable to Site Characteristics. There is no indication that the NRC Staff intends to convert any of the COL Action items into ITAAC.

6.34 In section 2.6, Site Parameter Envelooe, of the DFSER (NUREG-1469) the staff provided comments concerning ABWR SSAR Table 2.0-1. (This is the envelope of ABWR Standard Plant site design parameters.) There is no indication that the NRC Staff intends to consider coverage of any content of ABWR SSAR Table l 2.0-1 as ITAAC. l 1

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7. Applicable Regulations

/Ref // i 52.45 Filing of applications (c)(1) a final design approval under Appendix 0 of this part is a prerequisite for cenification of a standard design ..

/Ref2/ 5 52.47 Contents of applications.

(a) The requirements of this paragraph apply to all applications for design cenification.

(1) An application for design certification must contain:

/Ref 2.// (iii) The site parameters postulated for the design, and an analysis and evaluation of the design in terms of such parameters;

/Ref 2.2/ (vi) Proposed tests, inspections, analyses,- and acceptance criteria which are necessary and sufficient to provide reasonable assurance that, if the tests, inspections and analyses are performed.

and the acceptance criteria met, a plant which references the design is built and will operate in accordance with the design cenification.

/Ref2.3/ (vii) The interface requirements to be met by those portions of the plant for which the application does not seek certification.

/Ref2.4/ (vii)(continued)

These requirements must be sufficiently detailed to allow completion of the final safety analysis and design-specific probabilistic risk assessment required by paragraph (a)(1)(v) of this section;

[Ref2.5J (viii) Justification that compliance with the interface requirements of paragraph (a)(1)(vii) of this section is verifiable through inspection, testing (either in the plant or elsewhere), or analysis.

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/Ref2.6/ (viii)(continued)

The method to be used for verification of interface requirements must be included as part of the proposed tests, inspections, analysis, and acceptance criteria required by paragraph (a)(1)(vi) of this section; and

/Ref 2.7/ (1) An application li.e., an applicationfor design cenification

- RA C/ must contain a level of design information sufficient to enable the Commission to judge the applicant's proposed means of assurance that construction conforms to the design and to reach a l' mal conclusion on all safety questions associated with the design before the certification is granted..[ Emphasis Addedl

/Ref 2.8/ (1) (continued)

The information submitted for a design certification must include performance requirements and design information sufficiently detailed to nermit the orecaration of accentance and insnection recuirements by the NRC, and procurement specifications by an applicant. [ Emphasis Added]

/Ref 2.9/ (3) The staff shall advise the applicant [i.e., an applicantfor design cernpcation - RAC/ on whetber any technical information beyond that required by this section must be submitted.

/Ref 2.10/ 5 52.63 Finality of standard design certifications.

(a)(4) Except as provided in 10 CFR 2.758, in making the findings required for issuance of a combined license or operating license, or for any hearing under i 52.103, the Commission shall treat as resolved those matters resolved in connection with the issure or renewal of a design certification. IEmphasis Added)

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/Ref3/ Appendix 0 to Part 52 --Standardization of Design; Staff Review of Standard Designs

3. The submittal for review shall include ....

/Ref 3.1/ The submittal shall also include a description, analysis and evaluation of the interfaces between the submitted design.

and the balance of the nuclear power plant.

/Ref3.2/ With respect to the requirements of 65 50.34(a)(1) of this chapter, the submittal for review of a standard design shall include the site parameters postulated for the design, and an analysis in terms of such postulated parameters.

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