ML18207A456
| ML18207A456 | |
| Person / Time | |
|---|---|
| Site: | 05200046 |
| Issue date: | 07/20/2018 |
| From: | Korea Hydro & Nuclear Power Co, Ltd |
| To: | Office of New Reactors |
| Shared Package | |
| ML18207A455 | List: |
| References | |
| MKD/NW-18-0109L | |
| Download: ML18207A456 (14) | |
Text
13.05.02.01-5_Rev.3 - 1 / 3 KEPCO/KHNP REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION APR1400 Design Certification Korea Electric Power Corporation / Korea Hydro & Nuclear Power Co., LTD Docket No.52-046 RAI No.: 112-8015 SRP Section: 13 - Conduct of Operations Application Section: 13.05 Date of RAI Issue: 07/24/2015 Question No. 13.05.02.01-5 REQUIREMENTS The paragraph under Section 13.5.2.1.2, Operating Procedure Program, states:
The COL applicant is to provide a program for developing operating and shutdown procedures (COL 13.5(4), COL 13.5(7)).
Associated COL information items COL 13.5(4) and COL 13.5(7), under Section 13.5.3, Combined License Information, state:
COL 13.5(4):
The COL applicant is to provide a program for developing operating procedures.
COL 13.5(7):
The COL applicant is to provide a program for developing shutdown procedures.
Standard Review Plan (SRP) Section 13.5.2.1, Operating and Emergency Operating Procedures, Subsection I.2, states: The staff will review the applicants program for development and implementation of the operating procedures. SRP Section 13.5.2.1, Subsection I.1, identifies Operating Procedure classifications. Procedures that provide instructions for shutdown operations fall under the General Plant Procedures classification of Operating Procedures. Subsection I.1.B describes General Plant Procedures as: Procedures that provide instructions for the integrated operations of the plant, e.g., startup, shutting down, shutdown, power operation and load changing, process monitoring, and fuel handling.
ISSUE The cited text above from Sections 13.5.2.1.2 and 13.5.3 of the DCD, only states that the COL applicant is to provide a program for development of the Operating and Shutdown
13.05.02.01-5_Rev.3 - 2 / 3 KEPCO/KHNP Procedures. The implementation aspect of the program has not been addressed. In accordance with SRP Section 13.5.2.1, Subsection I.2, the staff reviews the COL applicants program for both the development and implementation of these procedures. Note that both the development and implementation aspects of the program for the Emergency Operating Procedures have been addressed in Section 13.5.2.1.3 and associated COL information item COL 13.5(5) in Section13.5.3.
The cited text above from Sections 13.5.2.1.2 and 13.5.3 of the DCD, appears to make a distinction between Operating Procedures and Shutdown Procedures. It is unclear whether the reference to Shutdown Procedures in these sections is intended to identify a set of shutdown procedural instructions other than what is described in SRP Section 13.5.2.1, Subsection I.1.B.
INFORMATION NEEDED Explain: (1) exclusion of the implementation aspect of the Operating Procedure program that is to be provided by the COL applicant, and (2) whether a set of shutdown procedural instructions other than what is described in SRP Section 13.5.2.1, Subsection I.1.B, exists.
Provide any changes necessary to ensure the completeness and accuracy of the information in Section 13.5.2.1.2, Operating Procedure Program, and associated COL information items, COL 13.5(4) and COL 13.5(7), in Section 13.5.3, Combined License Information, for the Operating Procedures.
Response - (Rev. 3)
To be consistent with the SRP, the implementation aspect of operating procedures will be included in the description of COL 13.5(4).
The definition of shutdown procedures was to differentiate between normal operation and shutdown operation. However, based on SRP 13.5.2.1, the definition of operating procedure includes shutdown operation. Therefore, a separate COL item for shutdown procedures is not necessary and will be deleted. COL 13.5(7) will be revised to provide a program for developing and implementing procedures that provide coverage for other safety-related plant operating activities, including related maintenance activities. COL 13.5(6) and associated Section 13.5.2.2 will be revised to ensure the accuracy and consistency of information amongst COL 13.5(6), COL 13.5(7), and Section 13.5.2.2. COL 13.5(8) will remain and be made consistent with the response to RAI 232-7864 for Question 19-6 (Rev.2) as indicated in Attachment.
