ML19269C845

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Responds to NRC 781117 Ltr Re NRC Position on Cold Shutdown Requirements for SWESSAR-P1/BSAR-205.NRC Position Has No Effect on Design.Believes Preliminary Design Approval Can Be Issued W/O Further Delay
ML19269C845
Person / Time
Site: 05000495
Issue date: 01/26/1979
From: Kennedy W L
STONE & WEBSTER, INC.
To: Heltenmes C
Office of Nuclear Reactor Regulation
References
RPS-361, NUDOCS 7902140214
Download: ML19269C845 (1)


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STONE FJ WEBS ER ENGINEERING CORPORATION 245 SUMMEh STREET. Boston. M A ss A CH U SETTs ADDRESS ALL CORRESPONDENCE TO P.O. BOX 2325. BOSTON. M ASS. 02107 Newwvenn otsioN c"c'. c'O ' ' *O.' " . " * ' ' ~

>+0v57ON EM AMIN ATiONS LAN R GON Mr. C. J. Ile1temes, Jr. , Chief January 26, 1979 Standardization Branch W.O. No. 510.41 Office of Nuc1 car Reactor Reculation '

U.S. Nucicar Regulatory Connission RFS-361 liashington, DC 20555 (Follows RPS-349)

Dear Sir:

COLD SilUTD0hN REQUIREME. V fS -

  • DOCKI?f NO. STN-50-495

'SGW REFERENCE NUCLEAR POWER PLANT Lis letter responds to your letter of November 17, 1978, relative to the Staff Position on cold shutdown requircaents for SWESSAR-P1/BSAR-205.

On the assumption that there are no changes in the BSAR-205 design as approved by the NRC (PDA-12, May 31,1978), the Staff Position has no effect on our des ign. Therefore, we believe the PDA for SWESSAR-P1/ BSAR-205 can be issued without further delays.

Notwithstanding our degree of conformance, Stone G Nebster has the following coments regarding the NRC Staff Position. A safety grade cooldown to cold shutdown conditions has not been shown to be a significant safety issue.

Although hot shutdown is a safe condition, there also exist acceptabic nethods of proceeding ta cold shutdown. A complete value/ inpact analysis, in our opinion, would not justify the implementation of the Staff Position on any plant. Without a value/inpact analysis, any design changes required as a result of the Staff Position are counter productive to the standardi::ation effort. Stone G Webster is in agreement with the comments provided by Atonic Industrial Forun, Inc. (AIF) and The Babcock 6 Wilcox Company (BGW) on Regula-tory Guide 1.139 - Guidance for Residual lleat Removal (refer to letter fron Mr. J. Ward of AIF to Mr.11. Denton of the NRC dated November 21, 1978, and to letter fron Mr. J. Taylor of BGN to the Secretary of the Connission dated August 4,1978) as applicable to the Staff Position.

Very truly yours,

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1./J. L. Kenn y- 7 /

Vice President JIN:ars O oh

+1 0 790214 09N i