ML20042D327
| ML20042D327 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1989 |
| From: | Pohle J NRC |
| To: | Justus P NRC |
| Shared Package | |
| ML20042D326 | List: |
| References | |
| NUDOCS 9001080287 | |
| Download: ML20042D327 (1) | |
Text
l EMwSC I DEC 2 o tseg 5
l
~
NOTE TO:
P. Justus FROM:
J. Pohle i
i
SUBJECT:
REVIEW OF PROPOSED TECHNICAL POSITION ON COORDINATION OF ESF i
DESIGN WITH REPOSITORY DESIGN (411133; L61318) j 1 have reviewed the planned score of the proposed technical position on coordination of ESF design with repository design.
I have the following comments for your consideration in preparing a branch response.
1.
On page 2, under section 3. it is stated that "the scope of this technical position will include guidance on coordination of ESF design and construction with the repository design on aspects that are important to waste isolation, site characterization and retrieval." Assuming that some, if not all, components of the ESF will be part of the GROA and even assuming that not all of those components are " major design features that are important to waste isolation" (60.21 (c)(1)(ii)(D)), there may be aspects tmportant to safety (60,111 (a)) that may need to be considered in the ESF design. This should be given consideration in further scoping analysis for this TP.
2.
It is clear that components of the ESF that in the future any be
" major design features that are important to waste isolation" cannot be l
identified in the design stage unless ESF design is coordinated with the overall repository design. Obviously the coordination of these designs will be one of the important positions taken by the NRC staff in the TP.
However, given that the TP will cover aspects of the ESF design that are "important to site characterization" (60.15), the scope of the TP is broader than just " coordination of ESF design with repository design". The design of the ESF includes the additional objective of " obtaining the information needed for site characterization". Thus, it would seem appropriate that the title be " Technical Position on ESF Design and Design Control Process" rather than the more limited " Technical Position on Coordination of ESF Design with Repository Design".
3.
I will not comment in any detail on section 2 (Regulatory Background) other than to repeat what is noted on page 6 (there are other applicable part 60 requirements not quoted in this draft).
I merely caution that the TP should not focus on 60.133(f), for example, to the exclusion of other design criteria of 60.133, of which all would apply to components of the ESF incorporated into the underground facility of the repository. Note that 60.21 (c)(1)(ii)(D) should read " barriers that may not be themselves" rather than " barriers that may be themselves".
I have no further comments, cc: R. Ballard D. Chery 9001080287 891222 PDR ORG NOMA