ML20024B419
| ML20024B419 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/23/1983 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Mittl R Public Service Enterprise Group |
| References | |
| NUDOCS 8307080684 | |
| Download: ML20024B419 (85) | |
Text
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3 JUN 2 3 1983 DISTRIBUTION:_
(Document Control)
NRC PDR Local PDR g ^ 50-354 NSIC
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Mr. R. L. Hitti, General ifanacer LB#2 File RMattson, DSI Nuclear Assurance & Regulation DWagner RVollmer, DE Public Service Electric & Cas Company EHyl ton TPSpeis, DST 80 Park Plaza T160 ASchwencer CMiles, OPA Newark, New Jersey 07101 TMNovak ELJordan, DEQA:IE DGEisenhut/RPurple JMTaylor, DRP:IE
Dear ifr. tiitti:
Goddard, OELD RDiggs HThompson, DHFS BPCotter, ASLBP
Subject:
Acceptance Review of Application for OL License for Hope Creek Generating Station, Unit No.1 On March 2,1983, the NRC staff received your application for an operating license for the hone Creek Generating Station, Unit 1.
Your application included tre Gereral Information, an Environnental Report - Operating License Stage (ER-OL),
a Final Safety Analysis Report (FSAR), Antitrust Infornation, an Energency Plan, a Security Plan, a Safeguards Contingency Plan and Engineering Drawings.
The staff has completed its review of your application and has concluded that the information filed, taken as a whole, is suf ficiently conplete for docketing your applit.ation and for initiation of the safety and environmental reviews.
Substantive deficiencies nay exist in sone sections that need to be corrected during the review. In view of your recent operating experiences at the Salen plant, the staff has a number of concerns regarding PSEaG panagement and QA.
One of those concerns which was discussed with you by telephone on June 6,1983, and June 21, 1983, was your ability to concurrently support a licensing effort on the Hope Creek application and still give adequate attentien to the safe operation of the Salen facility. We request that you docunent the bases for your confidence that the start of the licensing activities for Hore Creek will not detract fron PSEaG's efforts on Salen. The start of our review of Hope Creek will be subject to that docunentation.
The other concern is that the Iope Creek application at present does not reflect sionificant changes in overall PSEAG canagement capability and perfornance which you have rade or plan to nake in response to the HRC Order dated fiay 6,1983.
For this reason FSAR chapters 13 and 17 are not acceptable for initiation of the review. Docketing of your application should not suggest acceptance of these sections. Therefore, as a condition of docketing, we request that you update your FSAR as necessary to reflect all nanagement and other organizational changes r'ade, or scheduled to be mace at PSE&G in response to that Order.
This FSAR update is necessary for the staff to initiate its review of those sections of your FSAR (Chapters 13 and 17) dealing with nanagement and organization at all levels, including plant supervisory staff.
8307080684 830623 l
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fir. R. L. flittl Your filing of the application for docketing should include three (3) originals signed under oath or affimation by a duly authorized officer of your organiza-tion.
In addition, your filing should include fif teen (15) copies of the General Infomation portion of the application, forty-one (41) copies of the ER-OL, and forty (40) copies of the FSAR. As required by Section 50.30 and Section 51.21, 10 CFR Parts 50 and 51 respectively, you should retain an additional ten (10) and thirty (30) copies of the FSAR for direct distribution in accordance with j of this letter and further instructions which ray be provided later.
Within ten days af ter filing, you raust provide an affidavit that distribution has been nade in accordance with 10 CFR Part 2.101 and the Enclosure 1 to this letter. All subsequent aner.drents to the ER-OL and FSAR will require forty-one (41) and sixty (60) copies respectively, for distribution.
The hRC Caseload Forecast Panel visited the Hope Creek site in April 1983.
Observations made during the visit were considered during the development of the schedule for the review of your OL application. You have inforred the staff i
that your projected fuel load date is January 1986.
It is requested that you infom the staff of any change in this date.
l After docketing, the staf f will follow a revised review procedure whereby only a single set of questions will be transmitted to you for responses. Af ter your responses have been reviewed, a craf t SER will be prepared to provide a basis for a series of neetings designed to close out open items.
During the course of our prelininary review of your tendered FSAR and ER-OL, the enclosed requests for additional infomation (Enclosure 2 and 3 respectively) i' were generated.
In addition to Enclosures 2 and 3, other additional infomation is needed to expedite our review. Enclosures 4 through 11 identify this infomation. Those requests are, for the rest part, generic in nature (Generic Letter - Enclosure 10) or sanple requests for ir.fomation (Q List - Enclosure 5).
Those itens should be reviewed for applicability to the Hope Crcek Generating Station and responded to in the FSAR as appropriate. Your responses to Enclosures 2, ? and 4 should be subnitted as changes to the FSAR, in anendrnent fom, within sixty days from the decketing date, except as otherwise noted within.
l Your letter of transnittal for docketing of the application should include a
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connitnent to provide the requested information within sixty days of the date of your letter.
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Mr. R. L. Mittl If during the review you believe that there is a need to appeal a staff-proposed requirement, you should bring your appeal to my attention as early as possible so that the appropriate meetings can be arranged. The staff will provide an informal appeal process to provide an opportunity for you to discuss any such areas of disagreenents with a staff-proposed requirement. Briefly, each side of the issue is to develop the position it intends to take and forward the position statement to the Division of Licensina. Frcq these positions, an agenda containing appropriate discussion itens will be developed and distributed orior to any meeting. A first stage of appeal meeting will be conducted by staff management at the Assistant Director level.
If the matter is not resolved at the Assistant Director level, a second stage of appeal meetings will be held with the appropriate Division Directors in attendance.
If a satisfactory resolution has not been reached by the end of the second stage meeting, an appeal to the Director of Nuclear Reactor Regulation pay be submitted. A sumary report will be prepared and distributed, and a copy will be placed in the Public Document Room.
On flarch 26, 1982, the Commission published a final rule entitled, " Heed for Power and Alternative Energy Issues in Operating License Procedures," 47 Federal Reaister 12940, which amends its regulations in 10 CFR Part 51 to no loncer require operating license applicants to address such issues in the ER.
On March 31, 1982, the Comission published a final rule entitled, "Elinination of Review of Financial Qualifications of Electric Utilities in Licensing Hearings for Nuclear Power Plants," 47 Federal Reqister 13750, which eliminates the requirements for financial cualifications review and findings for electric utilities that are applying for construction permits or operating licenses. As a result of t'nese two final rules, the staff will not include these issues in the licensing review of the Hope Creek Generating Station.
If you have any ouestions concerning the enclosed infomation or docketing of your application, please call the Licensing Project Manager. Dave Wagner, at (301) 492-8525 Sincerely, 1priE nal i
p.rroll G' E Darrell G. Eisenhut, Director Division of Licensing Office of !!uclear Reactor Regulation
Enclosures:
As stated cc: See next page
- SEE PREVIOUS CONCURRENCES
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's N N N 's On t' arch 31,1982Dsthe Corrission published a final rule entitled, " Elimination of Peview of Financial, Oualifications of Electric Utilities in Licensine Hearines for Nuclear Power Plants," 47 Federal Recister 13750, which eliminates the recuirenents for financial cualifications review and findinas for electric utilities that are anplyinn for construction permits or operatino licenses. As a result of these two final rules, the staff will not include these issues in the licensina review of the Hope Creek Generatina Station.
If you have any nuestions concernino the enclosed information or docketinq of your application, please call the licenslqq project Panacer, Dave Vanner (301)492-9536.
