Responding to Three Mile Island (TMI), NRC developed 10 CFR Part 52, the ‘Combined License’ (COL) process nearly thirty years ago. The COL’s Quality Assurance Program (QAP) requires that certified plant designs have a ‘Reliability Assurance Program’ (RAP) to assure Probabilistic Risk Assessment (PRA)-assumed reliability.
Unfortunately, Reg Guide 1.206 (NUREG-0800) Standard Review Plan (SRP) Section 17.4 guidance remains incomplete. As written, the existing SRP Design Control Document (DCD) guidance for Section 17.4 provides little reliability assurance for new certified designs.
An effective RAP for new nuclear plant is just a complete scheduled maintenance plan developed from consensus standards. For safety-related equipment, scheduled maintenance & operating monitoring plans can effectively assure equipment reliability.
Providing an effective, consensus standards-based scheduled maintenance program RAP for certified designs would lower new plant construction, startup and operating costs as well as improve nuclear safety.
New plant construction presents a unique opportunity to extend COL certified design standardizations to achieve higher levels of safety and cost performance.
NRC should ask industry to provide an effective RAP by specifying scheduled maintenance & operating monitoring plans to license new plant designs to implement Part 52. NRC should revise SRP Section 17.4 guidance to require an effective RAP as part of the design certification process.
U.S. airframe suppliers have similarly certified scheduled maintenance plans for commercial airframes for the past 42 years -- since the Boeing 747. (ref ML092800071.pdf, NRC letter August 29, 2009)