ML19354E760

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Forwards Request for Addl Info to Complete Review of Sys 80+ Design Certification for CESSAR-DC,including Fire Protection Analysis,Fuel Assembly Storage Capacity,Storage Densities for Spent Fuel Pool & Spent Fuel Pool Storage Racks
ML19354E760
Person / Time
Site: 05000470
Issue date: 01/24/1990
From: Singh R
Office of Nuclear Reactor Regulation
To: Scherer A
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
PROJECT-675A NUDOCS 9002010306
Download: ML19354E760 (17)


Text

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Project No. 675 January 24, 1990 Hr. A. E. Scherer, Director Nuclear Licensing i

Combustion Engineering l

1000 Prospect Hill Road l

Post Office Box 500 Windsor, Connecticut 06095-0500

Dear Mr. Scherer:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON CESSAR - DC As a result of our review of Group E 2 submittal of CESSAR-DC, we require additional information in order to complete our review of System 80+

design. AdditionalinformationisneededonChapters6(Sections 6.2.2 through6.2.6,and6.4),9(Sections.9.1.,9.2.2,9.2.4 through 9.2.10, 9.3.1, 9.3.3, 9.4.1 through 9.4.8, 9.5.1, and 9.5.4 through 9.5.9) and 10 (Sections 10.1 through 10.3 and 10.4.1).

Please note that chapter 11 does not contain the minimum infonnation required for our review and as such, we have not identified specific information needs on this chapter.

A prompt response to the enclosed request for additional information is' requested.

If you have any questions, please call me at (301) 492-1103.

i Sincerely.

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/s/

Rabi Singh, Project Manager Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects - III, i

IV, Y and Special Projects i

l Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page RSingh l

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Danuary 24, 1990 f

Project No. (75

-l Mr. A. E. Scherer, Director Nuclear Licensing Combustion Engineering i

1000 rrospect Hill Road Post Office Box 500

-t Windsor, Connecticut 06095-0500 j

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Dear Mr. Scherer:

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SUBJECT:

REQUEST FOR ADDITION /,L INf0PmTION ON CESSAR - DC l

i As a result of our review of Group E i submittal of CESSAR-DC, we require l

additional information in order to corplete our review of System 80+

design. Additional information is neuded on Chapters 6 (Sections 6.2.2 through6.2.6,and6.4),9(Sections 9.1., 9.2.2, 9.2.4 through 9.2.10, 9.3.1, 9.3.3, 9.4.1 through 9.4.8, 9.5.1, and 9.5.4 through 9.5.9) and 10 (Sections 10.1 through 10.3 and 10.4.1).

Please note that chapter 11 does not contain the minimum infornation required for our review and as such, we have not identified specific information needs on this chapter, j

A prompt response to the enclosed request for additional information is requested.

If you have any questions, please call me at (301) 492-1103.

Sincerely, Rabi Sintih, Project Mana'er i

Standard'zation and Non-iower l

Reactor Project Directorate Division of Reactor Projects - !!!,

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-IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated F

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Combustion Engineering, Inc.

Project No. 675 Advanced CESSAR cc: Mr. C. B. Brinkman, Manager Washington Nuclear Operations Combustion Engineering, Inc.

7910 Woodmont Avenue, Suite 1310 Bethesda, Maryland 20014 Mr. Ernest' Kennedy Manager of Licensing Combustion Engineering 1000 Prospect Hill Road Post Office Box'500 Windsor, Conntaticut 06095-0500 1

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Enclosure J

REQUEST FOR ADDITIONAL INFORMATION PLANT SYSTEMS BRANCH COMBUSTION ENGINEERING STANDARD SAFETY ANALYSIS REPORT j

DESIGN CERTIFICATION CESSAR-DC, CE SYSTEM 80+

1 PROJECT NO. 675 280.1 Provide the fire protection analysis and/or interface requirements 1

(9.5.1) to ensure that safe shutdown can be achieved, assuming that all.

equipment in any one fire area _will be rendered inoperable by fire and that re-entry into the fire area for. repairs and operator -

actions is not possible with exception of the control room.. For the control room, provide the fire protection analyses and/or interface requirements having an independent alternative shutdown capability

. that is physically and electrically independent of the control room. Also, provide the fire protection requirements for redundant shutdown systems in the reactor containment building that will ensure, as much as practicable, that one shutdown division will be free of fire damage. Additionally, also ensure that smoke, hot gases, or the fire su)pressant will not migrate into other fire areas to the extent t1at they could adversely' affect safe shutdown capabilities, including operator actions.

