ML15212A762
| ML15212A762 | |
| Person / Time | |
|---|---|
| Site: | 05200045 |
| Issue date: | 07/30/2015 |
| From: | Head J Hitachi-GE Nuclear Energy, Ltd |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| MFN-15-064 | |
| Download: ML15212A762 (13) | |
Text
C~F Hit~rhi Nie~Ipir Fnnrnv H ITAC H I Jerald G. Head Senior Vice President, Regulatory Affairs 3901 Castle Hayne Road PO Box 780 M/C A-1 8 Wilmington, NC 28402-0780 USA T 910 819 5692 F 910 362 5692 jerald.head@ge.com MFN 15-064 Docket number: 52-045 July 30, 2015 US Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001
Subject:
Request for Additional Information Letter Number 6 Related to Chapter 9 for GE-Hitachi Nuclear Energy Advanced Boiling-Water Reactor Design Certification Rule Renewal Application - GEH Response to RAI 09.05.01-1
References:
Subject:
Request for Additional Information Letter Number 6 Related to Chapter 9 for GE-Hitachi Nuclear Energy Advanced Boiling-Water Reactor Design Certification Rule Renewal Application, April 29, 2015 In regard to the Requests for Additional Information transmitted in your April 29, 2015 letter, Reference 1, please find attached GEH's response to RAI 09.05.01-1. contains the complete response while Enclosure 2 contains the Design Control Document markups associated with this response..
If you have any questions concerning this letter, please contact Hugh Upton at 408-314-8499.
I declare under penalty of perjury that the foregoing information is true and correct to the best of my knowledge, information, and belief.
Sincerely, Jerald G. Head Senior Vice President, Regulatory Affairs
MFN 15-064 Page 2 of 2 Commitments: No additional commitments are made in this response.
Enclosures:
- 2. GEH Supplemental Response to RAI 09.05.01 ABWR DCD DRAFT Revision 6 Markups cc: Adrian Muniz, NRC David Sledzik, GEH Peter Yandow, GEH Patricia Campbell, GEH Shailesh R. Sheth, GEH Hugh A. Upton, GEH James A. Beard, GEH Erik Kirstein, GEH DBR - 0012107 IVIFN 15-064 GEH Response to RAI 09.05.01-1 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.
MFN 15-064 Page 1 of 3 NRC Request for Additional Information 09.05.01-1 (Item 11):
On July 13, 1994, the U.S. Nuclear Regulatory Commission (NRC) issued the final design approval (FDA), along with the "Final Safety Evaluation Report [FSER] Related to the Certification of the Advanced Boiling Water Reactor Design" (NUREG-1503). On May 12, 1997, the NRC issued the final design certification rule (DCR) for the Advanced Boiling Water Reactor (ABWR) design in the Federal Register (62 FR 25800).
10 CFR 52.59(a) (2014) requires, in pertinent part, a finding of compliance with the regulations in effect at the time of original certification in order to issue a renewed design certification. In 1997, operating license Final Safety Analysis Reports (FSARs) were already required by 10 CFR 50.48(a) to include "[tjhe means to limit fire damage to structures, systems, or components important to safety so that the capability to safely shut down the plant is ensured." However, further developments in the area of fire protection have taken place since then. Based on results from the industry documented in the 2002 EPRI Report No. 1006961, "Spurious Actuation of Electrical Circuits Due to Cable Fires," and NRC fire tests conducted after the certification of the ABWR DCD, as documented in the 2006 NUREGICR-6931, "Cable Response to Live Fire,"
(ADAMS Accession Nos. ML081190230, ML081190248, and ML081190261), the NRC staff's position is that fire-induced circuit failures can cause spurious actuations, including multiple spurious actuations, and that a plant's fire hazard analysis should account for these spurious actuations in assessing the plant's safe shutdown capability.
