ML20126F994
| ML20126F994 | |
| Person / Time | |
|---|---|
| Site: | 05000668 |
| Issue date: | 12/22/1992 |
| From: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-57FR44513, RULE-PR-50 57FR44513-00003, 57FR44513-3, NUDOCS 9301040013 | |
| Download: ML20126F994 (2) | |
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Westinghouse Energy Systems 92 DEC 28 P4 :16 8 ' 355 Electric Corporation Pmstuqn Pernsyivama 15230 0355 i.
5y ET NRC-92 3788 m.u NSRA-APSI 92-0269 December 22,1992
' r. Samuel J. Chilk M
The Secretary of the Commission U.S. Nuclear Regulatory Comitission Washington, D.C 20555 ATIT.NTION:
DOCKETING AND SERVICE BRANCII
SUBJECT:
" Acceptability of Plant Performance for Severe Accidents; Scope of Consideration in Salety Re pJations" (57 Fed. Reg. 44513, September 28,1992) - Advanced Notice of Proposed R'ilemaking (ANPR)
Dear Mr. Chilk:
The purpose of this letter is to provide Westinghouse Electric Corporation comments on the subject proposed rulemaking.
On June 26,1992, Westinghouse submitted to die NRC an application for final design approval (FDA) under Appendix 0 to 10 CFR Part 52 and a Standard Design Cenification (DC) under 10 CFR Part 52 for the AP600 plant design. As one of the three vendors with Advanced Light Water Reactor (ALWR) designs currently under review by the NRC, we have carefully reviewed the subject ANPR with puticular focus on the impacts the proposed rulemaking would have, on the pursuit of the FDA j
and DC for the AP600 oesign.
l Westinghouse believes that genetic rulemaking to address severe accident issues for future plants is l
neither necessary nor desirable. Contrary to a stated purpose of the proposed rule, we believe that the l_
proposed rulemaking will not " facilitate design cenification rulemaking" but would instead increase l
uncertainty with little or no added value.- To pursue gencric rulemaking fer severe accidents at this l
point in the AP600 Design Cenification effon would at best result in a duplication of effort, as well as l
a duplication of regulation and guidance. The intrusion of such rulemaking at this time introduces L
substantial uncertainty and confusion irto the Part 52 licensing process, and could easily jeopardize design certification for the AP600 as well as other advanced plants _
L l
ALWR severe accident issues are presently being addressed by the industry and NRC through the l
ALWR Utility Requirements Document (URD) and design cenification interactions. The utility requirements developed for both evolutionary and passive plant designs address a wide spectrum of severe accident phenomena and containment challenges. The Westh.ghouse AP600 is designed to meet the utility requirements for passive ALWR designs. As such, we believe that NRC review of the l
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I ET-NRC-92 3788 2-December 22,1992 NSRA APSI-92-0269 URD, as well as the design certification review of the AP600 design, provides the preferable method for resolution of severe accident technical issues. This piocess allows for generic resolution of severe accident issues to the extent possiMe via the ALWR URD and review and codification of design specific itnplementation as part of the AP600 design certification process.
We are particularly concerned that a generic rulemak:Ing for sewm accidents separate from the design certification process will signuinntly disrupt the design certification process being pursued for the AP600 with the potential for causing costly and unwarranted delays. As noted in the ANPR, 'this rule would be generally applicable to passive LWR designs. However, as detailed design information becomes available and review of the passive systems is completed, further rulemaking may be necessary." De impilcation is that the net result of this potential series of genetic rulemakings is a rule which wouhl reflect the information obtained through the specific passive plant design certifications. Thus there is no need for a separate rulemaking at this time. We expect the Design Certification application for the AP600 to be docketed within the next month (a docket number has already been assigned). The review of the AP600 design by the NRC staff is r.iready in process and we expect the AP600 FDA to be issued in mid to late 1994. His time frame does not lerd itself to the process envisioned in the ANPR.
Wes inghouse has participated in the preparation of industry comments on the proposed rulemaking and we support the comments being offered on this subject by NUMARC.
We appreciate this opportunisy to comment on the proposed rulemaking and urge that the Commission not proceed with the proposed generic rulemaking for severe accidents. As discussed above, we believe the NRC staff should continue to work toward resolution of severe accident issues for advanced plants via the design certification process.
Very truly yoms, Jgff' p
N. J. Uparulo, Menger Nuclear Safety and Regulatory Activities
/nja ec:
The Honorable Ivan Selin, Chairman Cornmissioner Kenneth C. Rogers Commissioner James R. Curtiss Commissioner Forrest J. Remiek Commissioner E. Gail de Planque Mr. J. Taylor, EDO l
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