Impact on DCD DCD Table 1.8-2 and Sections 13.5.2.1.2, 13.5.2.2, and 13.5.3 will be revised as indicated in the attached markup.
13.05.02.01-5_Rev.3 - 3 / 3 KEPCO/KHNP DCD Section 13.5.2.1.2 and Table 19.1-4 will be revised as indicated in the attached markup.
Changed Markups in Table 1.8-2, Section 13.5.3 of this response were already reflected in DCD Rev.2. Furthermore, COL 13.5(7) in DCD Rev.2 will be revised to make the consistency with the revised response to AI 19-142 (#PRA -135) (Rev.1) as indicated in the Attachment (8/11).
Impact on PRA There is no impact on the PRA.
Impact on Technical Specifications There is no impact on the Technical Specification.
Impact on Technical/Topical/Environmental Report There is no impact on any Technical, Topical, or Environment Reports.
RAI 112-8015 - Question 13.05.02.01-5_Rev.3 Attachment (1/11)
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RAI 112-8015 - Question 13.05.02.01-5_Rev.3 Attachment (8/11)
APR1400 DCD TIER 2 COL 13.5(4) The COL applicant is to provide a program for developing and implementing operating procedures.
COL 13.5(5) The COL applicant is to provide a program for developing and implementing emergency operating procedures.
COL 13.5(6) The COL applicant is to describe the procedures that provide coverage for other safety-related plant operating activities (i.e., operating activities not procedurally covered under the operating or emergency operating procedure programs), including related maintenance activities. The COL applicant is to provide a description of the nature, content, and development process for the maintenance and other operating procedures, including preliminary schedules for preparation and target dates for completion. In addition, the COL applicant is to describe how these procedures are classified, describe the general format and content of the various classifications, and identify the group(s) within the operating organization responsible for performing and maintaining the procedures.
COL 13.5(7) The COL applicant is to provide a program for developing and implementing procedures that provide coverage for other safety-related plant operating activities (i.e., operating activities not procedurally covered under the operating or emergency operating procedure programs),
including related maintenance activities.
- The risk can be minimized by appropriate outage management, administrative controls, procedures, and operator knowledge of plant configuration during plant shutdown operation. For example, the removable walls and slabs between areas in a division for equipment replacement must remain intact during plant shutdown operation.
Any SSC maintenance that requires these removable walls and slabs to Delete be removed must be performed during the defueled condition. Also, the foreign material exclusion (FME) program should direct that the covers be installed over the trash racks on the inlet to the holdup volume tank (HVT) during refueling outages.
13.5-4 Rev. 2
RAI 112-8015 - Question 13.05.02.01-5_Rev.3 Attachment (9/11)
APR1400 DCD TIER 2 Table 19.1-4 (23 of 27)
No. Insight Disposition Risk Insights from PRA Models 55 Passive autocatalytic recombiners (PARs) and igniters are normally placed to cope with at-power accidents, but hydrogen control should also be considered for LPSD configurations.
The COL applicant should provide reasonable assurance that there is sufficient hydrogen control COL 13.5(7) during a severe accident condition when the RCS is open (e.g., pressurizer manway, etc.). COL 13.5(8) 56 Solid state switching devices and electro-mechanical relays resistant to relay chatter are used in the Subsection 7.4.2.5 safety I&C platforms. Use of these devices and relays either eliminates or minimizes the mechanical discontinuities associated with mechanical relays at operating reactors.
57 The COL applicant is to perform a seismic walkdown to provide reasonable assurance that the as- COL 19.1(4) designed and as-built plant conforms to the assumptions in the PRA-based seismic margins analysis and that seismic spatial systems interactions do not exist. Details of the seismic walkdown are to be developed by the COL applicant.