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8-Hope Creek
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Mr. R. L. Mitti, General Manager Nuclear Assurance & Re'gulation Public Service Electric & Gas Company 80 Park Plaza T16D Newark, New Jersey 07101 cc: Troy B. Conner, Jr., Esonire F. Michael Parkowski, Esquire Conner & Wetterhahn Deputy Attorney General 1747 Pennsylvania Avenue, N. W.
Tatnall Building Washington, D. C. 20006 Dover, Delaware 19901 Richard Fryling, Jr., Esquire Mr. K. W. Burrowes, Project Engineer
- Assistant General Solicitor Bechtel Power Corporation Public Service Electric & Gas Co.
50 Beale Street 80 Park Plaza T5E P. O. Box 3965 Newark, New Jersey 07101 San Francisco, California 94119 Mr. P. R. H. Landrieu Mr. W. H. Bateman Project Manager - Hope Creek Resident Inspector Public Service Electric & Gas Co.
U.S.N.R.C.
80 Park Plaza T17A P. O. Box 241 Newark, New Jersey 07101 Hancocks Bridge, New Jersey 08038 The Honorable Mark L. First Mr. R. P. Douglas Deputy Attorney General Manager-Licensing & Analysis State of New Jersey Public Service Electric & Gas Co.
Nuclear Energy Council 80 Park Plaza T16D 36 West State Street Newark, New Jersey 07101 Trenton, New Jersey 07102 Mr. R. S. Salvesen Mr. David A. Caccia General Manager-Hope Creek Operations Box 70, A.R.D. #2 Public Service Electric & Gas Co.
Sewell, New Jersey 08080 P. O. Box A Hancocks Bridge, New Jersey 08038 Mr. B. A. Preston Principal Engineer Mr. B. G. Markowitz, Project Manager Public Service Electric & Gas Co.
Bechtel Power Corporation 80 Park' Plaza T16D 50 Beale Street Newark, New Jersey 07101 P. O. Box 3965 San Francisco, California 94119 Mr. N. C. Vasuki, Director Division of Environmental Control Mr. E. F. Devoy Tatnall Building Principal Engineer-Hope Creek Dover, Delaware 19901 PSE&G c/o Bechtel Power Corporation 50 Beale Street Robert D. Westreich, Esquire P. O. Box 3965 Assistant Deputy Public Advocate San Francisco, California 94119 P. O. Box 141 Trenton, New Jersey 08625 Mr. A. E. Giardino Manager - Quality Assurance E&C Public Service Electric & Gas Co.
P. O. Box A Hancocks Bridge, New Jersey 08038 i
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g ENCLOSURE'i DISTRIBUTION LIST FOR HOPE CREEK GENERATING STATION, UNIT 1 ENVIRONMENTAL REPORT
- ADVISORY COUNCIL ON HISTORIC PRESERVATION U. S. DEPARTMEN'T OF HEALTH AND HUMAN SERVICES Mr. Peter H. Smith (1)
Mr. Charles Custard (2)
Advisory Council on Historis Preservation U.S. Department of Health & Human Services 1522 K Street, N.W., - Suite 536 Room 537F Humphrey Building Washington, D. C.
20005 200 Independence Avenue, S.W.
Washington, D. C.
20201 cc letter without enclosure:
U.S. DEPARTMENT OF HOUSING AND URBAN Ms. Jerry English, Commissioner DEVELOPMENT REGION (2)
Department of Environmental Protection P. O. Box 1390 Environmental Officer Trenton, New Jersey 08625 Department of Housing & Urban Development 26 Federal Plaza U. S. DEPARTMENT 0F AGRICULTURE New York, New York 10007 Soil Conservation Service (State Office)
U. S. DEPARTMENT OF INTERIOR U. S. Soil Conservation Service (1)
Mr. Bruce Blanchard, Director (18) 1370 Hamilton Street Office of Environmental Project Review P. O. Box 219 U.S. Department of the Interior, Rm. 4256 Somerset, New Jersey 08873 18th and C Streets, N.W.
Washington, D. C.
20240 ARMY U.S. CORPS OF ENGINEERS DISTRICT (1)
U. S. DEPARTMENT OF TRANSPORTATION U.S. Army Engineer Dirivion, North Atl antic Mr. Joseph Canny (1) 90 Churcn Street Office of the Assistant Secretary New York, New York 10007 for Policy and International Affairs U. S. Department of Transportation U. S. DEPARTMENT OF COMMERCE (6) 400 7th Street, S.W. - Room 9422 Washington, D. C.
20590 Ms. Joyce M. Wood, Director Office of Ecology and Conservation Capt. William R. Riedel (1)
Department of Commerce - Room 6800 Water Resources Coordinator National Oceanic and Atmospheric W/S 73 U.S.C.G. - Room 1112 Administration U. S. Department of Transportation Washington, D. C.
20230 2100 Second Street, S.W.
Washington, D. C.
20590 FEDERAL ENERGY REGULATORY COMMISSION 00T Recional Office (1)
Mr. Lawrence R. Anderson, Director (1)
Office of Electrical Power Regulation Secretarial Representative Federal Energy Regulatory Commission U.S. Department of Transportatibn 400 First Street, N.W. - Room 304RB 434 Walnut Street - Suite 1000 Washington, D. C.
20426 Philadelphia, Pennsylvania 19106
- Number in Paren denotes number of copies to be served
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- STATE OFFICIALS (1)
LOCAL OFFICIAL (S)
(1)
Attorney General 0
Department of Law & Public Safety er Alloways Creek Township NeNo "$w Salem County, New Jersey 08709 ersey 08625 CLEARINGHOUSES Commissioner Department of Public Utilities State Clearinghouse (10)
Stem of New Jersey I
rce 5 et Division of State and Regional Planning N
r 07102 Department of Community Affairs 9 est State Street Commissioner, Department of hefto E i n
t 1 Protection Ne ersey 08625 Trenton, New Jersey 08625 Areawide Clearinghouse (1) 0FFICIALS OF ADJOINING STATES (1)
Wilmington Metropolitan Area Planning Attorney General.
Coordinating Council (WILtMPCO)
Suite 201, Stocxton Building Department of Justice n1versMy Office Maza 12th & Market Newark, Delaware 19702 Wilmington, Delaware 19801 ER (1)
Department of Natural Resources and Environmental Control ATTN:
Director, Division or.