410.63 You have stated in Section 9.1.1.1, Design Bases, that storage is (9.1.1) provided for 166 new fuel assemblies.

In Section 9.1.1.3.1.3, one of the stated methods of maintaining criticality safety margins is by " limiting the capacity to 166 fuel assemblies." However, in i

l Section 9.1.1.3.4 you have stated that " storage is provided for at least 166 new fuel assemblies..." Clarify these inconsistencies.

Also, provide maximum rated capacity of the new fuel storage racks.

Indicate how that limit will be implemented (e.g.,

administrative controls, plugging of vacant. cells).

410.64 You have identified the different. storage densities for regions I-t (9.1.2) and II of the spent fuel pool'(50% and 75%, respectively) in your submittal. Provide pertinent information concerning the design criteria'and anticipated controls to be implemented for the storage of spent fuel assemblies in the above regions.

410.65 You have stated in Section 9.1.2.3.1.3 that one of the accidents

'{9.1.2) considered in the design of the spent fuel pool storage racks is-a fuel assembly and'its handling. tool " falling into a blocked-off.

fuel storage cavity." Supply additional information concerning.

the mechanical blocking assemblies to allow determination of the l

extent of penetration of a fuel assembly into a blocked cavity.-

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' i 410.66 Your submittal does not provide information concerning the handling l

(9.2) of heavy loads in the vicinity of the spent fuel pool.

Provide an evaluation of the capability of the spent fuel loading pit to withstand a droppeo heavy load. The evaluation should include a shipping cask drop without breach of the pit area or loss of spent fuel pool water.

410.67 The spent fuel pool cooling system (SFPCS) design must include (9.1.3) proper redundancy of components so that safety functions are maintained assuming a sing (ailure of a component coincident with the loss of all offsite power.

Your submittal does not provide the information necessary to verify that the system can continue to perform its intended safety-function without offsite power._ Provide a failure mode and effect analysis (FMEA)'to verify that the system conforms to the above requirement.

410.68 You have stated in your submittal under Section 9.1.3.3.1 that the (9.1.3)

SFPCS has no emergency function during an accident. General Design Criterion (GDC)'44, however, requires that the system be able to perform its intended safety function under accident conditions.-

Verify that the system will be capable of continued operation during all accident conditions.

410.69 You have stated in your submittal under Section 9.1.4.2.1.2 that (9.1.4) an interlock prevents fuel carrier movement unless the transfer tube valve is fully open. Verify that an additional interlock is provided to prevent the transfer tube valve movement while the fuel carrier is passing through the valve or verify that transfer tube valve movement will not cause any fuel damage.

410.70 You have stated in your submittal under Section 9.1.4.2.1.3 that l

(9.1.4) an operator is a backup to electrical zone interlocks. Provide information on translation speed, interlock setpoint margin including obstruction or restricted area, free cable length, etc., to verify l

that the operator action is a viable option concerning the-identification of an interlock failure and follow-up of with proper response.

i 410.71 Section 9.1.4.4, Testing and-Inspection Requirements, discusses j

"preoperational checks." Verify that these checks include equipment testing before each use of fuel handling machines, overhead crane and polar crane. Also, verify that these checks include load testing and other testing designed to detect degradation due to wear or' 4

normal use for the above equipment.

Provide fuel building (2) safety-related equipment locations in the 410.72 layout drawings which show the (1) overhead (9.1.4) heavy load paths and vicinity of those paths susceptible to damage by failure of electrical 4

interlocks, stinging of the load, or other mechanisms for causing damage.

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3-410.73 Provide containment layout drawings showing the reactor vessel (9.1.4) head storage location, the upper guide structure storage stand, the load paths from the reactor to those locations, and safety-related equipment in the vicinity of the load paths susceptible

^o damage by load handling accidents.

410.74 Provide the following for the water systems described under Sections (9.2.1-9.2.1 through 9.2.10:

9.2.10)

(a) Tabulated equipment design parameters at least including anticipated normal and accident heat loads, system design flow rates, heat removal capacities, and tank capacities,

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(b) System piping and instrument diagrams (P& ids) and system descriptions that contain sufficient information to determine the following:

(1)

Interfaces between safety and non-safety portions of systems (including changes in component safety classifications),

Containment penetrations and isolation capabilitics, Complete system flowpaths, Interfaces with other systems and system boundaries, Isolation capabilities between essential and non-essential portions of the systems, and (6) Physical division between redundant portions of the systems, and (c) FMEA for the essential portions of water system to verify.

that these portions can withstand design basis accidents concurrent with a single active failure.