In SECY-08-0093, "Resolution of Issues Related to Fire-Induced Circuit Failures," dated June 30, 2008 (ADAMS Accession No. ML081370346), the Commission was informed of the NRC's staff approach to resolving issues concerning fire-induced circuit failures and multiple spurious actuations. This SECY paper included a clarification of fire-induced circuit fault requirements as well as a commitment to develop additional evaluation methods and publish them in the appropriate regulatory document. As stated in the SECY paper, for new reactor plants, the applicants must demonstrate that they have systematically identified possible multiple spurious actuation scenarios that could prevent safe shutdown and must describe their approach to addressing each scenario such that post-fire safe shutdown is ensured. On September 3, 2008, the Commission approved the approach described in SECY-08-0093 as documented in the staff requirements memorandum (SRM) on SECY-08-0093 (ADAMS Accession No. ML082470571).
Regulatory Guide (RG) 1.189, Revision 2, "Fire Protection for Nuclear Power Plants," provides guidance on the issue of multiple spurious actuations. RG 1.189 endorses Nuclear Energy Institute (NEI) 00-01, Revision 2, "Guidance for Post Fire Safe Shutdown Circuit Analysis," with several exceptions.
GEH-ABWR DCD Tier 2, Section 9.5.1, "Fire Protection System," does not contain a discussion on the effects of multiple spurious actuations due to a fire. Addressing multiple spurious actuations due to the effects of fire is necessary to ensure compliance with 10 CFR 50.48(a)
(1997).
Therefore, in accordance with 10 CFR 52.59(a) (2014) and 10 CFR 50.48(a) (1997), the applicant is requested to perform an evaluation for the effects of multiple spurious actuations due to a fire that is consistent with NEI 00-01, Revision 2, as modified in RG 1.89, Revision 2, or if an alternative approach is used, justify how the alternative approach complies with NRC regulations.
MFN 15-064 Page 2 of 3 GEH Response:
A detailed assessment of the ABWRs vulnerability to Multiple Spurious Operations (MSO) would need to be conducted during the plant detailed design of the COL phase. GEH will include in ABWR DCD Subsection 9.5.13 a COL License Information item requiring that Multiple Spurious Operations (MSO) be addressed at the time of COL Application.
In the way of supporting information, GEH led an MSO evaluation of an ABWR design currently under review following the methodology of NEI 00-01. The ABWR design reviewed was largely consistent with the US Design Certified ABWR especially in the areas of separation, both physically and electrically. The MSO expert panel determined that there were no scenarios that would prevent the ABWR from being shut down and maintained in a safe state. The focus of this MSO was deterministic in that it postulated "hot shorts" in copper wiring causing an undesirable spurious operation or actuation.
In ABWR DCD R5 paragraph 9.5.1.1.7 the probability of spurious operations resulting from the digital I&C systems is addressed. For the ABWR digital I&C systems the probability of spurious operations is considered to be practically zero.
Impact on DCD The ABWR DCD will be revised as follows to address this RAI:
- 1) Section 1.8; Table 1.8-20 Revise the entry for Regulatory Guide 1.189 to indicate that revision 2 issued October 2009 is applicable to NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 2, May 2009.
- 2) Section 1.8; Table 1.8-21 Add in section "other", "NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 2, May 2009"
- 3) Section 1.9 Table 1.9-1 Add item 9.39; "Multiple Spurious Operations Evaluation" 9.5.13.22
- 4) Section 9.5.1 Add new Section 9.5.1.6.5:
9.5.1.6.5 Multiple Spurious Operations Evaluation The COL applicant shall provide an evaluation of the ABWR's susceptibility to Multiple Spurious Operations (MSO) in accordance with the methodology contained in NEI 00-01, Guidance For Post Fire Safe Shutdown Circuit Analysis, Revision 2 and as modified by Regulatory Guide 1.189, Revision 2. The COL applicant will submit the results of this evaluation to the NRC for review. See Subsection 9.5.13.22 for COL license information item.
