ML20056G293
| ML20056G293 | |
| Person / Time | |
|---|---|
| Site: | 05200001 |
| Issue date: | 08/27/1993 |
| From: | Ouirk J GENERAL ELECTRIC CO. |
| To: | Poslusny C Office of Nuclear Reactor Regulation |
| References | |
| FRN-57FR46202 MFN-144-93, NUDOCS 9309020374 | |
| Download: ML20056G293 (2) | |
Text
..,,
~
MNuclear Energy l
I GeneralDe tntComrany l
175 Cave? he@e. San Jose CA 95125
.l l
i August 27,1993 MFN No.144-93 1
Docket No. STN 52-001 l
i Chester Poslusny, Jr, Senior Project Manager i
Standardization Project Directorate l
Associate Directorate for Advanced Reactors i
and License Renewal Office of Nuclear Reactor Regulation
Dear Mr. Poslusny,
l
Subject:
Nuclear Regulatory Commission Metrication Policy j
Reference:
Letter, Chester Poslusny to Patrick W. Marriott, same subject, July 7,1993 -
i GE Nuclear Energy hereby requests that NRC exempt the ABWR design certification from j
compliance with the requirements of the metrication policy adopted last year by the NRC and published in the Federal Register (57 Fed. Reg. 46202, October 7,1992). The policy statement provides that all measurements in regulations and regulatory amendments issued by the NRC '
subsequent to January,1993 he stated both in the International System of Units and in the '
English System unless the NRC concludes that the use of any partictuar system would be j
detrimental to the public health and safety.
i' NRC's metrication policy is in furtherance of the Metric Conversion Act oi PF5, as amended.
The Act specifically recognizes that its implementation should not be requirea to the extent that -
such use is impractical or is likely to cause significant inefficiencies." 15 U.S.C. f205b(2).
Application of NRC's 1992 policy statement to the ABWR, which is nearing the completion of an NRC review begun nearly 6 years ago, plainly meets those exclusionary criteria.
-i The ABWR SSAR utilizes Japanese Metric in lieu of the International System of Units (SI). The l
only exception to Japanese Metric is in the application of SI units to SSAR Chapter 19 i
(PRA/ Severe Accidents), and the use of English Units for the Fire Hazard Analysis (SSAR Appendix 9A). To facilitate use, SSAR Section 1.7 provides the conversion of English Units to.
Japanese Metric Units.
j
}
GE has been preparing engineering documentation for the Kashiwazaki Kariwa Nuclear Power -.
l Generction Station, Units No. 6 and 7 (K-6/7) since 1987. This documentation includes all of the l
Piping and Instrumentation Drawings (P& ids), Process Functional Diagrams (PFDs) and design j
specifications. Maintaining the SSAR in Japanese Metric Units is clearly cost beneficial and '
.j provides a better link to the supporting documentation. GE considers it beneficial to use English Units for the Fire Hazard Analysis since the basic data and acceptance criteria are provided in English Units rather than Metric Units. To require wholesale conversion of the ABWR design certification to SI and English Units would be an enormously costly and time consuming undertaking with no compensating safety benefit.
~
]
O p
9309020374 930827-
{DR~ ADOCK 05200000 {
- p~
_PDR.
~a s
e s
i a
1 Acebrdingly, GE Nuclear Energy requests an exemption relieving it of any responsibility for performing conversions to the International System of Units (SI) or providing dual units in any documents that are part of the design certification rule. GE Nuclear Energy also asks that it be 1
relieved of responsibility for verifying the accuracy of any conversions done by the NRC staffin the final safety evaluation report.
Sincerely yours, sc
. Quirk
/ Project Manager ABWR Certification MC-782, (408)925-6219 cc:
R. C. Berglund (GE)
D. M. Crutchfield (NRC)
N. D. Fletcher (DOE)
- 3. N. Fox (GE)
F. A. Ross (DOE) i I
l i
l l
)
i 1
l LTRilK 9A49 l
l