Librarian, Thermal Reactors Safety Group environmental Control Brookhaven National Laboratory Building 30 Tatnall Building Upton, Long Island, New York 11973 Dover, Delaware 19901 Attorney General vepartment or custice Capitol Annex Harrisburg, Pennsylvania 17120 Department of Environmental Resources Office of Environmental Planning ATTN: Mr. David Hess Executive House - Roam 813 Harrisburg, Pennsylvania 17120
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U. S. ENVIRONMENTAL PROTECTION AGENCY
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EIS Review Coordinator EPA Region II 26 Federal Plaza New York, New York 10007 4
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DISTRIBUTION LIST GENERAL INFORMATION PORTION OF OPERATING LICENSE APPLICATION AND FINAL SAFETY ANALYSIS REPORT ADDRESSEE REPORT TO BE SERVED STATE OFFICIALS (1 each)
Attorney General Application, General Information and Department of Law & Public Safety Amendments thereto State House Annex Safety Analysis Report and Amendments Trento'n, New Jersey 08625 thereto Commissioner Application, General Information and Depart ent of Public Utilities Amendments thereto State of New Jersey Safety Analysis Report and Amendments 101 Commerce Street thereto Newark, New Jersey 07102 Commissioner, Department of Application, General Information and Environmental Protection Amendments thereto P. O. Box 1390 Safety Analysis Report and Amendments Trenton, New Jersey 08525 thereto BORDERING STATE OFFICIALS (1 each)
Attorney General Application, General Information and Department of Justice Amendments thereto 12th & "arket Safety Analysis Report and Amendments Wilmington, Delaware 19801 thereto Departm.ent of. Natural Resources Application, General Information and and En /ironmental Control Amendmer.-i thereto ATTN:
Director, Division of Safety Analysis Report and Amendments Environmental Control thereto Tatnall Building Dover, Delaware 19901 Attorney General Application, General Information and Department of Justice Amendments thereto Capitol Annex Safety Analysis Report and Amendments Harrisburg, Pennsylvania 17120 thereto Department of Environmental Resources Application, General Information and Office of Environmental Planning Amendments thereto ATTN:
Mr. David Hess Safety Analysis Report and Amendments Executive House - Room 813 thereto Harrisburg, Pennsylvania 17120 l
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C. S. ENVIRONMENTAL PROTECTION AGENCY REGIONAL OFFICE
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EIS Review Coordinator Safety Analysis Reoort and Amendments EPA Region II thereto 26 Federal Plaza New York, New York 10007 S
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REQllEST FOR AD'DITIONAL INFORMATION RELATING TO HOPE CREEK FSAR 100.1 Section 1.3.2 references Table 1,3-8 which indicates a plant (1.3.2) unique analysis will be submitted for tne Mark I containment.
Either provide the analysis or a date for its submittal.
100.2 Part of Section 1.5.1.5 appears to be missing.
Provide the (1.5.1.5) missing information and any associated references.
100.3 The tables of electrical, instrumentation and control (EI&C)
(1.7) drawings indicate that some of the instrumentation and control crawings will be issued later.
Provide a schedule for issuing these drawings. Three copies of all proprietary anc nonproprietary EI&C drawings, including revisions as they are issuec, should be provided separate from the FSAR cut incorporated by reference in this secticn.
100.4 As per Regulatory Guide *.".70. Revision 3, for each piping (1.7) and instrumentaticec diagram (including revisions as issued) in the SAR, two large-scale copies (approximately 22 in. x 34 in.) should be proviced separately but sheuld be referenced in this section. The piping and instrumentation diagrams should contain grid coordinates and drawing cross-references.
Confirm that this information has been or will be provided.
100.5 As per Regulatory Guide 1.70, Revision 3, this section of (1.7) the SAR should include a list of any other specific data submitted in response to requests of the NRC staff, including card decks for computer codes, computer printouts, anc detailed geologic, seismologic, and foundation engineering information. Three copies of each such item should be submitted separately tut should be referenced in this section.
Confirm that the above guidance will be followed for data submitted in response to NRC staff requests.
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4 100.6 The response section for some of the TMI related items (1.10) indicates that a review will be done or a response will be provided later.
For each item for which your final response has not been stated, either provide the response or a schedule for its submittal.
311.1 A map of the site area of suitable scale (with explanatory
. (2.1.1.2) text as necessary) should be included.
It should " clearly" show tne following:
1.
Location of the site boundary.
If the site boundary lines are the same as the plant property lines, this should be stated.
2.
The coundary lines of the plant exclusion area (as defined ir 10 CFR Part 100).
If these boundary lines are the same as the plant property lines, this should be stated. The minimum distance from the reactor to the exclusion area boundary should be shown and specified.
311.2 The following information should be provided for the (2.1.2.1) exclusion area. Specifically state whether the exclusion area and plant property line and the site boundary are one in the same.
If the exclusion area extends into a body of water, the application should specifically address the bases upon which it has been determined that the authority required by paragraph 100.3(a) of Part 100 is or will be held by the apolicant.
311.3 Because of significant population variations due to (2.1.3.3) transient land use, additional tables of population distribution should be provided to indicate peak seasonal and daily populations.
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I 311.4 For the population center, discuss the present and I
(2.1.3.5) projected population density within and adjacent to local population groupings.
311.5 The cumulative resident population projected for the year of (2.1.3.6) initial plant oparation should be plotted to a distance of at least 30 miles anc comparec with a cumulative population resulting from a uniform population density of 500 people /sq. mile in all directions from the olant.
Similar information should be provided for the end of plant life but compared with a cumulative population resulting from a uniform population density of 1000 people /sq. mile.
240.1 Discuss wave setup, significant (33-1/3%) and maximum (1%) or (2.4.3.6) depth limited wave heights, wave runup, and resultant static and dynamic effects of wave action on each safety-related facility from wind-generated activity that may occur coincidently with the peak PMF water level.
240.2 A discussion should be provided on the effects of the water (2.4.5.3.3) levels on each.affected safety-related facility and the protection to be proviced against static and dynamic effects and splash.
240.3 For Tsunami flooding, provide an estimate of the minimum (low (2.4.6.5) water) Tbvel associated with the occurence of a tsunami from both distant and local generators. Describe the ambient water levels, including tides, sea level anomalies, and wind waves assumed coincident with tl.e tsunami.
240.4 For the ultimate heat sink, describe the ability to p* ovide (2.4.11.6) sufficient warning of impending icw flow or low water levels to allow switching to alternative sources where necessary. Heat dissipation capacity and water losses
~(such as drift, seepage, ano evaporation) should bg identified and conservatively estimated.
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230.1 A statement regarding who performed the work for this (2.5) section of the FSAR should ce made.
231.1 Provide a large-scale structural geology map (1:24,000) of (2.5.1.2) the site showing bedrock surface contours and including the locations of Seismic Category I structures. A large-scale geologic map (1:24,000) of the region within 5 miles of the site that shows surface geology and that includes the locations of major structures of the nuclear power plant, including all Seismic Category I structures, should also be furnished.
241.1 A discussion and evaluation of lateral earth pressures and (2.5.4.10) hydrostatic grounc-water loads acting on plant facilities should be included in this section.
Field and laboratory test results should be discussed. Design parameters used in stability analyses should be discussea and justified.
Sufficient data and analysis should be provided so that the staff may make an independent interpretation and evaluation.
410.1 Describe the procedures ~ required (see regulatory position 2 (3.4.1.1) of Regulatory Guide 1.59 and regulatory position 2 of Regulatory Guide 1.102) and implementation times available to bring the reactor to a cold shutdown for the flood conditions identified in Section 2.4.14.
These procedures ind times should be compared with the procedures and times required to implement flood protection requirements identified in Section 2.4.14.
410.2 The tornado missile protection analysis should take into (3.5.1) account the effects of missiles on ventilation openings in the various facility buildings housing essential shutdown equipment.
Reference or provide a dis'cussion addressing I
this subject.
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21 0.1 Provide the date that the many tables and figures identified (3.6) as "iater" will ce suomitted.
21 0.2 Prov;;e tne cate snat tne information icentified as "later" (3.9) in Taoles 3.9-5o, 3.9-5c, and 3.9-5s will be submitted.
2 71.1 Provice the cate tnat the information icentified as "later" (3.10) in Tables 3.10-2 and 3.10-3 will be submitted.
270.1 Provide the date inat the information identified as "later" (3.11) in Tables 3.11-1c and 3.11-1d will be submitted.
492.1 Provice the cate wnen tne reactor core stability data, the (4.4.4.6.6) cnannel hydrocyanmic stability performance data, and Figures 4.4-7, 4.4-8, 4.4-9, and 4.4-10 will be submitted.
