ML15170A037
| ML15170A037 | |
| Person / Time | |
|---|---|
| Site: | 05200045 |
| Issue date: | 06/19/2015 |
| From: | GE-Hitachi Nuclear Energy Americas |
| To: | Office of New Reactors |
| Shared Package | |
| ML15170A034 | List: |
| References | |
| MFN 15-044 | |
| Download: ML15170A037 (5) | |
Text
Enclosure 2 MFN 15-044 GEH Response to Item #17 ABWR DCD DRAFT Revision 6 Markups IMPORTANT NOTICE REGARDING CONTENTS OF THIS DOCUMENT Please Read Carefully The information contained in this document is furnished solely for the purpose(s) stated in the transmittal letter. The only undertakings of GEH with respect to information in this document are contained in the contracts between GEH and its customers or participating utilities, and nothing contained in this document shall be construed as changing that contract. The use of this information by anyone for any purpose other than that for which it is intended is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.
Conformance with Standard Review Plan and Applicability of Codes and Standards 1.8 -46 25A5675AC Revision 6 Design Control Document/Tier 2 ABWR
[H-46855B 1979 Human Engineering Requirements for Military Systems, Equipment and Facilities](5)
[HDBK-217 Latest Edition Reliability Prediction of Electronic Equipment](3)
[HDBK-251 Latest Edition Reliability/Design: Thermal Applications](3)
[HDBK-759A 1981 Human Factors Engineering Design for Army Material](5)
STD-282 1956 Filter Units, Protective Clothing Gas-Mask Components and Related Products: Performance-Test Methods
[STD-461C 1987 Electromagnetic Emission and Susceptibility Requirements for the Control of Electromagnetic Interference](3)(4)
[STD-462 1967 Measurement of Electromagnetic Interference Characteristics](3)(4)
[STD-1472D 1989 Human Engineering Design Criteria for Military Systems, Equipment and Facilities](5)
[STD-1478 1991 Task Performance Analysis](5)
Others ASCE 7 1988 Minimum Design Loads for Buildings and Other Structures ERDA 76-21 1976 Testing of Ventilation Systems, Section 9 of Industrial Ventilation Systems
[IEC 801-2 1991 Electronic Capability for Industrial-Process Measurement and Control Equipment](3)
[IEC 880 1986 Software for Computers in the Safety Systems of Nuclear Power Stations](3)(4)
[IEC 964 1989 Design for Control Rooms of Nuclear Power Plants, Bureau Central de la Commission Electrotechnique Internationale](5)
[ISO 7498 1984 Open Systems Interconnection-Basic Refence Model, as the Data Link Layer and Physical Layer](3)
OSHA 1910.179 1990 Overhead and Gantry Cranes NEI 12-02 2012 Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation TEMA C 1978 Standards of Tubular Exchanger Manufacturers Association UL-44 1983 Rubber-Insulated Wires and Cables UL-489 1991 Molded-Case Circuit Breakers and Circuit Breaker Enclosures UL-845 1988 Standard for Safety Motor Control Centers - Low Voltage Circuit Breakers Crane Manufacturers Association of America, Specification No. 70 Table 1.8-21 Industrial Codes and Standards* Applicable to ABWR (Continued)
Code or Standard Number Year Title NEI 91-04 R1 1994 Severe Accident Issue Closure Guidelines NEI 06-12 R2 2006 B.5.b Phase 2 & 3 Submittal Guideline NEI 12-06 R0, 2012 Diverse and Flexible Coping Strategies (FLEX) Implementation Guide NEI 14-01 R0 2014 Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents
Plant Procedures 13.5-1 25A5675AR Revision 5 Design Control Document/Tier 2 ABWR 13.5 Plant Procedures 13.5.1 Administrative Procedures Out of ABWR Standard Plant scope.
13.5.2 Operating and Maintenance Procedures Out of ABWR Standard Plant scope.
13.5.3 COL License Information 13.5.3.1 Plant Operating Procedures Development Plan A Plant Operating Procedures Development Plan shall be generated which establishes:
That the scope encompassed by the procedures development process includes those operating procedures defined in Subsection 13.5.3.4, which direct operator actions during normal, abnormal and emergency operations, including consideration of plant operations during periods when plant systems/equipment are undergoing test, maintenance or inspection.
The methods and criteria for the development, verification and validation, implementation, maintenance and revision of procedures. The methods and criteria shall be in accordance with TMI Items I.C.1 and I.C.9.
13.5.3.2 Emergency Procedures Development In addition to the above, for Emergency Procedures development, the plan shall establish:
That a writer's guide shall be developed and implemented which defines the process for developing emergency procedures. The writer's guide shall contain objective criteria which will require that the emergency procedures developed are consistent in organization, style, content and usage of terms.
The form and content of the documentation describing the emergency procedure development activity results which includes, but is not limited to: (1) the objectives of the emergency procedure development process, (2) the methods employed during emergency procedure development, (3) deviations from generic technical guidelines approved by the NRC and (4) discussion of any design change recommendations and/or negative implications that the current design may have on safe operation as a result of emergency procedures development plan implementation.
