ML20057C135

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Forwards marked-up TS Section 5.0, Administrative Controls. Subsection 5.7.2.13, Explosive Gas & Storage Radioactivity Monitoring Program Should Be Deleted Due to Inapplicability to Advanced BWRs
ML20057C135
Person / Time
Site: 05200001
Issue date: 09/20/1993
From: Fox J
GENERAL ELECTRIC CO.
To: Poslusny C
Office of Nuclear Reactor Regulation
Shared Package
ML20057C136 List:
References
NUDOCS 9309280001
Download: ML20057C135 (1)


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GE Nuclear Energy.

i DV!k!d! $!NOll { : iffy US Camu Aew lm.bse GA Mi?S September 20, 1993 Docket No. STN 51-001 Chet Poslusny, Senior Project Manager Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of the Nuclear Reactor Regulation i

Subject:

Submittal Supporting Accelerated ABWR Schedule - P&R Comments on Section 5.0, Administrative Controls

Dear Chet:

Enclosed find our markup comments on Technical Specification Section 5.0 of the P&R version dated 7/29/93. Only the pages with markup comments are included.

Subsection 5.7.2.13, Explosive Gas and Storage Radioactivity Monitoring Program should be deleted because it is not applicable to the ABWR. The bases for this program is Branch Technical Position ETSB-5, " Postulated Radioactive Release due to Waste Gas Systein Leak or Failure", and SRP 15.7.3, " Postulated Radioactive Release due to Tank Failures".

SRP 15.7.1, " Waste Gas System Failure", that ETSB-5 references has been deleted. Mr. Chandrasekaran of your staff indicated that the requirements of SRP 15.7.1 has been relocated to SRP 11.3.

We could not find such requirements.

In.he ABWR, there are no liquid waste storage tanks outside of the Radwaste Building and hence elements of Subsection 5.7.2.13 that refers to liquid waste storage tanks are not applicable.

A related issue to the SRP 15.7.1 is that an LCO for Main Condenser Offgas j

should not be included in the technical specification. The bais for this LCO j

in the Standard Technical Specification is to maintain the initial conditions assumed in transient analysis of 15.7.1, which than satisifies Criterion 3 of the NRC Policy Statement on Technical Specifications.

This is not applicable to the ABWR.

Please provide a copy of this transmittal to Mark Reinhart.

Sincerely,

. W 27-105 ack Fox Advanced Reactor Programs cc:

Alan Beard (GE), Norman Fletcher (DOE), Cal Tang (GE)

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