252.1 Provide the date when Figures 5.3-1 through 5.3-6 will be (5.3) suomitted.
252.2 Provide the date when the information identified as "later" (5.3.1) will be submitted.
252.3 Provide the date when the information identified as "later" (5.3.2) will be submitted.
281.1 The information missing in Tables 6.1-3 and 6.1-4 is to be (6.1.2) provided later.
Drovide a schedule for its submittal.
480.1 A description of the leak seal for the post accident (6.2.3.2.3) sampling supply and return line is to be provided later.
Indicate when this information will be submitted.
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480.2 The information missing in Table 6.2-16 is to be submitted l
(6.2.4.2) later.
Provide a schedule for this amendment.
440.1 Provide the date when the plant-specific LOCA analfsis will (6.3.3.7.3) be submitted in an amendment.
281.2 Figures 9.1-3 anc 9.1-4 are shown as to be supplied later.
(9.1.2)
Supply these figures or a cate by which they will be proviced.
281.3 Section 9.3.2.6 of the FSAR states that a generic resolution (9.3.2) to the limitations of the sampling system is currently uncer investigation; provide an estimated date by which such resolution may be expected.
280.1 The information missing in Table 9A-1 is to be provided in (Appendix 9A) an amencment.
Provide a schecule for its submittal.
460.1 As per Regulatory Guide 1.70, Revision 3, provide layout (11.4) drawings of the packaging, storage anc shipping areas.
460.2 Tables 11.4-2, 11.4-3, 11.4-4 and 11.4-7 and Figure 11.4-9 (11.4) indicate some information will be supplied later.
Either provide this information or a schedule for its submittal.
460.3 Table 11.5-1 indicates some information w'll be supplied (11.5) later. Either provide this information or a schedule for its submittal.
331.1 Specifically indicate whether, and if so how, the guidance (12.5) of Division 8 regulatory guides and 10 CFR 20 as given in SRP 12.5 of NUREG-0800 will be followed; if it will not be followed, describe the specific alternative approaches to be used.
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331.2 Section 12.5.2.2 states "As planning progresses more details (12.5.2.2) will be included in the section." This should include a description of the type of detectors and monitors and the quantity, sensitivity, range, as well as frequency and methods of calibration for all the tecnnical ecuipment and instrumentation.
Either provide the above information or a schedule for its suomittal.
630.1 Section 13.1.3.2 references Table 13.1-4 which indicates (13.1.3.2) that some resumes will be supplied later.
Either provide the resumes or 'a date fo submittal of the resumes.
630.2 The referenced Figure 13.2-1 states the training schedule (13.2.1.1) for maintenance mechanics will be supplied later.
Either provice this training senedule or a date for its submittal.
640.1 The sequential test schedule for the startup test chase (14.2.11) snould be provided. Also, confirm that approvec test procedures will be in a form suitable for NRC review at least 60 days prior to their intended use, and for fuel loading and startup test procedures, at least 60 days prior to fuel loading.
220.1 If Category I safety-related mascr.ry walls are used in Hope (3.8.4)
Creek Unit 1, provide a Section 3.8.4 that discusses the masonry walls in accordance with the information identified in Appendix A to SRP Section 3.8.4.
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331.3 All accessible areas in the vicinity of the spent fuel transfer (12.3.2)
(SRP 12.3-12.4 canal which are capable of having radiation levels greater than 11 1 (p. 12.3-7))
0 100 rads per hour shall be shielded during fuel transfer. Use of removable shielding for this purpose is acceptable. This shielding shall be such that the resulting contact radiation levels shall be no greater than 100 rads per hour. All accessible portions of the spent fuel transfer canal shall be clearly marked with a sign stating that potentially lethal radiation fields are possible during fuel transfer. Describe how you plan to comply with the above.
If a " cattle shute" shield is used in the fuel transfer canal, provide the maximum dose rates to any potentially occupied portions of the upper drywell during fuel transfer. Describe precautions to prevent access to other plant areas having radiation levels greater than 100 rads per hour.
331.4 Acceptance criteria II.4.b.3 of SRP 12.3-12.4 states that (12.3.4.1.3)
(SRP12.3-12.4, ventilation monitors be placed upstream of the HEPA filters so II.4.b.3) that they will provide an indication of elevated airborne radio-activity concentrations in plant areas. With the ventilation monitors downstream of the HEPA filters, describe how you intend to accurately detect ten MPC-hours of particulate and iodine radioactivity from any compartment which has a possibility of containing airborne radioactivity and which normally may be occupied by personnel (as stated in Section II.4.b.1 of SRP 12.3-12.4).
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331.5 The containment high range radiation monitors (DAPA Ri1S moriitors (Ta'ble 12.3-9) j
~(NUREG-0737, at Hope Creek) should be included in Table 12.3-9 and on the II.F.1-3) appropriate layout drawings in Chapter 12. The name of the manufacturer and model number of these monitors should also be provided.
331.6 The BWR exposure data used in Chapter 12.4 does not include (12.4.1.2.2)
(SRP12.3-12.4 plant exposures after 1976. Update your exposure estimates to I.5.a) include more recent exposure data (NUREG-0713, Vol. 3 contains exposure data up through 1981).
331.7 Provide a schedule for submittal of your response to NUREG-0737 (12.5.2)
(fiUREG-0737, Item III.D.3.3. Imoroved Inplant Iodine Instrumentation Under III.D.3.3)
Accident Conditions.
(91 0.1 )
Prior to final acceptance and ap'provai of the applicant's security program a guard training and qualification plan, as described in and required by 10 CFR 73.55(b)(4) and Appendix B to 10 CFR Part 73, must be submitted for our review by the Public Service Electric and Gas Ccmpany.
D T
2-9
100.7 The Hope Creek FSAR contains cn atypical Section 1.12 (1.12) that discusses unresolved generic safety issues and also references other FSAR sections that provide additional information on same of these issues. This section includes a) the applicant's evaluation of unresolved safety issues, including the applicant's position regarding the issue, and b) an applicants' interpretation of the NRC's position concerning these issues. After careful review of this section, the staff concludes that inclusion of an applicants' interpretation of the NRC's position may involve NRC policy considerations. Therefore, the staff requests that the "NRC assessment" part of each unresolved generic safety issue in section 1.12 be deleted from the text.
260.1 FSAR Section 17.2.2 states that the operational QA program will be appljed to items and activities listed in FSAR Tables 17.2-1 through
(]7.2.2) 17.2-4.
The detail given in Table 17.2-1 does not provide adequate assurance that all structures, systems, and components listed in Table 3.2-1 as meeting 10 CFR 50 Appendix B requirements will have the operational QA program applied.
Provide a commitment that the operational QA program will also be applied to the items listed in Table 3.2-1 with a "Y" in the column headed "QA Requirements" or justify not doing so. Also clarify that any disagreement between tables will be resolved by applying pertinent QA program controls unless and'until the tables are revised to show that QA is not required.
i 2-10
ENCLOSURE 3 RAI HOPE CREEK ENVIRONMENTAL REPORT E240.1 The ER-OL (Section 2.4.1.1 and Figure 2.4-4) provide tidal data for 2.4.1.1 (ER-0L)
Reedy Point, Delaware which is the nearest tide gage station 7.0 miles from the site.
The term "Mean Sea Level (Sandy Hook,1929 Adjustment)
U.S. Coast and Geodetic Survey Datum" as used throughout your report is not Mean Sea Level. According to the National Ocean Survey, Tides and Water Level Division, Datums and Information Branch, the correct updated terminology for their Sandy Hook,1929 Adjustment term is National Geodetic Vertical Datum,1929 (NGVD,1929). Additionally, the NOS Tide Tables and Tidal Benchmark data for the Reedy Point, Delaware. Tide Station #1833 provide the following values which differ from your vilues shown on page 2.4-2:
Mean High Water 5.5 feet Mean Sea Level 2.8 feet Mean Tide Level 2.7 feet NGVD,1929 2.45 feet Mean Low Water 0.0 feet Throughout your report varicus water levels either directly or indirectly refer to Mean Sea Level.