The procedure development will integrate the Emergency Operating Procedures (EOPs), Severe Accident Management Guidelines (SAMGs), FLEX Support Guidelines (FSGs) and Extensive Damage Mitigation Guidelines (EDMGs) by using the following guidance:
- Industry (BWROG) guidance as endorsed by applicable NRC regulatory guides consistent with the Task Force recommendation as described in SECY-11-0124 (Reference 13.5-9).
- Plant Specific Technical Guidelines (PSTGs), EOPs and SAMGs development activities using as inputs the standard ABWR guidelines (DCD) and generic industry guidance per NEI 91-04, Revision 1, Severe Accident Issue Closure Guidelines (Reference 13.5-10),
which includes the industry commitment to incorporate severe accident strategies into the overall accident management program.
- EDMGs development as described in NEI 06-12, Reference 13.5-11.
- The EOPs, EDMGs, FSGs and SAMGs will be integrated in a cohesive, effective and useable manner as described in NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents (Reference 13.5-13).
Plant Procedures 13.5-9 25A5675AR Revision 5 Design Control Document/Tier 2 ABWR 13.5.4 References In addition to the sources cited previously, accepted methods and criteria for development of plant procedures are embodied in the following documents.
13.5-1 Gilmore, et al, User-Computer Interface in Process Control: A Human Factors Engineering Handbook, Academic Press, San Diego, Ca, 1989 13.5-2 IEC 964, Design for Control Rooms of Nuclear Power Plants, Bureau Central de la Commission Electrotechnique Internationale 13.5-3 MIL-H-46855B, Human Engineering Requirements for Military Systems, Equipment and Facilities, Dept. of Defense 13.5-4 MIL-STD-1472D, Human Engineering Design Criteria for Military Systems, Equipment and Facilities, Dept. of Defense 13.5-5 NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures, USNRC, 1982 13.5-6 NUREG-1358, Lessons Learned From the Special Inspection Program for Emergency Operating Procedures, USNRC, 1989 13.5-7 NUREG-1358, Supplement 1, Lessons Learned From the Special Inspection Program for Emergency Operating Procedures, USNRC, 1992 13.5-8 NUREG/CR-5228, Techniques for Preparing Flowchart Format Emergency Operating Procedures (Vols. 1 & 2), USNRC, 1989 13.5-9 SECY-11-0124, Recommended Actions to be Taken Without Delay from the Near-Term Task Force Report, USNRC, September 9, 2011.
13.5-10 NEI 91-04 Revision 1, Severe Accident Issue Closure Guidelines, NEI, 1994.
13.5-11 NEI 06-12 Revision 2, B.5.b Phase 2 & 3 Submittal Guideline, NEI, 2006.
13.5-12 NEI 12-06 Revision 0, " Diverse and Flexible Coping Strategies (FLEX) Implementation Guide", NEI, 2012.
13.5-13 NEI 14-01 Revision 0, "Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents", NEI, 2014.
Conformance with Standard Review Plan and Applicability of Codes and Standards 1.8 -70 25A5675AC Revision 6 Design Control Document/Tier 2 ABWR 1370 9/89 Resolution of USI A-48 Subsection 19B.2.18 1275 2/91 Volume 6, Operating Experience Feedback Report Solenoid Operated Valve Problems 1339 6/90 Resolution of Generic Safety Issue 29: Bolting Degradation of Failure in Nuclear Power Plants Subsection 19B.2.62 CR-3922 1/85 Survey and Evaluation of System Interaction Events and Sources, Vol. 1, 2 Subsection 19B.2.59 CR-4261 3/86 Assessment of Systems Interactions in Nuclear Power Plants Subsection 19B.2.59 CR-4262 5/85 Effects of Control System Failures on Transients, Accidents at a GE BWR, Vol. 1 and 2 CR-4387 12/85 Effects of Control System Failures on Transient and Accidents and Core-Melt Frequencies at a GE BWR CR-4470 5/86 Survey and Evaluation of Vital Instrumentation and Control Power Supply Events CR-5055 5/88 Atmospheric Diffusion for Control Room Habitability Assessment Subsection 19B.2.40 CR-5088 1/89 Fire Risk Scoping Study: Investigation of Nuclear Power Plant Fire Risk, Including Previously Unaddressed Issues.
CR-5230 4/89 Shutdown Decay Heat Removal Analysis: Plant Case Studies and Special Issues CR-5347 6/89 Recommendations for Resolution of Public Comments on USI A-40 Subsection 19B.2.14 CR-5458 12/89 Value-Impact Assess for Candidate Operating Procedure Upgrade Program CR-4674 84/89 Precusors to Potential Severe Core Damage Accidents: Series Commission Order EA 051 3/12 Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instruments Interim Staff Guidance JLD-ISG-2012-03 8/12 Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation Table 1.8-22 Experience Information Applicable to ABWR (Continued)
No.
Issue Date Title Comment SECY-11-0124 9/11 Recommended Actions to be Taken Without Delay from the Near-Term Task Force Report Subsection 13.5.3.2