410.7S P. " de the following for the station service water system (SSWS):

(9.2.1)

(a) An analysis to demonstrate that the SSWS pumps will be -

protecteci from abnormally high levels of the ultimate heat sink c%. 2 flooding, (b) Divis h cross-connect information including valve positions and actuations, (c) An analysis concerning the effects of high and moderate energy-line breaks on safety functions of the system, L

(d) Provisions to preclude system failure due to water hamer

events, (e) Provisions to prevent potential radioactive leakage from the component cooling water system to the SSWS, and (f) System evaluation concerning the SSWS dependency on compressed air to perform its safety function.

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410.76 Providethefollowingforthecomponentcoolingwatersystem(CCWS):

(9.2.2)

(a) Information to determine that the CCWS surge tank is sized for the maximum expected leakage from the system for seven days, or H

that Seismic Category I makeup can be aligned within' the tire allowed by surge tank capacity, (b) Information concerning the effects of high and medium energy line breaks on safety function (s) of the system, (c) Provisions to preclude system failure due to water hammer

events, (d) Results of tests demonstrating the ability of the reactor coolant pumps (RCPs)-to operate for 20 minutes without seal cooling or provide provisions for the RCP seal and bearing cooling following the postulated accidents. (Section 9.2.2.2 indicates that RCP cooling functions are nonsafety-related.

Figure 9.2'.2-1 shows these functions isolated on a safeguard signal), and (e) A system evaluation concerning the CCWS's dependency on compressed air to perform its safety function.

410.77 In your submittal you have stated that' (1) the essentiel chilled (9.2.6) water system (ECWS) receives make-up from the condensate storage tank (CST) via a Seismic Category I line following a loss of offsite power and (2) the CST is not safety-related and is not designed as-Seismic Category I.

Provide your justifications concerning the reliance on a nonsafety-related CST to render the safety-re?ated ECWS operable.

1 410.78 Identify the portions of the refueling water system that provide (9.2.7) isolation from the safety-related and non-safety-related systems used to fill and drain the refueling pool (e.g., containment' spray, l

shutdown tooling, chemical and volume control Systems). Also, identify the provisions made to insure that failure of the isolation devices (either mechanical or through human error) will not adversely affect the operability of the safety-related systems.

410.79 Provide an evaluation concerning the conformance of.the turbine building (9.2.8 component cooling ard service water systems with the guidance of Position and and C.2 of Regulatory Guide (RG) 1.29.

9.2.10) 410.80 Provide the following for the chilled water systems:

(9.2.0)

(a) You have stated in Section 9.2.9.2 that, "Each division is totally independent...except for areas where it is physically impractical of unsafe." Provide a single failure analysis for the chilled water systems and assure that the lack of separation will not result in potential single failures, active or passive, that could render the ECWS inoperable, m

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. i (b) Provide ECWS design heat loads for normal and accident conditions. Also provide design details including flow

'j rates, heat removal rates, etc., for the ECWS and normal l

chilled water system, and I

(c) You have stated in your submittal that the ECWS serves primarily safety-related HVAC cooling loads.

Identify-the.

4 non-safety loads served by_the ECWS. Describe the measures provided to insure that these non-safety loads'do not impact the ability of the ECWS to perform its safety-related functions. -

410.81 Provide the following for the compressed air systems:

(9.3.1)

(a) Provide P& ids for the instrument and compressed air system showing portions classified as Quality Group C and Seismic -

Category 1, (b) Provide a list of safety-related as well as nonsafety-related equipment serviced by the instrument air system.

Identify equipment essential to safe shutdown-or accident mitigation.

Include system air capacity versus equipment consumption data and provide an evaluation of the effects of loss of instrument air on this equipment, (c) You have stated in Section 9.3.1.2.1 that in the event of-low instrument air pressure, the station air system will.

automatically supply air to the instrument air system.

Describe the connection between the two systems and the means for protecting the instrument air _ system from a failure in the station air system, and (d)

In Section 9.3.1.3 of your submittal, you have stated that failure of the instrument air system during an accident or station blackout would cause all pneumatically operated valves essential to safe shutdown to fail-in the safe position.