It is not clear to which Mean Sea Level these values are based (i.e., your Sandy Hook Datum or local MSL datum).
3-1
j Provide clarification of the tidal values and the relation to PSE&G elevations and justify the use of any value that differs from the above cited terms.
E240.2 Description of floodplains, as requested by Executive Order 11988, 2.4.1.1 (ER-OL )
Floodplain-Management, have not been provided.
The definition used in the Executive Order is:
Floodplain: The lowland and relatively flat areas adjoining inland and coastal waters including flood prone areas of offshore islands, including at a minimum that area subject to a one percent or greater chance of flooding in any given year.
a.
Provide descriptions of the floodplains adjacent to the site.
On a suitable map (s) provide delineations of those areas that will be flooded during the one percent (100-year) flood, both before and after plant construction or operation. We note that flood insurance studies for the Township of Lower Alloways Creek, New Jersey, Salem County, dated October 18, 1982 with accompanying panels 1-25, effective date April 18, 1983, are available for the site from the Federal E:nergency Management Agency (FEMA).
Panels 9 and 10 of 25 of this report indicate that parts of the water front area of the site are within the 100 year floodplain.
3-2 O
b.
Provide details of the methods used to determine the floodplains in response to a. above.
Include ycur assumption of, and basis for, the pertinent parameters used in the computation of the flood flows and water elevations.
If the flood insurance study avail-able from the Federal Emergency Management Agency for the site and adjacent affected areas is utilized, the details of the analysis used in the reports need not be supplied. You can instead provide the reports from which you obtained the floodplain information.
c.
Identify, locate on a map and describe all plant structures and topographic alternations in the floodplains such as the service water intake structure and barge slip.
d.
Discuss the hydrologic effects of all items identified in response to c. above.
Discuss the potential for altered flood flows and levels, offsite.
Discuss the effects on offsite areas of debris generated from the site during flood events.
e.
Provide the details of your analysis uscc in response to d. above.
The level of detail is similar to that identified in item b. above.
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e 2
l E290.1 Identify documents that include the results of terrestrial (ER, Sec. 2.2.1) vegetation sampling in the vicinity of the Hope Creek Generating Station.
E290.2 Identify documents that include the results of bird surveys.
(ER, Sec. 2.2.1.3) in the site vicinity.
What data are available on breeding, population density and hunter harvest of the 33 species of game birds reported to occur in the site vicinity (Section 2'.2.1.3 of the ER-0L)?
9 E290.3 How were the cooling tower salt drift deposition values (ER, Sec. 5.1.4.4) presented in Table 5.1-4 derived? Provide a figure depicting salt drift deposition isopleths around the cooling tower.
E290.4 Provide a description of the grounding systems that will be (ER, Sec. 5.5.4) used to reduce induced voltages and currents in conducting objects, such as metal fences, in the vicinity of the transmission line rights-of-way.
E290.5 Provide a discussion of the potential impacts of electrical (ER, Sec. 5.5.4) field strengths of 5.0 and <2.0 kV/m expected at ground level under and alcng the Salem-Deans 500 kV line.
E290.6 If available, provide low level aerial photographs of (General) the area within a 2 mile radius of the site.
3-4 I
.I E291.1 Provide estimates of recreational and commercial fish and (ER, Sec. 2.1.3.5) shellfish harvests for the years 1976 through 1980 for the 9
tidal portion of the Delaware River upstream of HCES.
Include tidal portions of major tributaries in this area, as well as the Chesapeake and Delaware Canal.
E291.2 ER page 2.2-13 discusses the aquatic invertebrate taxa (ER, Sec. 2.2.2.2) utilizing surface attachment of solid substrates.
Provide the following:
(a)
The seasonality of reproduction and attachment of the major fouling organisms in the HCGS vicinity; 4
(b) A discussion of the biofouling experience with surface attaching organisms at Salem NGS; (c) The potential for biofouling (by surface attaching organisms) of the HCGS intake structure; (d) The methodology for preventing or controlling biofouling of the intake structure.
i E291.3 Provide a copy of Reference 2.2-17 by H. M. Brundage cn (ER, Sec. 2.2.3) shortnose sturgeon.
E291.4 Provide, in tabular form, a comparison of all cooling system (ER, Sec. - 3.4.1) design specifications and structure locations as they now exist with those that were evaluated in the FES-CP stage and the AEC Initial Decision, LBP-74-79 of October 25, 1974.
3-5
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s E291.5 ER page 3.4-2 states that impinged organisms are returned (ER, Sec. 3.4.1) to the Delaware River at a distance from the intake structure, to reduce the potential for impingement on the screens.
Provide the following:
l (a) the location of the return trough to river in relation 1
to the intake and discharge structures for both HCGS and Salem NGS; (b) the design of the return system for monitoring mortality of impinged organisms prior to return to the river.
E291. 6
.ER Table 3.4-1 provides monthly average data on intake (ER, Table 3.4-1) and discharge performance.
Provide a similar table that shows monthly minima and maxima for each operational parameter in Table 3.4-1.
E291.7 ER page 5.1-2 states that the NJPDES Permit of 1975 has (ER, Sec. 5.1.1) not been renewed as yet.
Provide the following:
\\
l (a) the estimated schedule for finalizing the NJPDES Permit for operation of HCGS; (b) the details of the proposed plan of study for 1
316(a) and (b) monitoring under the NJPDES Permit.
l I
l l
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^
s t
E291.8 Several figures (notably 5.1-2F, 3B, 3H, 4B, 4H) depict (ER, Sec. 5.1.3.3) the thermal effluent plume extending near, and occasionally beyond, the cooling water intake during ebbing tides.
Provide the following:
(a) an analysis of the attraction of fishes to the plume, including species, seasonality, duration of exposure; (b) an analysis of the extent to which fishes attracted to the plume will be subject to entrapment / impingement at the cooling water intake when the plume extends to the intake area;
,(c) ~ a discussion of the experience with fish attraction to the thermal plume of the Salem NGS.
E291 (gene.9 )
Provide a summary and brief discussion, by ER-OL section, ral of differences between currently projected environmental effects (including those that would degrade and those that would enhance environmental conditions) and the effects discussed in the ER-CP stage and the hearing associated with the construction permit.
E291.10 (a) Provide a bibliographic listing and reprint copies of (general) all journal and professional conference proceedings publications (by applicant and applicant's consultants) that have resulted from aquatic studies and monitoring of the Hope Creek-Salem site area.
3-7
(b)
Provide a bibliographic listing of all technical papers that have been prepared by state and federal agencies and private organizations on the aquatic resources associated with the Hope Creek-Salem site area.
E291.ll Provide a copy of the Salem NGS 316(b) demonstration at (ER,Sec.13.4) the time it is submitted to the NJDEP (scheduled for
' June 15,1983).
E291.12 Provide the basis for the statement on p. 2.1-14 that "the (ER, Sec. 2.1.3.7) dilution factor of the Delaware River decreases the area potentially affected from an 80 kilometer (50 miles) radius to a 4.8 kilometer (3 mile) radius."
E291.13 Indicate the location of the samples, their number and (T.2.4-5) period of collection, that are the basis for the data in T.2.4-5.
E291.14 Indicate the location of sampling for the data shown on (T.2.4-9)
T.2.4-9.
