ML20086H574
| ML20086H574 | |
| Person / Time | |
|---|---|
| Site: | 05000605 |
| Issue date: | 12/02/1991 |
| From: | Marriott P GENERAL ELECTRIC CO. |
| To: | Pierson R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| EEN-9186, NUDOCS 9112090224 | |
| Download: ML20086H574 (3) | |
Text
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i-GE NucIcin Enrrgy n,,
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e December 2,1991 MFN No.155 91 1
Docket No. STN 50 605 EEN 9186 l
Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20535 Attention:
Robert C. Pierson, Director Standardization and Non Power Reactor Project Directorate
Subject:
Advanced lloiling Water Reactor (AllWR) Technical Specilications (TS)
Reference:
(1)
Letter of September 12,1991: Chester Poslusny (NRC) to Patrick W.
Marriott (GE), Same Subject, MFN No.103 91 (2)
Letter of November 1,1991: Patrick W. Marriott (GE) to Robert C.
Pierson (NRC), Same Subject, MFN No.138 91 As a follow up to the meeting held on November 8,1991, this letter is intended to communicate OE's plan to the NRC for submitting AllWR Technical Specifications in response to item 2 o' Reference 1. Reference 2 provided the information sought by item 1 of Reference 1.
Background
Because of the ongoing improved Technical Specifications (ITS) effort, there has been significant discussion regarding the apiropriate standard for the ABWR Technical Specifications. Both OE and NRC apree t iat the ABWR Technical Specifications should reflect the final agreements reached m the ITS program, in past com<nunialons, the NRC has requested ABWR Technical Specifications in the form of a mark up of its Draft NUREO.
Ilowever, the BWR Owners Group BWROO) comments on this document are extensive, reflecting not only differences of opmi(on but, in some cases, also including correction are believed to be technical errors or inadequacies. As such, it would be problematic for OE to use the Draft NUREO as the standard for ABWR Technical Specifications. Therefore, we are proposing a slightly different aparoach that will allow the ABWR Technical Specifications review to go forward on a timely basis from a technical persiective. This can then be accomplished in parallel with, and in close coordination with, t te resolution of those issues still bemg worked out within the framework of the ITS program.
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Document Control Desk Docket No. STN 50405 U.S. Nuclear Regulatory Conunission MFN No.155 91 December 2,1991 Page 2 f
As documented in Reference (2), it is GB's current assessment that only twenty of the approximately one hundred LCOs in the llWR ITS require significant modification in order to properly reflect the AllWR design. Of these twenty about half dealwith instrumentation and control (!&C) systems. Of the remaining eighty LCOs, fifteen are not applicable to AllWR and the other sixty five require only minor revisions, if any, to accornmodate AllWR specific nomenclature or numerical values.
Proposed Action it is OE's intention to address the AllWR Technical Specifications in three future submittals.
i The first willinclude proposed s iecifications for the non l&C systems that are different for the AllWR and will be submitted by December 13,1991. %e second willinclude the same for the I&C systems and will be submitted by January 31,1991. The third submittal will address the approximately sixty five LCOs that are essentially unchanged for AllWR. This is also scheduled for submittal by January 31,1991.
The two submittals dealing with what is different for AllWR will include specifications that will essentially be redrafted from scratch as the design dictates substantially different specifications he written. %ese s1ecifications will be based on the ITS, with their general look and feel, but will likely differ " rom both the Draft NUREO and the llWROO comment 3ackage. - A review of the affected specifications indicates that the only substantial difference actween the NRC and ilWROO versions is related to how the issue of support system operability is treated. We understand that this issue has now been effectively resolved as part of the ongoing discussions within the 1% program. Therefore, we propose to incorporate the agreed upon tesolution in the affected AllWR specifications. In the end, early incorporation of such resolutions will result in the most efficient and effective review process, particularly regarding any necessary reconciliation with the final ITS product.
The third submittal will be a pen and ink markup, or computerized equivalent, of the NRC's subrnittal will be to show what is not different rather than what is.prirnary intent of this Draft NUREO, These changes will be few and minor in nature. The This should avoid unnecessary review. While we bellese the Draft NUREO is the most efficient vehicle foi accomplishing this particular goal in the overall review, their use should not be interpreted in any way as a OE endorsement of either the format or technical content of those sections of the Draft NUREO document. It is still our plan that the final AllWR Technical Specifications will closely mimic the final ITS product.
i Document Control Desk Docket No. STN 50 605 U.S. Nuclear Regulatory Commission MFN No.155 91 December 2,1991 Page 3 Although the above plan differs somewhat from the approaches previously discussed, we believe it offers the best means for keeping the review of the ABWR Technical Specifications focussed and on a schedule consistent with the Coal of a timely FDA issuance. Furthermore, we are prepared to work closely with the NRC staf f to assure its successful execution.
Sincerely,
/
1 P.W. Ma riott, Manager Regulatory and Analysis Services M/C 382, (408) 925-5948 cc:
F. A. Ross (DOE)
N. D. Fletcher (DOE)
C. Poslusny, Jr.
(NRC)
P. C. llearn (NRC)
R. C. Ucrglund (GE)
J. F. Quirk (GE)
I
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