MFN 15-064 Page 3 of 3 Enclosure I Add new section 9.5.13.22 9.5.13.22 Multiple Spurious Operations Evaluation The COL applicant shall provide an evaluation of the ABWR's susceptibility to Multiple Spurious Operations (MSO) in accordance with the methodology contained in NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 2 and as modified by Regulatory Guide 1.189, Revision 2. The COL applicant will submit the results of this evaluation to the NRC for review.
Section 9.5.14 Add new reference 9.5-10 9.5-10 "NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 2, May 2009" The ABWR DCD R5 revised marked up pages are provided in Enclosure 2.
MFN 15-064 GEH Response to RAI 09.05.01-1 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 5 ABWR Design Control Document/Tier 2 Table 1.8-20 NRC Regulatory Guides Applicable to ABWR (Continued)
Appl.
Issued ABWR RG No. Regulatory Guide Title Rev.
Date Applicable? Comments 1.142 Safety-Related Concrete Structures for Nuclear Power Plants (Other Than Reactor Vessels and Containments) 1.143 Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants 1.144 Auditing of Quality Assurance Programs Nuclear Power Plants 1.145 Atmospheric Dispersion Models for Potential Accident Consequences Assessments at Nuclear Power Plants 1.146 Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 1.147 Inservice Inspection Code Case Acceptability-ASME Section XI, Division 1 1.148 Functional Specifications for Active Valve Assemblies in Systems Important to Safety in Nuclear Power Plants 1.149 Nuclear Power Plant Simulation Facilities for Use in Operator License Examinations 1.150 Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations 1.151 Instrument Sensing Lines
[1.152 Criteria for Programmable Digital Computer System Software in Safety-Related Systems of Nuclear Power Plants
[1.153 Criteria for Power, Instrumentation, and Control 1
11/81 1
10/79 Super-ceded 1
12/82 Super-ceded 8
11/90 0
4/81 1
5/87 1
2/83 Yes Yes See Table 17.0-1 Yes See Table 17.0-1 Yes Yes COL Applicant Yes Yes Yes](4) 0 0
7/83 11/85 0
12/85 Yes](4)
__1.1 89 Fire Protection for Nuclear Power Plants 2 10/2009 Yes Limited to NEI 00-01 see Table 1.8-21 I
Keporis Jur Pressurized vvater Reactors 1.155 Station Blackout 160 Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 5.1 Serial Numbering of Fuel Assemblies for Light-Water-Cooled Nuclear Power Plants 5.7 Control of Personnel Access to Protected Areas, Vital Areas, and Material Access Areas 0
0 8/88 6/93 Yes Yes Yes Yes 0
12/72 1
5/80 1.8-33 Conformance with Standard Review Plan and Applicability of Codes and Standards
25A5675AC Revision 5 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
[HDBK-217
[HDBK-251
[HDBK-759A STD-282
[STD-461C
[STD-462
[STD-1472D
[STD-1478 Others ASCE 7 ERDA 76-21
[IEC 801-2 1979 Latest Edition Latest Edition 1981 1956 1987 1967 1989 1991 1988 1976 Human Engin@gring Requirements for Military Systems, Equipment and Facilities] oJ Reliability Prediction of Electronic Equipment](3)
Reliability/Design: Thermal Applications](3)
Human Factors Engineering Design for Army Material](5)
Filter Units, Protective Clothing Gas-Mask Components and Related Products: Performance-Test Methods Electromagnetic Emission and Susceptit~lijy, Requirements for the Control of Electromagnetic Interference] ) )
Measurement of Electromagnetic Interference Characteristics](3)(4)
Human Engineering Design Criteria for Military Systems, Equipment and Facilities]?R)
Task Performance Analysis](5)
Minimum Design Loads for Buildings and Other Structures Testing of Ventilation Systems, Section 9 of Industrial Ventilation Systems Electronic.goability for Industrial-Process Measurement and Control 1991
[NEI 00-01 May 2009 Guidance for Post Fire Safe Shutdown Circuit Analysis, Rev. 21 I
lu BMW 1 149 d 05353rware 4)o u Trs in we Sary,)ystems of NvuclearPoe
[IEC 964 1989 gn for Control Rooms of Nuclear Power Plants Bureau Central de la Commission Electrotechnique Intemationale](5,
[ISO 7498 1984 Open Systems Interconnection-asic Refence Model, as the Data Link Layer and Physical Layer(JJ OSHA 1910.179 1990 Overhead and Gantry Cranes 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 Aluminum Construction Manual by Aluminum Association NCIG-01 Rev. 2 Visual Weld Acceptance Criteria for Structural Welding at Nuclear Power Plants I
Conformance with Standard Review Plan and Applicability of Codes and Standards 1.8 -46
25A5675AC Revision 5 ABWR Design Control Document/Tier 2 Table 1.9-1 Summary of ABWR Standard Plant COL License Information (Continued)
Item No.