This implies that all pneumatic valves that actuate to mitigate an accident would actuate on-loss of instrument' air.

Provide an analysis that shows that inadvertent actuation of safety-related valves due to failure of the instrument air system will not cause any unsafe conditions that preclude achieving-and maintaining safe shutdown.

410.82 Provide the following for the equipment and floor drain system:

(9.3.3) 1 (a) Provide an analysis of postulated tank failures. This analysis should include the failure of the drain and waste tanks flooding safety-related equipment and/or release of radioactive contents to the environment. Also, these tanks should be classified-Seismic Category I and Quality Group C, 1

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' 6-i (b) Provide an evaluation concerning the ability of the system to withstand active component failures, blockages, and probable i

maximum flood without. inundating safety-related areas, and

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(c) Verify that contaminated liquid waste can not be. inadvertently routed to the noncontaminated drainage systems.

410.83 Provide the following-for the heating, ventilation, and air conditioning (9.4)

(HVAC) systems described under Sections 9.4.1-through 9.4.8:

(a) Tabulated design equipment parameters at least including anticipated normal and accident heat loads, system design airflow rates, heat removal capacities, (b) System P& ids and system descriptions that contain sufficient 1

information to determine:

a (1)

Interfaces between safety and non-safety portions of the systems (including changes in. component safety classifications),

(2 Containment penetrations and isolation capabilities, Complete system flow paths, Interfaces with other systems and system boundaries, Isolation capabilities between essential and non-essential portions of the-systems, and (6) Physical division between redundant portions of the

systems, 3

(c) Provide an FMEA for the essential portions of-each water system since essential portions of. the HVAC systems must be,able to withstand design basis accidents and a concurrent single active failure, and (d) Provide a tabulated summary of environmental design parameters i

L for equipment cooled by the HVAC system in mild environments.

410.84 Concerning the control building ventilation system,' verify that the (9.4.1) intake monitors for the control room outside air supply alarm in l

the control room prior to or upon isolation of an intake.

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that provisions will be made for inservice inspection of control room L

isolation dampers and other control room HVAC dampers.

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410.85 Provide the following for the fuel building ventilation system:

(9.4.2) l (a). Section 9.4.2.1, Design Bases, of your submittal states that the fuel building ventilation system will be in. operation whenever irradiated fuel handling operations in the I

fuel pool are in progress.

Provide the intended system configuration l

and its mode of operation during normal plant operations (other than fuel handling),

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(b) Verify that~the radiation detectors in the exhaust ducts are far enough' upstream of the bypass dampers to ensure that the dampers will have completely. actuated to direct exhaust flow

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through the filter trains before the first airborne radioactive material reaches the bypass dampers, and (c). Provide assurances that system performance will not be affected.

due to" pipe breaks and whip, jet impingement and other.

associated failures of non-seismic systems in the vicinity.

410.86 Concerning the auxiliary and radwaste building ventilation system,.

i (9.4.3) you have stated in Section 9.4.3.2, System Description, that the 1

- general ventilation system is not safety-related and performs no function essential to safe shutdown or post-accident operation.

Provide additional information supporting a~ determination that the system is not required to control radioactive releases from a

the auxiliary building in the post-accident environment.

410.87 Concerning the station service water pump structure ventilation (9.4.6) system, Section 9.4.8 does not providelinformation to preclude-the accumulation of dirt and dust in electrical equipment, and makes no mention of filters. Provide information pertinent to the location of the system intakes and/or other features (e.g.,

cabinet gaskets) designed to prevent the ingress of dust to electrical cabinets.

410.08 Provide the following for the diesel generator. support syttem as (9.5.4-described in Sections 9.5.4 through 9.5.9:

9.5.9)

(a) Verify that the diesel generator building.is tot only Seismic.

Category I, but that it also provides. protection against the affects of missiles and floods as required to meet the-requirements of GDC 2 of Appendix A to 10 CFR 50, (b) Provide system layout diagrams for the diesel generator support systems with sufficient detail so-that component location within (or outside) the diesel generator building can be determined and the accessibility of equipment-for test and maintenance can be evaluated, 1

(c) System P& ids showing equipment classification and clearly identifying system boundaries and system interfaces, (d) FMEAs, 1

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(e) Verify that the system components and structures, including isolation devices between essential and non-essential-portions-of the system, are Seismic Category I.

