ML15170A037

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Enclosure 2 to Mfn 15-044, GEH Response to Item #17, ABWR DCD Draft Revision 6 Markups
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.

25A5675AC Revision 6 ABWR Design Control Document/Tier 2 Table 1.8-21 Industrial Codes and Standards* Applicable to ABWR (Continued)

Code or Standard Number Year Title

[H-46855B 1979 Human Engineering Requirements for Military Systems, Equipment and Facilities](5)

[HDBK-217 Latest Reliability Prediction of Electronic Equipment](3)

Edition

[HDBK-251 Latest Reliability/Design: Thermal Applications](3)

Edition

[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)

NEI 91-04 R1 1994 Severe Accident Issue Closure Guidelines

[IEC 964 NEI 06-12 1989 R2 2006 Design for Control B.5.b Phase 2 & 3Rooms of Nuclear Submittal Power Plants, Bureau Central Guideline (5) de la Commission Electrotechnique Internationale]

[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 NEI 12-06 R0, 2012 Diverse Instrumentation and Flexible Coping Strategies (FLEX) Implementation Guide NEI TEMA C 14-01 R0 2014 1978 Emergency Response Standards Procedures of Tubular Exchangerand Manufacturers Guidelines for Association Beyond Design Basis Events and Severe Accidents 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 Conformance with Standard Review Plan and Applicability of Codes and Standards 1.8 -46

25A5675AR Revision 5 ABWR Design Control Document/Tier 2 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.

The procedure development will integrate the Emergency Operating Procedures 13.5.3 COL License Information (EOPs), Severe Accident Management Guidelines (SAMGs), FLEX Support Guidelines (FSGs) and Extensive Damage Mitigation Guidelines (EDMGs) by using the following guidance:

13.5.3.1 Plant Operating Procedures

  • Industry Development (BWROG) guidance Plan by applicable NRC regulatory guides as endorsed consistent A Plant Operating with the Development Procedures Task Force recommendation as described Plan shall be generated in SECY-11-0124 which establishes:

(Reference 13.5-9).

  • Plant That the scopeSpecific Technical encompassed Guidelines by the (PSTGs),

procedures EOPs and development SAMGs process development includes those activities using as inputs the standard ABWR guidelines (DCD) and generic industry operating procedures defined in Subsection 13.5.3.4, which direct operator actions during guidance per NEI 91-04, Revision 1, Severe Accident Issue Closure Guidelines (Reference 13.5-10),

normal, abnormal and emergency operations, including consideration of plant operations which includes the industry commitment to incorporate severe accident strategies into during periods when plant systems/equipment are undergoing test, maintenance or the overall accident management program.

inspection.

  • EDMGs development as described in NEI 06-12, Reference 13.5-11.

The methods and criteria for the development, verification and validation, implementation,

  • The EOPs, EDMGs, FSGs and SAMGs will be integrated in a cohesive, effective and maintenance useableand revision manner asof procedures.

described The14-01, in NEI methods and criteria Emergency shall be Procedures Response in accordanceand with TMI Items I.C.1 Guidelines and I.C.9.

for Beyond Design Basis Events and Severe Accidents (Reference 13.5-13).

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.

Plant Procedures 13.5-1

25A5675AR Revision 5 ABWR Design Control Document/Tier 2 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 13.5-9 SECY-11-0124, Recommended Actions to be Taken Without Delay from the Near-Term Task Force 13.5-3 MIL-H-46855B, Human Engineering Requirements Report, USNRC, for Military September 9, 2011.Systems, Equipment and Facilities, Dept. of Defense 13.5-10 NEI 91-04 Revision 1, Severe Accident Issue Closure Guidelines, NEI, 1994.

13.5-4 MIL-STD-1472D, Human Engineering 13.5-11 NEIDesign Criteria for 06-12 Revision Military 2, B.5.b Systems, Phase 2&3 Equipment and Facilities, Dept. of Defense Submittal Guideline, NEI, 2006.

13.5-12 NEI 12-06 Revision 0, " Diverse and Flexible 13.5-5 NUREG-0899, Guidelines for the Preparation Coping of Emergency Strategies (FLEX) OperatingGuide", NEI, Implementation Procedures, USNRC, 1982 2012.

13.5-13 NEI 14-01 Revision 0, "Emergency Response 13.5-6 NUREG-1358, Lessons Learned From the Procedures andSpecial Inspection Guidelines Program for Beyond for Basis Design Events USNRC, Emergency Operating Procedures, and Severe Accidents", NEI, 2014.

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 Plant Procedures 13.5-9

25A5675AC Revision 6 ABWR Design Control Document/Tier 2 Table 1.8-22 Experience Information Applicable to ABWR (Continued)

Issue No. Date Title Comment 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 Subsection Failure in Nuclear Power Plants 19B.2.62 CR-3922 1/85 Survey and Evaluation of System Interaction Events and Sources, Subsection Vol. 1, 2 19B.2.59 CR-4261 3/86 Assessment of Systems Interactions in Nuclear Power Plants Subsection 19B.2.59 CR-4262SECY-11-0124 5/85 Effects 9/11of Control System Failures Recommended onbe Actions to Transients, Accidents Taken Without at from Delay a GE the Near-Term Task BWR, Vol.Report Force 1 and 2 Subsection 13.5.3.2 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 3/12 Issuance of Order to Modify Licenses with Regard to Reliable Spent 051 Fuel Pool Instruments Interim Staff Guidance JLD- 8/12 Compliance with Order EA-12-051, Reliable Spent Fuel Pool ISG- Instrumentation 2012-03 Conformance with Standard Review Plan and Applicability of Codes and Standards 1.8 -70