E291.15 Indicate the status of the total residual chlorine reduction (ER, Sec. 3.4) methodology study referred to on p. 3.4-5.
E291.16 The target free available chlorine residual concentration (ER, Sec. 3.6) at the outlet of the last service water heat exchanger is given as 0.5 mg/l in Section 3.4.1 and as 0.2'mg/l in Section 3.6.
Resolve the apparent discrepancy.
- Likewise, Section 3.4.1 indicates that chlorination of the service 3-8
water systems is planned to be continuous, whereas Section 3.6.1 indicates intermittent application.
Resolve the apparent discrepancy.
E291.17 Update the status of the planning of the treatment (ER, Sec. 5.3.1.1) system for station low volume waste water.
If available, provide information on the type and degree of treatment, expected quality of the system effluent, effluent discharge rate and location of discharge.
E291.18 Provide the rationale for the shortening of the extension (ER, Sec. 3.4) of the discharge point from 200 ft offshore to 10 ft offshore.
E291.19
. Provide the site specific chlorination effects study (ER, Sec.13.1) conducted by PSE&G to comply with the ASLB hearing order quoted at the beginning of Section 13.1.
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1 S.
l
' E310.1 The discussion of transient population (Section 2.1.2.3) omits any
/
( 2.1. 2. 3) j discussion of. U.S. Highway 13 (Delaware) which is within 16 km of the site. The applicant should indicate the extent to which the highway L
contributes to the transient population total.
The data in Table 2.1-3 for the SW Sector (8-16 km) and in Table 2.1-4 E310. 2 (Table 2.1 -4 )
do not correspond. The applicant shculd explain this apparent discrepancy.
Will the maint' nance of the HCGS transmission lines adversely affect E310. 3 e
(3.9) existing archeological resources in the three corridors (i.e., Hope Creek-New Freedc=, Hope Creek-Keeney,.and Hope Creek-Salem)? The applicant's answer should be specific with respect to the individual corridors.
E310.4 What assumptions were made in deriving the levelized lifetime estimate l
(8.1. 2.1 ) of local real estate taxes (Section 8.1.2.1)?
E310. 5 Does the estimate of local tax payments give any consideration to state L
i
{
(8.1 )
property tax abatement or exemption programs which may be applicable?
If not, what would be the effects of such programs on tax payments to localities?
I The operating staff for HCGS is estimated to be 378 persons (Section 6.1.2.2). I E310. 6 (8.1.2.2)
Does this figure include security forces and other contractor employees 1
who would regularly be employed at the HCGS site? If not, the applicant
(
should provide data on such employment and its contributicn to local payroll.
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E310.7 The applicant should provide a table showing the mid-year numbers of (8.1.2.2) operating phase workers at the site. These data should reflect utility employees and contractor personnel (e.g., security, maintenance) who would normally be found on the site, but should exclude intermittent or occasional employees, such as those employed in fuel loading. The data should also reflect broad categories of employees (e.g., operators, secretarial / dministrative, nontechnical maintenance).
The applicant should provide these data for a period beginning in 1983 and ending when
~
the complement of operating staff is on site.
~
E310.8 Does the applicant intend to purchase goods and services from suppliers (8.1.2.3) in the local (within 50 miles) area?
If so, the applicant should indicate the kind 'and amount of such' purchases.
E310. 9 What is the basis for the specific capture rates used in Secticn 8.1.2.3?
(8.1.2.3)
E311.1 Table 2.1-4 should indicate the number of people' associated with each (Table 2.1 -4) facili ty.
E311. 2 Table 2.1-5 should indicate the maximum number of visitors / day at each (Table 2.1-5) of the facilities listed.
E320.1 Explain how the estimated decommissioning costs for the various methods (Tabl e 5.8.1) listed in Table 5.8-1 were derived from NUREG-0586.
E320.2 Provide supporting data for each of the capacity factors listed in Table 8.1-1.
(Table 8.1.1) 3-11
E 451.1 Include in the discussion of windspeeds greater than 50 knots (ER0L (2.3.1.5) l Section 2.3.1.5) other occurrences of extreme winds concurrent with (R.G. 4.2, Rev. 2) the onsite data period from area National Weather Service (NWS)
Section 2.3 statio ns. Also, present frequency of occurrence of greater than I
50 knot windspeeds for long periods of record available from NWS stations as recommended in Regulatory Guide 4.2 (Rev. 2).
E 451.2 EROL Section 2.3.2 (Onsite Meteorological Data Collection Program)
(2.3.2) states:
"The present meteorological monitoring program is in con-(R.G. 4.2, Rev. 2) formance with the recommendations of Regulatory Guide 1.23".
This Section 6.1.3.1
' regulatory guide presents system accuracy specifications.
A system l
refers to the composite accuracy reflecting the errors introduced by sensor, cable, signal conditioner, and data reduction processes.
a)
Consider the precision of all components from the sensor to the recording system; determine the collective parameter accuracy for the proposed operational onsite meteorological data collec-tion program.
E 451.3 a)
Section 2.3.6 of the ER provides a description of air quality (2.3.6.1) standards in the vicinity of the site. Describe station sources (R.G. 4.2, Rev. 2) of criteria air pollutants, including estimated emissions, and Section 5.6 compare these suissions to the DeMinimus criteria established 3-12
by the Environmental Protection Agency (EPA). If station emissions are in excess of the DeMinimus levels, provide a quantitative assessment of the station emissions on local air quality using current EPA guidelines on atmospheric dispersion modelit:g.
Are these values within National and State ambient air quality standards (i.e., Table 2.3-23 for TSP)?
b)
Discuss synergistic effects of airborne emissions interacting with the cooling tower plume and present a survey of possible
' mechanisms that may lead to po'tential ambient air quality impact.
E 451.4 Substantiate the statements made in ER0L Section 5.1.4.7 concerning (5.1.4.7) cloud enhancement and shadowing.
(P..G. 4.2, Rev. 2)
&)
Compare the potential reduction in solar radiation, due to a Section 5.1.4 visible cooling tower plume, with the relative reduction in insolation which was observed during the preoperational monitor-ing program. Present findings for an annual cycle.
E 451. 5 Include in EROL Section 5.1.4.1 (Ground Fogging and Icing) a dis-(5.1.4.1) cussion on frequency of possible adverse conditions due to icing of (R.G. 4.2, Rev. 2) elevated structures by Hope Creek Generating Station (HCGS) natural Section 5.1.4 draft cooling tower plumes.
a)
Discuss the probability of icing conditions existing on elevated roads and bridges above 200 feet in the range of the visible 3-13
plume.
In the wirter months, moist plumes have been observed 1
to persist as far as 30 miles downwind.
b)
Detemine if existing air traffic or local airport operations will be adversely affected by restricted visibility aloft or possible icing conditions downwind of the station during opera-tion. The investigation should cover a distance 5 which the visible plume may be expected to reach before dissipation (relative humidity (100%).
Present~ estimates of maximum likelihood for these adverse e'nvironmental conditions to exist over areas of concern.
E 451.6 a)
Regulatory Guide 4.2 (Rev. 2) states, dispersion models used (6.1.3.2) by the applicant should be described in detail and their (R.G. 4.2, Rev. 2) validity and accuracy discussed (Reg'Datory Guide 4.2 (Rev. 2)
Section 6.1.3.2 Section 6.1.3.2), the HCGS ER only "efers in a general manner to the Models in Sections 6.1.3.2 and 2.3.5.