Also, for those portions of the syst'em not housed in the diesel generator unit structure, provide information verifying that these portions of the system are:

i (1) Seismically qualified, (2) Protected from the results of_the seismic failure of non-safety-related systems, (3) Tornado missile protected, and-(4)

Flood protected, and (f) Provide information concerning the diesel generator engine

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coolingwatersystem(Section9.5.5),(Section9.5.7) alarm starting system (Section 9.5.6), and lube oil system and/or trip signals, including the lock-out circuit logic of-these trip signals during EDG operation following a loss of-4 coolantaccident(LOCA)orlossofoffsitepower(LOSP)and conformance with the guidance of RG 1.9, Position C.7.

410.89-Provide the following for the diesel generator fuel oil system:

(9.5.4)

(a) Verify that the fuel oil storage tank fills and vents are.

located above the probable maximum flood level, l

(b) Verify that the fuel oil sampling and _ impressed current cathodic protection system surveillances are in conformance with the guidance of-RG 1.137, Position C.2, and (c) Verify that sufficient fuel oil storage capacity for 7 days is provided, including consideration of periodic testing and the unusable portion below the EDG suction -location. Also, provide the fuel oil storage and day tank capacities.

Include flow capacity data from the storage tank to the day tank.

410.90 Provide tabulated design data including design _ flow and heat removal (9.5.5) requirements for the. diesel generator engine cooling system, 410.91 Provide tabulated design data including compressor capacity, power

,9.5.6) source and air receiver capacity for the diesel generator engine

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starting system.

410.92 Provide power supply information for the motor-driven pre-lube (9.5.7) oil pump and system design data including pump flows, cooling system heat removal capabilities and electric heater characteristics for the diesel generator engine-lube oil system.

410.93 Provide the following for the diesel generator engine air intake and (9.5.8) exhaust system:

(a) Complete the second sentence of the second paragraph in Section 9.5.8.3 by providing the needed information.

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l (b) Verify that there are no active components in the air intake l

and e haust system, and (c) Identify the restrictions used for. the location of the diesel generator building in relation to possible on-site sources of j

gases which may be intentionally or accidentally released, to I

insure that such releases do not result in degraded operation of the EDG.

410.94 Provide the following for the diesel generator sump pump system:

' (9.5.9)

(a) Verify that this system is evaluated concerning the internal f

flood protection:for the diesel generator building, i

(b) Provide interface information with the equipment and floor drain system, and (c) Provide pumping design characteristics and identify the pipe rupture used to size the sump pumps. Also,' provide the maximum expected flow rate data from the pipe rupture.

410.95 Provide the following for the turbine generator system (TGS):-

(10.2)

(a) Additional information on the power / load unbalance circuit, i

including closure time for all control valves upon load / power unbalance condition, (b) Verification of " excess vibration" as one of the signals that leads to a turbine trip, (c) Justification to deviate from the inservice inspection review guidance of SRP 10.2 for the turbine components (e.g., stop l

valves,interceptvalves). You have stated in your submittal that ISI for these components will be approximately once every five years, during refueling while above guidance provides the l

ISI once every three and a third years, during refueling or maintenance shutdown, (d) Verification to assure that TGS inservice inspection (ISI)'

testing will be performed in accordance with the. requirements 1

of ASME codes, and (e) Information that will confirm that the extraction check valves will be capable of closing within time limits required to maintain stable conditions.

1 410.96~

Verify that the main condenser design provides features to protect (10.4.1) safety-related systems from the effects of a flood due to its complete failure.

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, 480.8 The CESSAR 80+ system design precludes the need to switchover the (6.2.2) emergency core cooling system (ECCS) suction to a seoarate source of water following the injection phase of a LOCA, by'providing an-in-containment refueling water storage tank (IRWST).

However, a single water source, must meet the licensing requirements for the recirculation phase of a LOCA because of the potential buildup of debris and foreign matter. Therefore, provide the following for conformance with GDC 38 and.SRP 6.2.2, Revision 4 (NUREG-0800) by following the guidance of RGs 1.82 and 1.1 and NUREG-0897, Revision 1, as appropriate:

1 (a) Perform a net positive suction head (NPSH) analysis for the containment spray pumps to assure that pump cavitation will not i

occur during any anticipated operating conditions-during the s

injection and recirculation phases of a postulated LOCA. Also, provide associated supporting-inputs and assumptions for the above analysis,

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(b) Provide an evaluation of the long term ability of the IRWST, to provide a reliable source of water for the containment spray-system during the recirculation phase of a LOCA.

