ML20056C497
| ML20056C497 | |
| Person / Time | |
|---|---|
| Issue date: | 09/01/1992 |
| From: | Costner R Advisory Committee on Reactor Safeguards |
| To: | Igne E, Michelson C NRC |
| References | |
| ACRS-CT-2041, CT-2041, NUDOCS 9306240278 | |
| Download: ML20056C497 (2) | |
Text
(
C T-a 6 91 e
fpra 69tl43 FILE = TIER-lLT.003 LETTER on Tier i Document TO:
Mr. C. MICHELSON, Chairman, ABWR Subcommittee ATTENTION: Mr. E. G. Igne US Nuclear Regulatory Commission MS-P315 Washington, DC 20555 FROM:
R.A.COSTNER DATE:
September 1,1992 SUBJ: COMMENTS FROM REVIEW OF THE ABWR TIER I DOCUMENT Last week I left you two letters at The Mail Center, Inc. You were going to forward one copy of each to Al for distribution. The two letters were: (1) FILE = TIER-ILT.002, dated j
August 27,1992, and (2) FILE = TIER-ILT.R02, dated August 28,1992.
in these letters I transmitted the results of my review o'f the Tier I document. In the first letter I highlighted certain of the results which I feel illustrate some general problems. Those problems have significance beyond that associated with the particular sections on which the comments cited were made.
There is an additional very important generic issue which the NRC Staff, GE, and ACRS must resolve. The purpose of this letter is to highlight that additional issue.
Definition of Significance of Diacrams -- Comment 2.0-6 and Comment 2.0-7 discuss the ambiguous status of the diagrams. Comment 2.0-6 quotes from the Tier 1 document as follows:
These diagrams are for the purpose of illustrating the principal design features of the ABWR systems and their relationship to each other. The simplified figures are not to scale and are not intended to be exact representations of the detailed system configurations that will be utilized in any facility referencing the certified design.
In my opinion this wording is sufficiently imnrecise to result in a lot of grief (1) both during the next several months of review by ACRS and NRC and (2) during subsequent years of application of the Certified Rule. There are a number of the ITAAC which use wording which is some variation on "the installed equipment is in compliance with the desien configuration defined in Figure 2.x.y."
In addition, there is a great amount of disparity as to the degree of detail presently presented in the diagrams. Some diagrams are almost bare.
bones, quasi P&lDs showing equipment, valves, instmments, etc. A few other diagrams consist of little more than a collection of labeled blocks with arrows connecting the blocks.
080 c o m o carcixit g}
Certified By C
9306240278 920901
- g
-Q g
i rq.
9 Mr. C. MICHELSON ATTENTION: Mr. E. G. Igne page 2 What is needed for the Tier i document is (1) a carefully worded statement of what "The simplified figures are intended to be with respect to the detailed system configurations," and (2) an agreement as to the criteria for the minimum degree of detail to be presented in the diagrams. Similarly, an agreement as to the criteria for the minimum degree of detail to be presented in Design Description sections is needed.
Both the NRC and the future applicants require assurance as to the degree to which future designs can rely on the con 6guration depicted in the "simplined figures" and in the Design Descriptions as " certified." What is needed in short is definition of configurations that "will stand up in court"; definitions with suf6cient speci6 city that, when challenged legally, the record will show that actual conceptual configurations were "certiGed."
What must be avoided is the Certi6ed Rule being vulnerable to an interpretation that only a somewhat vague general concept was evaluated and certified. This last situation would be a disservice to industry, the regulators, and the public. Rather than result in optimizing expenditure of national resources as intended by 10CFR Part 52, this lack of clear de6nition would fuel future litigation.
e U