ML20087C097
| ML20087C097 | |
| Person / Time | |
|---|---|
| Site: | 05200001, 05200002 |
| Issue date: | 07/31/1995 |
| From: | Dodson W STONE & WEBSTER ENGINEERING CORP. |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-60FR17924, RULE-PR-52 60FR17924-00001, 60FR17924-1, PNO-95-042, PNO-95-42, NUDOCS 9508090037 | |
| Download: ML20087C097 (2) | |
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- o STONE 6 WEBSTER ENGINEBR]RQDRPORATION USNRC 245 SUMMER STREET, BOSTON, MASSACHUSETTS 0221 bNNb me............,
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OAM RIDGE TM Mr. John Hoyle, Secretary July 31,1995 OfGce of the Secretary U.S. Nuclear Regulatory Commission PNO-95-042 Washington, D.C. 20555 Attention: Docketing and Servicing Branch
Subject:
Proposed Rule: Standard Design Certification for the System 80+ Advanced Pressurized Water Reactor (60 Fed. Reg.17925. April 7.1995)
Stone & Webster Engineering Corporation (Stone & Webster) is a partner with Combustion Engineering, Inc. (ABB-CE), the applicant for design certification (Docket No.52-002) of the System 80+ Standard Plant Design described in the above-referenced proposed rule.
Stone & Webster has been an active participant in the System 80+ Design Certification process and strongly endorses the comments submitted by NEI and ABB-CE on both the ABB-CE System 80+ and the General Electric Co. ABWR Design Certification Notice of Proposed Rules (NOPR). We commend the NRC for the efforts expended to reach this point in Design Certification. While we agree with most of the proposed Rule, we would like to emphasize that there are a limited number of items which if not properly resolved could significantly deter its intended use. These are fully discussed in the NEI and ABB-CE comments and will only be briefly highlighted in the following paragraphs.
50.59 Like Changes - As addressed by the proposed Rule, these types of changes m
are subject to more external exposure than they are in current operating plants today. This is inconsistent and undesirable. Complicating the change process blocks potential positive improvements, Definition of Certified Design Approval - The entire concept of the Design u
Certification Process and the principal feature that made our participation worth while was that sufficient approval would be obtained that minor changes normally encountered during the detailed design, procurement and construction process would not have to be re-reviewed and subject to the public review process since these have little impact on the fundamental safety of the plant. These were relegated to Tier 2 in the Design Certification Process. The NOPR does not obtain this objective.
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- 989 1889 9508090037 950731
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- Mr. John Hoyle, Secretary Page 2 July 31,1995 I
s Design Stability - The " Applicable Regulations" requirement of the NOPR will' e
prevent successful standardization. As the industry.has painfully discovered, minor changes from a standard are multiplied ten fold due' to consequential impacts when they have to be incorporated into the design.
trAAC Reauirements for Part 50 - This requirement to include ITAAC provisions i
u for System 80+ if licensed under part 50 is the classic "rachet". This is being t
promulgated in a manner which would avoid the requirement of justifying the cost benefit of regulatory changes. This defm' itely deserves a detailed evaluation of that type before it is given any serious consideration.
Please contact Steven L. Stamm at (617) 589-7499 if you have any questions on this j
i submittal.
Very truly yours, i
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W.B. Dodson Vice President l
Nuclear Operations o
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