ML20095D349

Comments on Introduction & Chapters 1,6,8 & 9 of Draft, Format & Content for Applications for Licensing of Nonpower Reactors, & Draft, Safety Analysis Rept Review Plan & Acceptance Criteria for Nonpower Reactors

ML20095D349
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	02/23/1995
From:	Maria Moore ARMED FORCES RADIOBIOLOGICAL RESEARCH INSTITUTE
To:	NRC (Affiliation Not Assigned)
References
RTR-NUREG-GENERA NUDOCS 9512130026
Download: ML20095D349 (6)

Text

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ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE BETHE A, ARY D2 9- 603 23 February 1995

SUBJECT:

Draft Application Format and Content Guidance and Review Plan and Acceptance Criteria for Non-Power Reactors Director, Non-Power Reactors and Decommissioning Project Directorate United States Nuclear Regulatory Commission M. S.11-B-20 Washington, DC 20555 Dear Director.

We have reviewed the introduction and Chapters 1. 6,8, and 9 of the draft

" Format and Content for Applications for the Licensing of Non-Power Reactors" and the draft " Safety Analysis Report Review Plan and Acceptance Criteria for Non-power Reactors."

We find these drafts generally clear and workable. We believe they represent '

an improved mechanism for the preparation, review, and ultimate approval of Safety Analysis Reports (SARs) and licensing applications for non-power reactors.

l Specific comments and questions related to our review of these documents are  ;

attached. Please contact Mark Moore, at telephone number (301)295-5590, if you l have any questions regarding these comments.

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Cud Attachments: MARK L. MOORE I (1) Comments on Introduction Reactor Facility Director (2) Comments on Chapter 1 (3) Comments on Chapter 6 (4) Comments on Chapter 8 l (5) Comments on Chapter 9 l q

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I 9512130026 950223 O PDR

AFRRI COMMENTS i SAR REVIEW Pi.AN AND ACCEPTANCE CRITERIA INTRODUCTION i SECTION REQUIREMENT COMMENT SUGGESTION '

SF&C, p. viii Specify measurements in This requirement is unnecessarily Require only that the both Si and English units. burdensome. Many existing plant licensee use one drawings and diagrams are in one system or the other for system or another, to invest the individual drawings or  !

time and manpower to convert diagrams, as applicable.

them solely for the purpose of SAR submittal is a waste of resources.

RP&AC, p. iv The text references: No such example document was Forward a copy of the

" Appendix A of this document found in the material received for example document to  ;

is an example of an NRC review. the licensee.  ;

Evaluation Report" -

NOTE: SF&C denotes comments pertaining to the SAR Standard Format and Content RP&AC denotes comments pertaining to the SAR Review Plan and Acceptance Criteria .

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AFRRI COMMENTS I SAR REVIEW PLAN AND ACCEPTANCE CRITERIA CHAPTER 1: GENERAL DESCRIPTION OF THE FACluTY SECTION REQUIREMENT COMMENT SUGGESTION RP&AC, p.1-6, The reviewer should The task of the licensee in The concept of" shared '

11.4.3 assess the effect of the describing the interactions of facilities" should be very shared facilities on safety. multiple facilities depends on explicitly defined, with the exact definition of " shared consideration of the facilities." implications of this definition on SAR analysis and review.

NOTE: SF&C denotes comments pertaining to the SAR Standard Format and Content RP&AC denotes comments pertaining to the SAR Review Plan and Acceptance Criteria

AFRRI COMMENTS SAR REVIEW PLAN AND ACCEPTANCE CRITERIA i i

CHAPTERS: ENGINEERED SAFETY FEATURES

• SECTION REQUIREMENT COMMENT SUGGESTION No comments on this  !

chapter.

NOTE: SF&C denotes comments pertaining to the SAR Standard Format and Content  !

RP&AC denotes comments pertaining to the SAR Review Plan and Acceptance Critoria I

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AFRRI COMMENTS SAR REVIEW PLAN AND ACCEPTANCE CRITERIA CHAPTER 8: ELECTRICAL POWER SYSTEMS SECTION REQUIREMENT COMMENT SUGGESTION No comments on this chapter.

NOTE: SF&C denotes comments pertaining to the SAR Standard Format and Content RP&AC denotes comments pertaining to the SAR Review Plan and Acceptance Criteria

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I AFRRI COMMENTS i

SAR REVIEW PLAN AND ACCEPTANCE CRITERIA CHAPTER 9: AUXIUARY SYSTEMS SECTION REQUIREMENT COMMENT SUGGESTION +

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SF&C, p. 9-4, Applicant should There is no prachcal way to demonstrate, in Delete the general 19.4 discuss how the the SAR, that the facility meets "all local statement for the facility meets all local budding and fire codes." The facility had to applicant to building and fire meet the cmdes in existence when the facility demonstrate compliance codes. was originally constructed, and then comply with "all local building with penodic inspections. However, and fire codes."

satisfactory inspections are not documented, only violations or noncompliance. The proposed general requirement to demonstrate i compliance with "all local building and fire codes" is imprachcai.  ;

RP&AC, p. 9-5, The NRC will rewsw The apphcant will have difficulty furnishing Modify the text of this 19.3.1 systems, components, suitable material for rewsw. There is currently sechon to recognize that and methods used to no authonzed shipping cask for TRIGA fuel, speafics on the

' prepare and ship fuel and no speafic destinabon to which fuel may systems, components, ,

off site in accordance be shipped. and methods for l with applicable preparing and shipping  !

regulations. fuel off site may not be i available.

NOTE: SF&C denotes comments pertaining to the SAR Standard Format and Content

RP&AC denotes comments pertaining to the SAR Review Plan and Acceptance Criteria r

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