LD-94-027, Forwards Summary of Sys 80+ Design & Operational Features Involving Deviations from Current Regulations

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Forwards Summary of Sys 80+ Design & Operational Features Involving Deviations from Current Regulations
ML20070N529
Person / Time
Site: 05200002
Issue date: 04/26/1994
From: Brinkman C
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LD-94-027, LD-94-27, NUDOCS 9405060298
Download: ML20070N529 (4)


Text

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April 26, 1994

' LD-94-027 Docket No. 52.-002 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington. D.C. 20555

Subject:

System 80+" Exemptions From Regulations

Dear Sirs:

In response to a request fror;: the NRC Project Directorate, ABB-CE is submitting the attached summary of System 80+ design and operational features which involve deviations from current regulations. These features have been reviewed by NRC staff and the exemptions summarized in the attachment are consistent with those in the advance copy of the System 80+ Final Safety Evaluation Report.

The attachment summarizes the basis for each of the exemptions, consistent with the requirements of 10 CFR 50.12. It is ABB-CE's understanding that the acceptability of the exemptions and corresponding System 80+ features will be datumented in the Final Safety Evaluation Report (NUREG-i;$2) and will be codified during the System 80+ Design Certification rulemaking.

If you have any questions, please call me or Mr. Stan Ritterbusch at (203) 285-5206.

Very truly yours, COMBUSTION ENGINEERING, INC.

C. B. Brinkman Director Nuclear Systems Licensing CBB/ser cc: 1. Trotter (EPRI)

T. Wambach (NRC)

P. Lang (DOE) p p n r, r

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. ATTACHMENT 1 Summary of System 80+ Deviations From NRC Reaulations The following paragraphs summarize System 80+ deviations from NRC regulations, it is ABB-CE's understanding that NRC staff agrees with the deviations, as documented in the advance copy of the System 80+

Final Safety Evaluation Report.

10 CFR 50.34[f) - Compliance with the " TID 14844" Radioloaical Source l Termt i

Paragraph 2(xxviii) of this regulation requires the evaluation of pathways that may lead to control room habitability problems "under accident conditions resulting in a TID 14844 source term release".

Similar wording appears in subparagraphs vii, viii, and xvi. ABB-CE has implemented the new source term technology summarized in Draft NUREG-1465 and Appendix 15A of'the Combustion Engineering Standard Safety Analysis Report for Design Certification (CESSAR-DC). NRC staff has encouraged the development and implementation of the new source term technology (re: letter to ABB-CE, dated October 19, 1992).

Our understanding of the NRC staff position is that the new source term must be used consistently and that the old TID source term could not be used for equipment qualification if the new source term were implemented in the accident analysis of CESSAR-DC, Chapters 6,15, and 19. We have, therefore, implemented the new source term for equipment qualification (Section 3.11 of CESSAR-DC) as well as for the accident analysis. The NRC staff's concurrence is documented in the advance copy of the Final '

Safety Evaluation Report (FSER), Section 3.11.3.2 and Appendix 15A.

l This approach and its inherent conservatism meets exemption criteria  !

(a)(1), (a)(2)(ii), and (a)(2)(iii) of 10 CFR 50.12.

l L0 CFR 100 - Elimination of the Operatina Basis Earthauake Subsection IV, paragraph (a)(2) of 10 CFR 100, Appendix A, requires that structures, systems and components be designed to remain functional when subjected to an Operating Basis Earthquake (0BE). The NRC staff and industry groups have analyzed in detail the problems associated with including the OBE in the design of plant piping and equipment support systems (e.g., see SECY-93-087). ,

i System 80+ is designed for Safe Shutdown Earthquake of 0.39 and it has been shown that all design basis safety criteria are met. Removal of i

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.the OBE decreases the number of analyses required and.results in '

" improved (and simplified) piping and equipment support systems.

llowever, plant safety has not been decreased. NRC staff concurrence is documented in the advance copy of the System 80+ FSER, Section 3.1.1.

i The System 80+ design analysis performed using the Safe Shutdown Earthquake complies with exemption criteria (a)(1), (a)(2)(ii), and (a)(2)(iii) of 10 CFR 50.12.

10 CFR 50.34(f) - Dedicated Vent for Severe Accident Mitiaation Paragraph (3)(iv) of 10 CFR 50.34(f) states that designs should provide "one or more dedicated containment penetrations, equivalent in size'to a single 3-foot diameter opening, in order to not preclude future installation or systems to prevent containment failure". System 80+

advanced design features address all severe accident issues, including containment integrity, overpressurization, and the need for venting; however, a dedicated vent and/or its penetration are not included in the design.

Based on the System 80+ Probabilistic Risk Assessment, the containment failure probability given a severely damaged core is only 4% (i.e., the probability of maintaining containment integrity, given a severely damaged core, is 96%), as documented in Section 19.12.2.3 of CESSAR-DC.

Due to the robustness of the System 80+ containment design, a dedicated filtered containment vent is approximately seven orders of magnitude from being cost effective (see CESSAR-DC, Appendix 19A, Table 19A.2-1).

This evaluation of System 80+ containment integrity meets exemption criteria (a)(1), (a)(2)(ii), and (a)(2)(iii) of 10 CFR 50.12.

10 CFR 50. Anp_endix J - Assumptions for leak Rate Testing Strict application of Appendix J would not allow isolation, repair, or adjustment to a leakage barrier during a " Type A" test. However, consistent with common practice, isolation or repair of certain leaks are allowed for the System 80+ design (see CESSAR-DC, Section 6.2.6 for details).

Based on a proposed revision to Appendix J and specific conditions identified in Section 6.2.6 of the System 80+ FSER, the NRC staff has concurred with this exemption. This evaluation meets exemption criteria (a)(1), (a)(2)(ii), and (a)(2)(iii) of 10 CFR 50.12.

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l 10 CFR 50.34(f) - Post-Accidgnt Samolina System (PASS) Desian i

Paragraph (2)(viii) of 10 CFR 50.34(f) requires the capability to obtain l and analyze samples of reactor coolant for certain materials, including l chloride. The System 80+ post-accident sampling design, Section 9.3.2

, of CESSAR-DC, does not require the capability for chloride analysis.

In its response to NRC staff's policy paper SECY-03-087, the Commission deleted the requirement for post-accident sampling for chlorides (see the Commission's staff requirements memorandum dated July 21,1993).

The staff documented its recognition that chloride sampling was not a requirement in the advance copy of the System 80+ FSER, Section 9.3.2, Based on the documentation in SECY-93-087 and the Commission's response, I the System 80t PASS meets exemption criteria (a)(1), (a)(2)(ii), and j (a)(2)(iii) of 10 CFR 50.12.

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