ML20073R797
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UNITED STATES
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NUCLEAR REGULATOR SiON
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May 29,1992
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yo 11 Docket No.52-001 Mr. Robert C. Berglund, General Manager Advanced Reactor Programs GE Nuclear Energy 175 Curtner Avenue San Jose, California 95125
Dear Mr. Berglund:
SUBJECT:
_ REQUEST FjfLCERTIFICATIO Q F TIE DESIGN CERTIFICATION MATERIAL
~ STAGE 3 SUBMITTAL. FOR THE AD D BOILING WATER REACTOR (ABWR)
The staff has reviewed your Tier 1 Design Certification Material for the GE Nuclear Energy (GE) ABWR Design - Stage 2 Submittal provided in ycur letter of April 6, 1992.
Preliminary comments were provided to you in a letter dated May 7,1992, and were discussed with you at a senior management meeting on May 7, 1992.
10 CFR 52.47(a)(1)(vi) requires you to submit proposed tests, inspections, analyses, and acceptance criteria (ITAAC) which are "necessary and sufficient to provide reasonable assurance that, if the tests, ir.spections, and analyses are performed and the acceptance criteria met, a plant which references the design is built and will operate in accordance with the design certification."
As discussed in the preliminary comments and in the meeting, the staff has identified several inconsistencies in your su itta wnich are of significant concern because they reflect a Tack of internal _ual tv Assurance prior to submittal to the Nuclear Regulatory Commission (NRC).
The staff has noted inconsistencies between the Design CarlificationJa.terial Jnd the standard safety analysis report ~(5SARl. An examole3 f this is the TTe~r 1 control room ventilation design descriotion in Section 2.15.5.
The SSAR Chapter 15 analysis indicates a minimum of 95 percent filter efficiency for this system. The Tier 1 design description specifies a minimum 80 percent efficiency for these filters, which is significantly less conservative.
In addition, this design description indicates that both of the air intakes for this system can be isolated at the same time.
This is contrary to the SSAR analysis that requires a positive atmospheric pressure in the control room.
t The control room HVAC could not maintain a positive pressure with both intakes closed. Thus, the Tier 1 design information is not consistent with the design basis analysis for the control room. The staff notes tMt it is especially difficult to monitor for consistency between the Tier 1 mformation and the SSAR, since amendments to the SSAR have not been submitted with changes to the Tier 1 material.
Further, it appears that there are a number of systems j
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Mr. Robert C. Berglund May 29, 1992 proposed for the Tier 1 document that have not been addressed in the SSAR.
These include the Breathing Air System (Section 2.11.19) and the Dust Radia-
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tion Monitoring System (Section 2.3.3).
{ The staff notes that although you initially comitted to providing a "roadmap" for a number of key analyses in January 1992, only one actually has been 2
i provided. Thus, it is not clear how the Tier 1 material reflects the design basis analyses in the SSAR, especially for key areas such as PRA insights into i
the design and the verification of severe accident features in the Tier 1 material.
1 It is also the staff's understanding that you are u.,able to support discus-sions with the staff to address the May 7,1992, coments pertaining to the Stage 2 submittal.
This means that many similar comments will likely need to be addressed in the Stage 3 submittal.
It is inefficent to review a submittal with known deficiencies, given the already advanced stage of the review and will likely impact the timing of the staff's issuance of its safety findings.
10 CFR 52.48 requires that your application meet the standards in 10 CFR Part 50, as they apply to applications for construction permits and operating licenses for nuclear power plants. Accordingly, you are requested to certify that the Design Certification Material Stage 3 submittal for the ABWR design j
will meet the Quality Assurance requirements of 10 CFR Part 50, Appendix B.
j Questions on this topic should be directed to the ITAAC project manager, Tom Boyce, at (301) 492-1130.
Sincerely, original signed by:
William Travers J
Dennis M. Cratchfielu, Associate Director for Advanced Reactors and License Renewal l
Office of Nuclear Reactor Regulation 4
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Og/92 0FFICIAL RECORD COPY:
ITAAC-QA.THB
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