NUREG-1225, Submits ACRS Comments on NUREG-1225, Implementation of NRC Policy on Nuclear Power Plant Standardization, Discussed at ACRS 318th Meeting on 861009-11.Rept Should Clarify Scope & Level of Detail of Info Required for Design Certification

Submits ACRS Comments on NUREG-1225, Implementation of NRC Policy on Nuclear Power Plant Standardization, Discussed at ACRS 318th Meeting on 861009-11.Rept Should Clarify Scope & Level of Detail of Info Required for Design Certification

ML20215H280
Person / Time
Issue date:	10/15/1986
From:	Ward D Advisory Committee on Reactor Safeguards
To:	Zech L NRC COMMISSION (OCM)
References
RTR-NUREG-1225 ACRS-R-1220, NUDOCS 8610230066
Download: ML20215H280 (2)

Text

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,! #' 'o g UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION

{ I ADVISORY COMMITTEE ON REACTOR SAFEGUARDS wasumaron, o.c.nossa

• • • • • October -15,1986 i- Honorable Lando W. Zech, Jr.

Chairman j U.S. Nuclear Regulatory Comission l Washington, D.C. 20555 i

SUBJECT:

ACRS COMMENTS ON DRAFT NUREG-1225, " IMPLEMENTATION OF NRC POLICY ON NUCLEAR POWER PLANT STANDARDIZATION" During its 318th meeting, October 9-11, 1986, the Advisory Comittee on

) Reactor Safeguards discussed the referenced draft NUREG-1225 "Implemen-tation of NRC Policy on Nuclear Power. Plant Standardization."- A sub-i comittee. meeting on this - matter was held in Washington, D. C. on October 8, 1986.

! We are in general agreement with the draft NUREG-1225, but we have the following observations:

1. -It is not clear that the proposed NUREG-1225 will be published for public coment. We believe that the Comission would benefit from and should seek public coment on the design certification rule-making options. Also, if infomed comment is to be obtained during the rulemaking process, we think that the. criteria and threshold for standing and interest for participation in the legislative or adjudicatory rulemaking hearings should be made clear. We under-stand that the p'rovisions for participation will be defined .in the notice of rulemaking . in the Federal Register for the specific rulemaking proceedings; this should be so stated in draft NUREG-1225. .

, 2. We do not consider that the scope and level' of detail of infoma-tion required for design certifications are adequately defined in draft NUREG-1225. It should be made clear that, in addition to

! providing a level of design detail equivalent to that required by

! 10 CFR 50.34(b) for a final safety analysis report, an applicant for a final design approval (FDA) should be prepared to supply such other information as is customarily required by the NRC Staff to perform a final safety analysis report review.

Since an FDA for a final design must be issued before the design can be certified, the certification process ideally should require little additional design information if that supplied with the FDA is adequate. However, the scope of design presently described in Section 3.1.3, " Design Certification Concept," of draft NUREG-1225 is not adequate and needs to be expanded and better defined. ..

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Honorable Lando W. Zech, Jr. -

2- October 15, 1986 We believe that the expansion and clarification of infomation requirements for an " essentially complete design" should have input

$ rom the principal cognizant NRC Staff reviewers and various industry organizations experienced in such matters.

3. It should be made clear that portions of a design which has re-ceived design certification by the NRC are not thereby certified for other applications.

The ACRS would like to be kept informed regarding this matter.

Sincerely,

. 4 David A. Ward Chaiman

Reference:

Draf t NUREG-1225 " Implementation of NRC Policy on Nuclear Power Plant Standardization," undated, Handout during 318th ACRS meeting, October 9-11, 1986 O

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