ML19332E570
| ML19332E570 | |
| Person / Time | |
|---|---|
| Issue date: | 11/28/1989 |
| From: | Kenyon T Office of Nuclear Reactor Regulation |
| To: | Kintner E GENERAL PUBLIC UTILITIES CORP. |
| References | |
| PROJECT-669A NUDOCS 8912070390 | |
| Download: ML19332E570 (4) | |
Text
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' Project No. 669 November 28, 1989
.Mr. E. E. Kintner, Chairman
.ALWR Utility Steering Committee GPU Nuclear Corporation One Upper Pond _ Road e
Parsippany,.New Jersey 07054
Dear Mr..Kintner:
SUBJECT:
REQUEST-FOR ADDITIONAL INFORMATION ON EPRI-ALWR REQUIREMENTS
~l DOCUMENT
' As a result of our review of your July 3,.1989 response to our request for additional information relative _to the ALWR Requirements Document Chapter 6, 4
. and your August 18, 1989 response relative to Chapters 6, 7, 8, 9,.12, and 13, i
we require additional.information in order to complete our review of the design..The additional information.is needed in the area of. reactor safeguards and is covered in'the enclosed questions.
Please respond to this request within 60 days of the date of this letter.
If.
.you-have any questions regarding this matter, call'me at (301) 492-1120.
lThe reporting and/or recordkeeping requirements contained in this letter affect i
fewer than ten respondents; therefore, OMB clearance'is not required under P.L.
296-511.--
Sincerely,
/s/
Thomas J. Kenyon, Project Manager Standardization and Life Extension Project Directorate 1
Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation l
Enclosure:
'As stated-
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November 28, 1989.
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L Project No. 669 l
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Mr. E.,E. Kintner, Chairman
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LALWR Utility Steering Committee 1 e
'GPU Nuclear Corporationi a
One Upper Pond Road Parsippany,.New Jersey 07054.
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Dear Mr. Kintner:
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SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON EPRI ALWR REQUIREMENTS-i DOCUMENT (TACS M71248/M71803/M71804) u q
As a result of-our review of your July 3,1989, response to our requast for additional information relative to the ALWR Requirements Document Chapter 6,
-and your August 18, 1989, response relative to Chapters 6, 7, 8, 9,'12, and 13,
.i
.we' require' additional. infonnation in order to complete our. review of the design. -The additional information is needed in the area of reactor safeguards 11 and 1s covered.in the enclosed questions.
j Ed Please respond _to this request within 60 days of the date of this~ letter.
If l
N
- you' have. any -questions regarding this matter, call me at-(301) 492-1120.
j 5
The reporting and/or recordkeeping requirements contained in this letter affect j
fewer thaniten respondents; therefore, OMB clearance is not required unoer P.L.
F 96-511.
L Sincerely,
)W Thomas J. kenyon,9roject Manager Standardiz6 tion and Life Extension Project Directorate Division of Reactor Projects - III, L
IV,~ V and Special Projects L
Office of Nuclear Reactor Regulation
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Enclosure:
~
As stated i
Lcc w/ enclosure: William Sugnet
-Nuclear Power Division L'
Electric Power Research Institute i
P.O. Box 10412 i
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Palo Alto, California 94303 u
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- Advanced Light _ Water Reactor Requirements Document u
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REQUEST FOR ADDITIONAL INFORMATION Chapter 6/
910.10 ' The July 3,1989 response to question 1 (and the August 18, 1989 response
> to question 5 on Chapter 9) state that the ALWR Requirements Document has y
no specific requirement at this-time for. ALWR designers to do more than E' ~
comply with security system requirements of 10 CFR Part 73 for protection
'against insiders. However, haven't'some design requirements been included, L perhaps to reduce operator error concerns, that inherently would result in N
s less risk from insiders? Discuss any new reactor system requirements.that could result' in reduced opportunities (compared to current reactors) for.
1 radiological sabotage to' result from action of a single insider. The NRC's
~ desire, as expressed in the Severe Accident Policy Statement is to-decrease the reliance on security measures'in protecting agalnst s
i-p
-radiological sabotage by increasing inherent protection designed into the n
. reactor.
L
- 910,21
.The July 3 1989: response to question 1 states that Section 5 of Chapter 9 describes the measures to protect against insider sabotage. Which of the provisions in that referenced section are intended to protect against an insider with authorized access to vital equipment?
'910.3-LThe July.3,1989 response to question 5 refers to NUREG 1398, which does
-not exist. The Access Delay Technology Transfer Manual issued by Department of Energy's Office of Safeguards and Security would be a good reference for this data, but its distribution is restricted by DOE as-Unclassified Controlled Nuclear Information..
I:
Cliapter 8
.910.4 The August 18. 1989 response to question 1 agrees to add to Chapter 5 of the Requirements Document a requirement for remote positive indication of correct manual valve isolation valve-alignment, and that' position indication. switches-on both manual and motor-operated valves be
- tamper-indicating and line supervised. However, that response appears to
~11mit. the scope of this to valves "of each bypassed or deliberately induced b
inoperable condition that meets all:three of the guidelines specified in.
l
- Regulatory Guide 1.47.".To meet the intent, why wouldn't a better scope be l
either all systems and components required (by Criterion 20 of Appendix A to 10 CFR Part 50) to be automatically (initiated by the protection system, l-or those designated as vital systems?
Also, the July 3, 1989 response to
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L l question 4 on Chapter 6. which stated that no specific requirements are imposed to detect equipment disablement by an authorized insider, should be updated to be consistent with this position.)
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'44-Advanced Light-Water Reactor Requirements Document v
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REQUEST FOR ADDITIONAL INFORMATION Chapter 9 910.5' The August-18,1989 ' response to question 6 states that EPRI believes that L
personnel access' constraint procedures are compatible with the cited ALWR access requirement, but that." careful evaluation and appropriate design
-planning wre needed to achieve this." Discuss why that design planning should not be included in the. Requirements Document as a requirement in i order to assure compatibility.
'910.6'
.The August ~ 18,~1989 response to question 9(b) says that there are no words-in the Requirements Document that specifically reject the concept of an
-alternative dedicated shutdown facility. Section 8.1.3 of Chapter. 9,
' discussion of Generic Issue A-29, states
- i 1
"This-issueLis addressed in Section B.1,: Appendix B, of Chapter 5 which-concluded that addition of such a system was not warranted for ALWR plants."
910.7 The August 18, 1989 responsetoquestion9(c)notesthatrequirementsin
- Chapter 5, Section 6.6.3.4, require alternatives to reliance on the essential service water intake structure for introducing _ water into 4'
containment.- However, the cited section only requires means inde undent of station normal or emergency ac power supplies.
It would be possiale for.a reactor designer to meet that requirement with a diesel powered pump L
located within the same intake structure as the service water pumps.
Discuss' whether a requirement should be added that specifically-requires
. provisions for connecting a portable pump to an existing system as a means for introducing water into' containment independent of the intake structure.
910.8 Discuss how the August 18, 1989 response to question 14 would apply to BWR designs.
910.9
The NRC's Regulatory Effectiveness ~ Review program has reported, in
~
restricted distribution-documents, instances where traditional security barriers in subterranean passages were judged to be ineffective-in preventing individuals from gaining undetected access to the protected
. area..Some barriers could be penetrated within minutes with hand carried tools.L Please reconsider NRC comment 20 in light of this information.
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