nikkkom said:
All this paperwork was added because practice showed that without it, nuclear industry does not execute due diligence and does not make their plants safe enough.
As to this particular filter, I don't see why it is not installed on the existing vent line, why a new vent line needs to be added (as opposed to "existing vent line is cut, and a detour through the filter is inserted into the cut"). This way, all changes are way outside containment.
There are many plants that don't do due diligence even with the paperwork. (Browns ferry...)
The idea for all the paperwork is due to configuration management. For every plant that is "built", there are 3 plants. The regulatory required plant, the designed plant (also known as the "paper plant"), and the physical plant itself.
When a plant is licensed, the regulator is actually saying that the paper plant is good enough to meet or exceed the regulatory required plant. The plant is then built per the paper plant, and QA/QC/testing performed to ensure the physical plant was built in conformance with the paper plant.
As far as the regulator is concerned, the paper plant is what you are licensed to, so anytime you want to make a change to the plant, you first have to update your paper plant. Then you go and do the licensing side to either demonstrate that you are still bounded by the approved regulatory plant design model, OR you get permission to deviate from that (license amendment). Then, finally, when all that is done, you are allowed to update the physical plant to bring it into conformance with the paper plant.
It really has nothing to do with diligence. The reason for all the paper work, is that is how you prove that your plant design can actually meet regulatory objectives.
As for the filter, remember that for design basis accidents the filter is not required at all. It only helps with beyond design basis accidents. For beyond design basis accidents, remember that in order to get into a beyond design basis accident, something extraordinary had to occur to make your ECCS fail. Putting a filter inside the plant just makes it vulnerable to the same common event which caused you to lose your ECCS in the first place (not to mention that Mark I/II plants have no place to put something inside their secondary containment, they are space limited and seismic/structural limited).
So just throwing a filter into the plant may look good to the public, but in reality it doesn't mean the filter will work for those beyond design basis events which you really need it for. Having the valves and equipment inside the plant means that you now have to send people into very high rad (lethal?) fields to open and close those valves (remember no guarantee of electricity). So really, you want this equipment to be outside the plant, in an enclosure that is hardened far beyond that of the plant itself, such that the events which would cause you to lose your plant ECCS (plane crashes, large tornados, extermely heat/frost, extremely flooding, tsunamis) don't cause you to lose the filter as well, and give you the ability to control the release rate from outside the high rad field. You would also need to make sure that the system doesn't breach containment during design basis accidents like LOCA, where you DO have your ECCS and you absolutely want to keep ALL the material inside containment.