Either provide the infomation described in Regulatory Guide 4.2 (Rev. 2) in the ER, or provide explicit cross references to the FSAR (i.e., identify the specific infomation listed in Regulatory Guide 4.2 (Rev. 2) and cite the FSAR subsection by number) and appropriate summaries of the infomation in the ER.
IV.S. Atomic Energy Commission, Final Environmental Statement, Hope Creek Generating Station, Unit Nos.1 and 2, Section 5, February 1974.
3-14
b)
Substantiate the use of a straight-line Gaussian diffusion equation without modifications (terrain correction factors).
Consider 1) temporal and spacial airflow changes in the vicinity of the site (N50 miles); ii) possible mesoscale circulation during the summer months, when pronounced differ-ential heating of land and water occurs.
E 460.1 Acceptance Criterion II.2 of SRP 11.4 requires a Process Control (SRP 11.4)
Section 11.4 Program (PCP) for the solidification of solid radwaste.
of the FSAR states that the topical report WPC-VRS-001 (Rev.1) dated May 1978, which has been approved by the NRC, will be used.
"Page 7.7 of this topical report states that the feedstream chemical composition and per cent of solids in the feedstream are required to detemine the end product. Tables V-1, V-2, and V-3 provide maximum radioactivity limits for the feedstream.
In Section 1.8 of the FSAR, you take exception to Regulatory Guide 1.21 for detemining the quantity and composition of solid waste. Provide the infomation on laboratory tests that will be conducted under the PCP to assure that the feedstream will be within the parameters in WPC-VRS-001 (Rev.1) for chemical, physical, and nuclide quantity and composition; the frequency of feed sample testing; and the method that will be used to establish feed conditions.
khat type 3-15
of laboratory / field instruction record sheet will be used within the PCP at HCGS.
Address the 1% of oil limit on the feedstream. Specify the program to be used whenever a batch fails to solidify. Address the fire protection measures recommended by the topical report.
E460.2 Your response in Section 1.10 of the FSAR to task action (SRP 11.2, 11.3, and item III.D.1.1 is not complete. You should provide a list of the others) systems and subsystems to be tested, the frequency of leakage tests, and method that will be used to detemine leakage rates. In order to establish a bases for each system or subsystem leakage, an initial test is recomnended so that future tests can be compared and main-tenance requirements can be scheduled.
What goals will be established for the liquid and gaseous systems and subsystems in the initial testing? Your response should addres's the North Anna incident (clarification item 3).
Provide the additional infomation as to how you intend to meet the positions and clarifications of III.D.1.1.
E460.3 On June 1,1976, PSE&G submitted a cost-benefit analysis for HCGS (SRP 11.1) in response to the requirements of Appendix I to 10 CFR 50, In the document, enclosure 1, page 6.1, a capital recovery factor which re-flects the cost of borrowed money was assumed to be 0.1150 (based on 11% interest).
In order for us to complete our review for the OL stage, provide the present recovery factor if different from that' provided in the June 1,1976 submittal.
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E 470.1 (Section 2.1):
1.
Update or reconfirm that the infomation provided in Chapter 2, Section 2.1, Tables 2.1-9 through 2.1-14 of the ER-OL are current.
2.
Is the total recreational catch given in Table 2.1-14 in units of number of fish / year or kilogram of fish / year?
3.
Provide updated data for recreational catch (kilograms / year) for fish and invertebrates in both Delaware and New Jersey.
E 470.2 (Section 2.4.2.2):
For the public water supplies (well locations) within 40 kilometers (25 miles) of the proposed HCGS-1 site shown in Table 2.4-14 and Figure 2.4-21 which may be recharged by the Delaware river provide the following infomation:
1.
The transit times and dilution factors for each water supply location and the basis or method of calculating these values, and 2.
Population served for Smyrna, Delaware and New Castle, Delaware.
E 470.3 (Section 2.4):
For the private water wells within 8 kilometers (5 miles) radius of the site listed in Table 2.4-15:
3-17
1.
Indicate the wells which are in use and which may be recharged by the Delaware River and their distancesfrom the HCGS-1 site.
2.
Provide the transit time and dilution factors for each well in use and the basis or method of calculating these values.
E 470.4 (Section 5.2):
Confirm if the distance of 35 miles NW for the nearest farm residence, milk-cow and meat animal shown in table 5.2-2 is correct.
E 470.5 (Sectf on 5.1):
Milk sampling station (code SF1) located at 6.5 mi E of vint and listed in Table 6.1-3 is not shown on Figure 6.1-2 which depicts the offsite radiological sampling locations.
E 470.6:
For population shoreline. recreation, swimming and boating provide updated infor-mation on:
a.
Location (access areas) b.
usage (person-hours) c.
dilution factors, and d.
transit times (hours) i 3-18 w
ENCLOSURE 4 Request for Additional Information Hope Creek Generating Station Docket No. 50-354 n
There are many areas in which requirements have been added or modified, or in which staff concerne have been raised in the review of other pending OL applications. To expedite the review process for your application, it is requested that you evaluate these areas and, where appropriate, upgrade your FSAR to include how these requirements are met or how these staff concerns are resolved.
You should submit these, changes to the FSAR, in amendment fora, within s.ixty days from the~ docketing date except as other-wise noted below.
(1) Safety-Related Structures, Systems and Components (0-list)
Controlled by the QA Program - Staff requests for additional information regarding this issue have been sent to a number of OL applicants. A sample request from the Perry review is s
provided ahtEnclosure 5.
(2)
Fracture Prevention of Containment Pressure Bouhdary'(GDC 51) -
' provides the technical basis by which the staff determines compliance with GDC.51.
Preservice and Inservice Inspect' ions - Staff guidance in this (3) review area has been sent to a number of pending OL applicants.
1 A copy of that guidance is provided as Enclosure 7.
(4)
Preservice Inspection and Testing of Snubbers - The staf f has recently established requirements to ensure snubber operability which have been transmitted to pending OL applicants. A copy of those requirements is provided as Enclosure 8.
(5) Equi oment Qualifications: Seismic and Environnental - Seismic and Dynamic Qualification and Qualification of Mechanical Equipment reviews consist of two elements: a review of the FSAR, and a detailed onsite audit. The information required for the review is included as Enclosure 9 and its attachments. This information will not be required until the first calendar quarter of 1984 (6)
Procedures and Training for Station Blackout - In response to a recommendation in a recent decision by the Atomic Safety and Licensing Appeal Board ( ALAB-603), to ensure that station blackout eve,nts can be accommodated, the staff is requesting licensees and OL applicants';
to implement emergency procedures and a training program for station blackout events. A copy of that request is provided a: Enclosure 10.
D )' Initial Test Program Reviews - A discussion of problems encountered during recent OL application reviews is included as Enclosure 11 along with a recommended course of action to reduce Test Program review time.
4-1
ENCLOSURE 5 PERRY Request for Additional Information 260.0 Quality Assurance 260.6 Section 17.1.2.2 of the standard format (Regulatory Guide 1.70) requires the identification of safdty-related structures, systems, and components controlled by the QA program. You are requested to supplement and clari-fy Table 3.2-1 of the Perry FSAR in accordance with the following:
a.
The following items do not appear on FSAR Table 3.2-1.
Add the appropriate items to the table and provide a commitment that the remaining items are subject to the pertinent requirements of the FSAR operational quality assurance program or justify not doing so.
1.
Safety-related masonry walls (see IE Bulletin No. 80-11).
2.
Biological shielding within the fuel handling intermediate building, control building, and reactor building complex auxiliary building.
3.
Missile barriers within the fuel handling intermediate building, reactor building complex auxiliary building, control building, diesel generator building, off-gas building, and emergency service water pump house.
4.
Spent fuel pool and liner.