This evaluation should include the provisions for adequate drainage back to the IRWST, IRWST hydraulic performance, and the design features of the IRWST which preclude debris accumulation from inhibiting sufficient flow to the containment spray system.

480.9 In order to evaluate the performance capability of the containment (6.2.2) spray system for conformance with GDC 38 and SRP 6.2.2 Revision 4, 5

provide the following design parameters:

(a) Spray header location relative to containment internal structures, (b) Spray nozzle arrangement on the spray headers and the expected

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spray pattern, (c) Spray drop size spectrum and mean drop size emitted from the i'

nozzle as a function of differential pressure across.the j

nozzle, and i

l (d) Average spray drop residence time in the containment atmosphere.

I 480.10 Provide an evaluation of the heat _ removal capability of the l

'( 6.2.2) containment spray heat exchangers with surface fouling on the secondary side for conformance with GDC 38 and SRP 6.2.2 Revision 4.

480.11 Provide the design features and provisions of the containment spray e

l (6.2.2) system for periodic inspection and operability testing for conformance l

with GDCs 39, 40, and SRP 6.2.2 Revision 4.

Also, outline the anticipated schedule and extent of this inspection and testing.

480.12 Provide an evaluation of the effect of CCWS failures on the containment (6.2.2) spray system (CSS) via the CSS heat exchanger as addressed in Table 6.5-3.

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4 480.13 You have stated that secondary containment functional design will be

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(6.2.3) provided later. Provide information to permit the staff to perform 1

an integrated review of the secondary containment.

J 480.14 Provide the following)information to evaluate the containment (6.2.4) isolation system (Cis in conformance with GDCs 16 54, 55, 56 and 57 and guicance of RG 1.141 and SRP 6.2.4, RevIston 2.

(a) Completed Table 6.2.4-1, " Containment Isolation System,"

(b) The number and physical location of containment isolation valves (CIVs),

(c) The actuation and control features for each isolation valve, (d) The positions of each isolation valve for normal, post-accident,.

and valve operator power failure conditions, (e) Valve actuation signals for each isolation valve, (f) The closure time and basis for each isolation valve, and (g) The mechanical redundancy for each isolation valve.

480.15 Provide the containment isolation design provisions for all (6.2.4) instrument lines that penetrate the containment in accordance with the guidance of RG 1.11, 480.16 Provide correct maximum integrated radiation dose for the CIV design (6.2.4)

(see page 6.2-35 as 4.0E-7 rads).

In addition, qualify this dose regarding whether it is solely due to gamma radiation.

If so, provide design beta and neutron doses for the CIVs and associated:

valve operators.

480.17 Provide specific details on outside containment leak testing (6.2.4) provisions for remote manual valves of engineered safety feature, i

engineered safety feature-related, or safe shutdown systems i

penetrating the containment for conformance with the guidance of

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SRP 6.2.4 Revision 2.

480.18 Provide a system reliability evaluation and outside containment (6.2.4) enclosure design details for all engineered safety feature or engineered safety feature-related system containment penetrations having only one isolation valve for conformance with the guidance of SRP 6.2.4 Revision 2.

480.19 Provide the design details of any sealed closed barriers that are (6.2.4) used in place of automatic isolation valves for containment l

penetrations for conformance with the guidance of SRP 6.2.4 Revision 2.

480.20 Provide the relief valve setpoints for valves which are used as CIVs.

(6.2.4)

i 480.21 Provide an evaluation for selecting 5 psig as the containment (6.2.4) isolation actuation signal (CIAS) setpoint. (See Chapter 7).

This evaluation should follow the guidance of SRP 6.2.4, l

GDC 54, NUREG-0737, and NUREG-0718 for selecting the CIAS " minimum value compatible with norr.a1 operating conditions."

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480.22 SRP 6.2.4 Revision 2 guidance states that all lines that I

(6.2.3) provide an open path between the containment and the outside containment environment should be equipped with radiation monitors.

l These lines should be isolated on receipt a high radiation signal.

L This design feature is not addressed in Section 6.2.4.

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the design details for these monitors for all applicable containment penetrations.

480.23 Provide an evaluation of the plant design features that will minimize (6.2.4) the time required to keep open the 4-inch on-line containment pressure control system (OLCPCS) CIVs.