Subject Subsection 9.28 Plant Security System Criteria 9.5.13.11 9.29 Not Used 9.5.13.12 9.30 Diesel Fuel Refueling Procedures 9.5.13.13 9.31 Portable and Fixed Emergency Communication Systems 9.5.13.14 9.32 Identification of Chemicals 9.5.13.15 9.33 NUREG/CR-0660 Diesel Generator Reliability 9.5.13.16 Recommendations 9.34 Sound-Powered Telephone Units 9.5.13.17 9.35 Fire-Related Administrative Controls 9.5.13.18 9.36 Periodic Testing of Combustion Turbine Generator (CTG) 9.5.13.19 9.37 Operating Procedures for Station Blackout 9.5.13.20 9.38 Quality Assurance Requirements for CTG 9.5.13.21 10.1 Low r
Fracture Toughness 10.2.5.1 10.2 Turbine Desian Oversoeed 10.2.5.2 19.39 Multiple Spurious Operations Evaluation 9.5.13.22 I
10.4 Procedures to Avoid Steam Hammer and Discharge Loads 10.3.7.1 10.5 MSIV Leakage 10.3.7.2 10.6 Radiological Analysis of the TGSS Effluents 10.4.10.1 11.1 Plant-Specific Liquid Radwaste Information 11.2.5.1 11.2 Compliance With Appendix I to 10CFR50 11.3.11.1 11.3 Plant-Specific Solid Radwaste Information 11.4.3.1 11.4 Calculation of Radiation Release Rates 11.5.6.1 11.5 Compliance with the Regulatory Shielding Design Basis 11.5.6.2 11.6 Provisions for Isokinetic Sampling 11.5.6.3 11.7 Sampling of Radioactive Iodine and Particulates 11.5.6.4 11.8 Calibration Frequencies and Techniques 11.5.6.5 12.1 Regulatory Guide 8.10 12.1.4.1 12.2 Regulatory Guide 1.8 12.1.4.2 12.3 Occupational Radiation Exposure 12.1.4.3 12.4 Regulatory Guide 8.8 12.1.4.4 12.5 Compliance with 10CFR20 and 10CFR50 Appendix I 12.2.3.1 12.6 Airborne Radionuclide Concentration Calculation 12.3.7.1 COL License Information 1.9 -9
25A5675AL Revision 5 ABWR Design Control DocumentlTier 2 plant-specific licensing. Items of interest under the administrative controls review will include but not be limited to:
(1)
Control of combustible materials such as combustible/flammable liquids and gases, fire retardant treated wood, plastic materials, and dry ion exchange resins (2)
Transient combustible materials and general housekeeping, including health physics materials (3)
Open-flame and hot-work permits and cutting and welding operations (4)
Quality assurance with respect to fire protection systems components, installation, maintenance, and operation (5)
Qualification of fire protection engineering personnel, fire brigade members, and fire protection systems maintenance and testing personnel (6)
Instruction, training, and drills provided to fire brigade members The COL applicant shall provide the description of these administrative controls to the NRC for review. See Subsection 9.5.13.18 for COL license information.
