ML20045F685

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Provides ABB-CE Proposed Sys 80+ Tier 1 Definition for Channel. Proposes That Introductory Section 1.0 Be Deleted
ML20045F685
Person / Time
Site: 05200002
Issue date: 05/26/1993
From: Egan J
SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Borchardt B
NRC
References
NUDOCS 9307080238
Download: ML20045F685 (1)


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rACsmiLe (202)663 8007 MEMORANDUM wRff E.R'S DIRE CT vial NUMB f R TO:

Bill Borchardt l

FROM:

Joseph R.

Egan DATE:

May.26, 1993 RE:

System 80+ Tier 1 Definition for " Channel" Below is ABB-CE's proposed Tier 1 definition for "Chan-nel," which we promised in a previous memo to provide for you, i

1.

Unless we hear otherwise from you or OGC, this completes the ABB-CE submittal for the Definitions section and the General Pro-visions section of the System 80+ Tier-1 material -- Sections 1.1 and 1.2, respectively.

Although we and GE had originally proposed to have an introductory Section 1.0, both of us now believe that explanatory material as to the nature of the contents of--the Tier 1 package or of'anything in the Design Control Document is best-left to the Statement of Considerations that would accompany the' proposed rule.

We found that any attempt to define what it was we were including in the document raised legal questions.

Moreover, we noted that rulemakings generally do not contain explanatory introductions as parts of the rules themselves, but, rather, they-leave such explanations to the Statement of Considerations, which.

is authored in final form by NRC.

Accordingly, we are proposing that Section 1.0 be deleted or be simply an extremely short statement introducing the document.

I Channel means either an arrangement of components and their interconnects that generates a signal to initiate an' action or to indicate a condition, or a dis-tinct path among multiple paths within instrumentation and control equipment.

cc:

Charles Brinkman Adrian Heymer (NUMARC)

Steve Frantz (Newman & Holtzinger/GE)

Tony James (GE)

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