This evaluation should specifically address the areas of excess air leakage from pneumatic systems, heat loss from the primary and secondary system to the containment air, and excess airborne activity levels in the containment atmosphere. Also, provide the design basis for operation of the OLCPCS, including estimated integrated time during a year when this system is expected to be open. Quantify the additional radiologicalconsequencesofthissystembeingopen(beforeisolation is completed) during a design basis accident (DBA) and evaluate these doses against 10 CFR 100 requirements to conform with the guidance of BTP CSB 6-4, Revision 2.

480.24 Provide CIS design information which addresses ar. inadvertent (6.2.4) reopening of CIVs and ensures a high reliability against reopening-to conform with the guidance of GDC 54, SRP 6.2.4, Revision 2, NUREG-0737, and NUREG-0718.

It should be noted that ganged reopening of CIVs and administrative controls for manual isolation valve.

closure before resetting the isolation signal may not be acceptable.

480.25 Youhavestatedthatthecombustiblegascontrolincontainment(CGCC)

(6.2.5) section will be provided later. Provide CGCC information to permit the staff to perform an integrated review.

480.26 Provide a comparison of the design basis containment leak rate f6.2.6) listed in Section 6.2.6 (0.5 weight per cent per day) with the containment leak rate assumed by CE in performing the LOCA site boundary doses in accordance with the requirements of 10 CFR 100.

Justify any non-conservative differences.

480.27 You have committed under Section 6.2.6 to conduct Type A and B (6.2.6) tests in accordance with 10 CFR 50 Appendix J.

However, you have only stated that Type C tests are " described in 10 CFR 50 1

Appendix J."

Clarify that Type C tests will be conducted in accordance with Appendix J or provide justification for any deviations from the requirements of Appendix J.

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i 480.28 Provide an evaluation for conformance with the review guidance of l

(6.2.6)

SRP 6.2.6 Revision 2, concerning the instrument lines that penetrate containment during the containment integrated leak rate l

test (CILRT).

t 480.29 Identify all systems that will not be vented and drained during the (6.2.6)

Type A CILRT for conformance with the guidance of SRP 6.2.6, Revision 2.

1 Provide justification for not venting or draining these systems.

480.30 List all containment penetrations which will be subjected to Type B tests for conformance with the guidance of SRP 6.2.6 Revision 2.

Justify the exclusion of any penetrations from such testing.

480.31 List all containment isolation valves that will be subjected to Type C (6.2.6) tests for conformance with the guidance of SRP 6.2.6, Revision 2.

Justify the exclusion of any isolation valves from such testing.

480.32 Clarify whether external hydrogen recombiners or equivalent are (6.2.6) included in the containment design.

If so, include them specifically

'in the CILRT for conformance with the SRP 6.2.6, Revision 2 guidance.

480.33 Identify any potential bypass' leakage pathways and include them (6.2.6) specifically in the Type C local leak rate testing program for i

conformance with the SRP 6.2.6 Revision 2 and BTP CSB 6-3 guidance.

450.1 Provide the following information concerning the control room (6.4) habitability system for conformance with the guidance of SRP 6.4, Revision 3:

(a) P&IDsofthecontrolbuildingventilationsystem(CBVS),

(b) Drawings showing the control building emergency zone-(CBEZ) and air intake locations and distances relative to potential radiological and hazardous and toxic chemical release points.

(c) Drawings showing-the boundaries of the CBEZ, indicating how specific rooms and areas are enclosed in or interface with this

zone, (d) FMEA of the CBVS which demonstrates that it will perform its emergency function with any single active failure prior to or during an emergency, and (e) Provide the following CBVS and CBEZ design data:

Nurmal ventilation flow rates, Emergency mode flow rates for the CBEZ, Design basis inleakage rates of potentially contaminated air for dampers, ducts, etc., associated with the CBEZ by type of damper, etc., and with its totals, (4) Composition, type, and size of filters used in the emergency mode of the CBVS, 4

4 u' (5)~ Free air-volume of the CBEZ and total volume of the -

(6). control room, Maximum number of occupants expected in the CBEZ during an emergency, n

(7) The presence, quantity, and location of toxic and 1

hazardous substances within the site boundary (e.g.

chlorine for water treatrent, C0 forfiresuppression),and-l (8) The location and quantity of botfled air which would be accessible to occupants cf the CBEZ during an emergency.

450.2 Provide information to demonstrate that the technical support. center (TMI has the same radiological habitability as the control room under Action accident conditions, in accordance with the guidance of NUREG-0696, Item

" Functional Criteria for Emergency Response Facilities."

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