9.5.
Communication Systems 9.5.1.6.5 Multiple Spurious Operations Evaluation The COL applicant shall provide an evaluation of the ABWR's susceptibility to Multiple Spurious Operations (MSO) in accordance with the methodology contained in NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 2 and as modified by Regulatory Guide 1.189, Revision 2. The COL applicant will submit the results of this evaluation to the NRC for review.
9.5.2.1 ýSee Subsection 9.5.13.22 for COL license information.
9.5.2.1.1 Power-Actuated Paging System The paging system is designed to provide facilities for mutual communication and simultaneous broadcasting in the related buildings of the plant.
9.5.2.1.2 Sound-Powered Telephone System The design basis for the sound-powered telephone system is to provide communication primarily for fuel transfer, testing, calibration, maintenance and emergency conditions.
Other Auxiliary Systems 9.5-27
25A5675AL Revision 5 ABWR Design Control Document/Tier 2 (2)
The operator can accomplish this from the main control room.
(3)
One Class 1 E circuit breaker and one non-Class 1 E circuit breaker exist and are functional between each of the Class IE diesel generator buses and the CTG. (Note that only the circuit breakers for the preselected division are racked in. The remaining two divisions have their Class 1 E breakers normally racked out, as shown in Figure 8.3.1.)
(4)
Each 92 days, verify the combustion turbine generator (CTG) starts and achieves steady state voltage (>6210 V and <7590 V), and frequency (>58.8 Hz and <61.2 Hz) within 2 minutes. Load the CTG to >90% and <100% of its continuous rating and operate it with this load for at least 60 minutes. All CTG starts may be preceded by an engine prelube period.
(5)
The reliability of the CTG is at least 0.95 as calculated by methods defined in NSAC 108, The Reliability of Emergency Diesel Generators at US Nuclear Power Plants.
9.5.13.20 Operating Procedures for Station Blackout Appropriate operating procedures and personnel training shall be developed to:
(1)
Address the operation of the AAC-CTG during an SBO event (2)
Restore other plant offsite (preferred) and onsite emergency power sources as soon as possible (3)
Recover plant HVAC Systems as soon as possible to limit heat rises (4)
Provide additional core, containment, and vital equipment makeup and cooling services, as necessary (5)
Establish orderly plant safe shutdown conditions 9.5.13.21 Quality Assurance Requirements for CTG Quality assurance standards and practices shall be developed to assure continued operational reliability of the CTG as an AAC power source for SBO events, in accordance with Regulatory Guide 1.155 and 10CFR50.63.
9.14 Reference 9.5.13.22 Multiple Spurious Operations Evaluation rnced The COL applicant shall provide an evaluation of the ABWR's susceptibility to
- ioners, Multiple Spurious Operations (MSO) in accordance with the methodology contained in NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 2 and as
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results of this evaluation to the NRC for review.
Other Auxiliary Systems 9.5-71
25A5675AL Revision 5 ABWR Design Control Document/Tier 2 9.5-3 "Design of Smoke Control Systems for Buildings", American Society of Heating, Refrigerating, and Air Conditioning Engineers, Inc., September 1983.
9.5-4 "Recommended Practice for Smoke Control Systems", NFPA 92A, National Fire Protection Association, 1988.
9.5-5 Life Safety Code, NFPA 101, National Fire Protection Association.
9.5-6 "Reliability of Emergency Diesel Generators at U.S. Nuclear Power Plants", Electric Power Research Institute, NSAC-108, September 1986.
9.5-7 Loss of All Alternating Current Power, 10CFR50.63.
9.5-8 Regulatory Guide 1.155-Station Blackout.
9.5-9 "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors", NUMARC-87-00.
9.5-10 "NEI 00-01, Guidance For Post Fire Safe Shutdown Circuit Analysis, Revision 2, May 2009" 9.55-72 Other Auxiliary Systems