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December 5, 1991 Docket No. STN 50-605 Mr. Patrick W. Marriott, Manager Licensing & Consulting Services GE Nuclear Energy 175 Curtner Avenue San Jose, California 95125
Dear Mr. Marriott:
DETAILED COMMENTS ON PILOT INSPECTIONS, TESTS, ANALYSES, AND
SUBJECT:
ACCEPTANCE CRITERIA (ITAAC) SUBMITTAL FOR THE ADVANCED BO WATER REACTOR (ABWR) t The staff has completed a review of your pilot ITAAC submittal for the ABWR provided in your letter of September 20, 1991.
Preliminary comments were provided to you in a letter dated October 23, 1991, and additional coments were provided to you in a meeting sumary dated October 31, 1991. Enclosed in this letter are detailed comments on the pilot ITAAC.
In general, the staff believes that the pilot ITAAC lack the level of detail and specific acceptance criteria appropriate for inclusion in Tier I design Section 52.103(c) of Title 10 of the Code of Federal certification material.
l Regulations (10 CFR 52.103(c)) requires that the Comission must be able to find that "the acceptance criteria have been met and that, accordingly, the facility has been constructed and will operate in conformity with the Atomic The level of detail in the Energy Act and the Commission's regulations."
pilot ITAAC will not permit the Commission to make that finding.
1 The review of the pilot ITAAC has been restricted since GE has not yet The detailed submitted proposed " construction-related" or " generic" ITAAC.
comments point out several areas where the staff believes these generic The staff's review has also been hampered by the
. requirements are applicable.
J lack of a written description of the methodology used to develop the pilot ITAAC.
The staff notes that there are several areas that have been recently identi-fled where it is not practical for you to provide final design details and the associated ITAAC. These area, include piping design, leak before break, We are control room design, and advanced instrumentation and controls.
working closely with your technical staff on the development of design acceptance criteria which may b3 used in limited areas to support the staff's safety determination.
4 I IN3ME-W
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i December 5, 1991 I
23, 1991, if General Electric does not 4
As stated in our letter of October submit its complete pilot ITAAC submittal (defined as the nine system ITAAC, the generic ITAAC, and the development methodology) by the end of 1991, then the projected staff completion of the ITAAC review will not meet the schedules established in SECY-91-16), " Schedules for the Advanced Reactor Reviews and 4
j Regulatory Guidance Revision.'
Please advise me if you cannot meet this schedule.
1 Questions on this topic should be directed to the ITAAC project manager, Tom Boyce, at (301) 492-1130.
4 Sincerely, OngM W %:
Robert C. Pierson, Director l
Standardization Project Directorate i
J Division of Advanced Reactors and Special Projects j
Office of Nuclear Reactor Regulation i
l
Enclosure:
J Detailed Coments on Pilot ITAAC 4
cc w/ enclosure:
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Sr-next page i
DISTRIBUTION w/ enclosure:
j Docket File PDST R/F LLuther DCrutchfield WTravers CPoslusny VMcCree AThadant j
RNease JNWilson RPierson TBoyce i
RBorchardt FHasselberg THiltz TKenyon l
TWambach JHWilson JMoore, 15B18 EJordan, MNBB3701 4
ACRS (10)
LShao, NLOO7 RBosnak, NLOO7 J0Brien, NL271A i
- ZRosztoczy,NLS169 BSheron, RES JMurphy, NL5007 BHardin, NLS169 l
RVan Houten, SECY GHolahan JRichardson RJones l
SNewberry
- RCaruso, GBagchi DTerzo JStewart -
MRubin TMurley (w/o)
AVietti-Cook (w/o)GGrant(w/o)lI>lFRosa
- i 0FC : LA:PDST:
PM:PDST:DAR PM:PDST:DAR SC:PDST:DAR SC:PDST:DAR l
NAME: LLuth r TBoyce:tz CPoslusny RBorghardt JNWilson J
DATE: 12/ 5 / 1 12/ /91 12/$/91 12/*>/91 12/y/91 j
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0FC : D:I
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l NAME: RPd e on D u field j
MTE: 12/%
1 12/6/91 2
0FFICIAL RECORD COPY:
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