58 The fire PRA assumes that the fire barrier management procedures used during LPSD will include Subsection 19.1.6.3.1.2 directions to provide reasonable assurance that breached risk-significant fire barriers can be closed COL 19.1(15) in sufficient time to prevent the spread of fire across the barrier. The procedural direction is to include the use of a fire watch whose duties are commensurate with the risk associated with the barrier. For example, for fire barriers that separate two fire compartments that both contain no COL 19.1(14) equipment or cables necessary to prevent core damage or large release during LPSD conditions, or have been demonstrated to have low risk significance, there will at least be a roving fire watch to check the barrier during rounds. For fire barriers separating fire compartments that contain equipment or cables necessary to prevent core damage or large release during LPSD conditions, and have been demonstrated to be risk significant with respect to fire, a permanent fire watch will be established until the barrier is reclosed. In the latter case, the fire barrier management procedure is to direct that hoses or cables that pass through a fire barrier use isolation devices on both sides of a quick-disconnect mechanism that allow for reclosure of the barrier in a timely fashion to re-establish the barrier prior to fire spread across the barrier.
19.1-351 Rev. 2
RAI 112-8015 - Question 13.05.02.01-5_Rev.3 Attachment (10/11)
APR1400 DCD TIER 2 Table 19.1-4 (25 of 27)
No. Insight Disposition Risk Insights from PRA Models 62 The LPSD PRA assumes that Pressurizer manway is opened before midloop conditions are reached. Subsection 19.2.2.2 In order to assure that the nozzle dam design pressure limit is not exceeded during reduced COL 13.5(7) inventory operations with boiling conditions in the reactor vessel, the APR1400 design includes a COL 13.5(8) requirement that will be imposed to establish a mid-loop vent pathway via the pressurizer manway before operating in reduced inventory. The nozzle dams are installed in the cold legs first and in the hot legs second. The nozzle dams are removed in the hot legs first and in the cold legs second.
Before cold leg nozzle dam installation or removal and cold leg maintenance, the steam generator hot leg manway and its associated hot leg pipe should be kept open. When the manway is opened to the containment atmosphere, the surge line provides sufficient venting capacity to prevent RCS pressurization and subsequent nozzle dam failure 63 Mid-loop operation should be started at least 4 days after shutdown and equal to or less than TS 3.4.8 57.2 °C (135 °F) of initial hot leg temperature.
64 The LPSD SFIA assumes that procedural guidance is developed to ensure that in fire compartments Subsection 19.1.6.3.1.3 containing post-seismic or post-fire safe shutdown equipment that: COL 19.1(21) the seismic ruggedness of temporary ignition sources is adequate, or that the duration that these temporary ignition sources are in these areas is minimized, the seismic ruggedness of temporary equipment such as scaffolding in fire compartments containing potential seismic-fire ignition sources, or near fire protection equipment is adequate, and either the duration of activities which could impact manual firefighting is minimized, or alternative firefighting equipment (e.g., pre-stage portable smoke removal equipment, prestage additional firefighting equipment, etc.) is supplied.
65 The probability of IRWST suction strainer plugging is not increased relative to the power operation Subsection 19.1.6.1.2.5 PRA model. The IRWST design characteristics (e.g., large, separation between suction lines, debris filtering capability) and plant procedures (e.g., foreign material control) are expected to provide reasonable assurance that this probability is low.
19.1-353 Rev. 2
RAI 112-8015 - Question 13.05.02.01-5_Rev.3 Attachment (11/11)
APR1400 DCD TIER 2 Table 19.1-4 (27 of 27)
No. Insight Disposition Risk Insights from PRA Models 67 The flood PRA assumes that maintenance-induced flooding events is an insignificant contributors to Subsection 19.1.5.3.1.5 overall flood risk. Subsection 19.1.6.4.1.2 COL 19.1(17) 68 The core exit thermocouples (CETs) provide representative indications of the core exit temperature Subsection 19.1.6.1.1.5 when shutdown cooling system (SCS) is operational, including reduced inventory operations.
Continuous, redundant narrow range RCS water level indication is operational during reduced inventory operations.
69 The HG design is composed of 30 PARs and 8 igniters. The LPSD Level 2 PRA assumes that the Subsection 19.1.6.1.1.5 25% of the PARs are unavailable due to test and maintenance. The remaining 75% of the PARs and COL 13.5(7) COL 13.5(8) all of the igniters are available during LPSD conditions. COL 19.2(3) 19.1-355 Rev. 2