ML20057E019

Discusses CE Request for Exemption from Compliance W/Nrc Metrication Policy Re ABWR Design Certification, Specifically Exemption from Performing Conversion to SI or Providing Dual Units in Design Certification Rule Documents

ML20057E019
Person / Time
Site:	05200002
Issue date:	09/30/1993
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Remick, Selin I, The Chairman NRC COMMISSION (OCM)
References
NUDOCS 9310070110
Download: ML20057E019 (4)

Text

PPA

~

g[

o UNITED STATES g

NUCLEAR REGULATORY COMMISSION g

g E

WASHINGTON D. C. 20555 k ***e /

September 30, 1993 MEMORANDUM TO:

The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque FROM:

James M. Taylor Executive Director for Operations

SUBJECT:

METRICATION POLICY EXEMPTION REQUEST The Commission directed the staff in COMFR-93-003 that Asea Brown Boveri-Combustion Engineering's (ABB-CE) System 80+ design certification is exempted from the NRC's policy on metrication. The Commission also requested the staff to identify other vendors that may wish to be granted similar exemptions.

In response to the Commission's request, the staff sent a letter to GE Nuclear Energy (GE) dated July 7,1993, asking if GE would like to be relieved of the responsibility for performing unit conversions or for providing dual units in any documents that are part of the design certification rule.

In response to the staff's letter on metrication policy, GE sent a letter to the NRC dated August 27, 1993, which is enclosed.

In this letter, GE requested that NRC exempt the advanced boiling water reactor (ABWR) design certification application from compliance with the requirements of the NRC's metrication policy. GE specifically requested an exemption from 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 also askec that it be relieved of responsibility for verifying the accuracy of any conversions done by the NRC staff in the final safety evaluation report (FSER).

The ABWR standard safety analysis report (SSAR) currently has SI units in Chapter 19, English units in Appendix 9A, and Japanese metric units in the remainder of the SSAR. GE provided a conversion of English units to Japanese metric units in Section 1.7 of the SSAR.

The difference between SI and Japanese metric are in the units for pressure, force, and torque.

For example, Japanese metric expresses pressure, force, and torque in terms of Kg/cm squared, Kg, Kg-m units, respectively, while SI uses Pascal (Pa), Newton (N) and N-m units, respectively. The Japanese metric system can be confusing because the same unit (Kg) is used for both mass and i

force. The staff believes GE's use of mixed units would be confusing for i

1 i

CONTACT:

k.fgh hd QQ ((py 5b4 5

-l 9310070110 930930 I

PDR ADDCK 0520 2

g

The Commissioners future users of the ABWR design control document (DCD).

Therefore, the stm f recommends that GE be required to prepare the ABWR DCD in SI units.

Only three units will need to be changed (pressure, force, and torque), and it will result in a more useable document. The staff also recommends that GE provide a conversion table from SI to English units in the DCD in lieu of providing dual units. The staff will prepare the ABWR FSER in dual units in accordance with Commission guidance.

Origin 91el;ned by SECY, Please Track.

Hggh t.Th0mp000, b.

James M. Taylor Executive Director for Operatiors cc:

SECY OGC OCA OPA DISTRIBUTION:

Central File EDO R/F JTaylor, 17G21 JSniezek, 17G21 PDR HThompson JBl aha, 17G21 TMurley/FMiraglia,12G18 WRussell, 12G18 JPartlow, 12G18 FGillespie, 12G18 DCrutchfield WTravers RBorchardt JNWilson PShea SNinh CPoslusny DTang TGody, 17G21 BToms PMagnanelli NRR Mailroom,12G18 PDST R/F

• SEE PREVIOUS CONCURRENCE OFC:

PM:PDST LA:PDS L %

a TECH EDITOR SC:PDST D:PDST NAME:

SQ

tr PShea DGable*

JNWilson*

RBorchardt*

DATE:

09/

93 09 93

/93 09/27/93 09/27/93 k

0FC:

OCC /

_ ADMihRR f

AD\\NRR f:kW A,

EDO NAME:

DC ld WRiA

(

T rtey JMTaylor

'09/2.h93 09//d/93 DATE:

09/ /93 0924/93 09/ /93 0FFICIAL RECORD COPY:

COMMLTR.SQN

-f

)

GENucle:r Energy i

Genere DescCompay r

175 Carmer Avenue Sen Jose. CA 95125 August 27,1993 MFN No.144-93 Docket No. STN 52-001 Chester Poslusny, Jr, Senior Project Manager Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation

Subject:

Nuclear Regulatory Commission Metrication Policy

Reference:

Letter, Chester Poslusny to Patrick W. Marriott, same subject, July 7,1993 GE Nuclear Energy hereby requests that NRC exempt the ABWR design certification from compliance with the requirements of the metrication policy adopted Int year by the NRC and published in the Federal Register (57 Fed. Reg. 46202, October 7,1992). The policy statement provides that all meartrements in regulations and regulatory amendments issued by the NRC subsequent to January,1993 be stated both in the International System of Units and in the English System unless the NRC concludes that the use of any particular system would be detrimental to the public health and safety.

NRC's metrication policy is in furtherance of the Metric Conversion Act of 1975, as amended.

The Act specifically recognizes that its implementation should not be required "to the extent that such use is impractical or is likely to cause significant inefficiencies." 15 U.S.C. 5205b(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.

The ABWR SSAR utilizes Japanese Metric in lieu of the International System of Units (SI). He only exception to Japanese Metric is in the application of SI units to SSAR Chapter 19 (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.

I GE has been preparing engineering documentation for the Kashiwazaki Kari%a Nuclear Power Generation Station, Units No. 6 and 7 (K-6/7) since 1987. This documentatio includes all of the Piping and Instrumentation Drawings (P&TDs), Process Functional Diagrams FFDs) and design specifications. Maintaining the SSAR in Japanese Metric Units is clearly cost eneficial and 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 ceceptance 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.

i 1

Accordingly, GE Nuclear Energy requests an exemption relieving it of any respcnsibility 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 relieved of responsibility for verifying the accuracy of any conversions done by the NRC staffin the final safety evaluation report.

Sincerely yours, fs

. Quirk

/ Project Manager ABWR Certification MC-782, (408)925-6219 cc:

R. C. Berglund (GE)

D. M. Crutthfield (NRC)

N. D. Fletcher (DOE)

3. N. Fox (GE)

F. A. Ross (DOE)

LTfulK 9.Mo 5

e A