5.
Drywell-wetwell vacuum breaker.
6.
Diesel generator combustion air intake and exhaust system.
7.
Radiation monitoring (fixed and portable).
8.
Radioactivity monitoring (fixed and portable).
9.
Radioactivity sampling (air, surfaces, liquids).
10.
Radioactive contamination measurement and analysis.
- 11. Personnel monitoring internal (e.g., whole body counter) and external (e.g., TLD system).
12.
Instrument storage, calibration, and maintenance.
13.
Decontamination (facilities, personnel, and equipment).
- 14. Respiratory protection, including testing.
15.
Contamination control.
16.
Accident-related meteorological data collection equipment.
7 5-1
\\
- 17. Seismic category I slopes of the Lake Erie shoreline bluff located 305 feet north of the emergency service water pump-house.
- 18. Seismic category I fill.
19.
Foundation for seismic category I electrical duct banks and manholes.
- 20. Site grading and watershed alterations.
- 21. Valve operators for all safety-related valves.
- 22. Motors for all safety-related pumps.
b.
The following items from FSAR Table 3.2-1 need expansion and/or clari-fication as noted. Revise the list as indicated or justify not doing so.
1.
Provide a comitment that the safety-related instrumenta-tion and controls (I&C) described in Sections 7.1 through 7.6 of the FSAR plus safety-related I&C for safety-releced fluid systems will be subject to the pertinent requirements of the FSAR-QA program. This can be done by footnote to Table 3.2-1.
2.
For the systems shown below, expand the list in Table 3.2-1 to include the indicated components under the pertinent 10 CFR 50 Appendix B quality assurance requirements or verify that they are included as part of the components already lis ted.
IX RHR System Containment spray nozzles Conical stainless strainer XXIII Offgas' System As per Section C.6 of Regulatory Guide 1.143 XXXII Standby AC Auxiliary Power Systems (Class IE)
Diesel generator packages including auxiliaries (e.g., lube system, Jacket cooling, air start system, governor, voltage regulator, excita-tion system) 6900 volt switchgear 480V load centers 480V motor control centers Instrumentation, control, and power cables (including underground cable system, cable splices, connectors and termina,1. blocks) 1 5-2
e Conduit and cable trays and their supports containing Class IE cables and those whose failure may damage other safety-related items 6900/480V transformers Valve operators Protective relays and control panels AC control power inverters Containment electrical penetration assemblies Other cable penetrations (fire stops)
XXXIII 125 Volt Class IE DC Vital Power Distribution System 125V batteries, battery chargers, and distribu-tion equipment Cables Conduit and cable trays and their supports con-taining Class IE cables and those whose fail-ure may damage other safety-related items Battery racks Protective relays and control panels XXXIV Structures Reactor pressure vessel shield wall annulus Drywell head compartment RWCU heat exchanger compartment RWCU demineralizer valve compartment RWCU demineralizer compartment R4CU valve nest compartment Main steam tunnel compartment Drywell-to-suppression pool vents XXXV.1 Annulus Exhaust Gas Treatment System Units k
Filter housing i
Fans and motors Demis ters Heaters j
Ductwork Dampers I
XXXV.12 Fuel Handling Building Exhaust Units Filter housing Fans and motors Demisters Heaters Ductwork Dampers e
i 5-3 '
k
-, ~
XXXV.25 Control Room Emergency Recirculation Units Filter housing Fans and motors Demis ters Heaters Ductwork Dampers XXXV.3O' Combustible Gas Control Hydrogen analyzer i-Hydrogen recombiners XXXV.
Control Room HVAC System Fans and motors Coolinp coils (DX)
Fil ters Humidifiers r.
Condenser Charcoal filter housing Ductwork and dampers Valves with safety isolation function Utility exhaust fan Unit heaters of NUREG-0737, " Clarification of TMI Action Plan Require-c.
ments" (November 1980) identified numerous items that are safety-related and appropriate for OL application and therefore should be on 4
Table 3.2-1.
These items are lis ted belav. Add the appropriate items to Table 3.2-1 and provide a commitment that the remaining items are subject to the pertinent requirements of the FSAR operational QA pro-gram or justify not doing so.
NUREG-0737 Clarification Item
- 1) Plant-safety-parameter display console.
I.D.2 2)
Reactor coolant system vents.
II.B.1
- 3) Plant shielding.
II.B.2 4)
Post accident sampling capabilities.
II.B.3
- 5) Valve position indication.
II.D.3 6)
Dedicated hydrogen penetrations.
II.E.4.1 7)
Containment isolation dependability.
'*II.E.4.2 5-4
8)
Accident monitoring instrumentation.
II.F.1 9)
Instrumentation for detection of inade-II.F.2 quate core-cooling.
'10) HPCI & RCIC initiation levels.
II.K.3(13) 11)
II.K.3(15) 12)
Challenges to and failure of relief II.K.3(16) valves.
13) hDS actuation.
II.K.3(18) 14)
Restart of core spray and LPCI.
II.K.3(21) 15)
R.CIC suction.
II.K.3(22) 16)
Space cooling for HPCI & RCIC.
II.K.3(24) 17)
Pmver on pump seals.
II.K.3(25) 18)
Common reference level.
II.K.3(27)
- 19) ADS valve, accumulators, and associated II.K.3(28) equipment and instrumentation.
- 20) Emergency plans (and related equipment).
III. A.l.1/III. A.2
- 21) Equipment and other items associated with III. A.l.2 l;
the emergency support facilities.
22)
Inplant 12 radiation monitoring.
III.D.3.3 23)
Control-room habitability.
III. D. 3. 4 I
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ENCLOSURE 6 FRACTURE PREVENTION OF CONTAINMENT PRESSURE BOUNDARY (GDC-51)
Our safety evaluation review assesses the ferritic materials that constitute the containment pressure boundary in the nuclear plant containment system to determine if the material fracture toughness is in compliance with the requirements of General Design Criterion 51, " Fracture Prevention of Con-tainment Pressure Boundary".
'GDC 51 requires that under operating, maintenance, testing and postulated accident conditions, (1) the ferritic materials of the containment pressure boundary behave in a nonbrittle manner and (2) the probability of rapidly propagating fracture is minimized.
The Hope Creek primary containment includes a ferritic steel containment vessel (drywell), a ferritic steel suppression chamber (torus) and vent pipes providing the connection between the drywell and the torus. The ferritic materials of the containment pressure boundary, which are con-sidered in ou. assessment, are those which have been applied in the fabrica-tion of the drywell, drywell head, torus, vent pipes and primary containment equipnent hatch, personnel lock and penetrations and piping system components including the valves required to isolate the system. These components are the parts of the containment system which are not backed by concrete and must sustain loads under the conditions cited by GDC-51.
The acceptability of these materials within the context of GDC-51 is determined in accordance with the fracture toughness criteria identified for Class 2 materials by the Summer 1977 Addenda to ASME Code Section III.
6-1
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ENCLOSURE 7 l
PRESERVICE' INSPECTION We require that your inspection program for Class 1, 2 and 3 comoonents be in accordance with the revised rules. in 10 CFR Part 50, Section 50.55a.
car.agraph (g). Accordingly, submit the following information:
(1), A preservice inspection pla'n which is consistent with the required edition of the ASME Code. Tnis inspection plan should include any exceptions you prep:sa :s the C de requirements.
(2) An inservice inspection plan submitted within six =enins cf :ne anticipated date for c:=ercial c:eration.
This crescryice ins:e: tion plan will be recuired to support the safety evaluation re:cr: finding regarding your cc=sliance witn ;reservict and inservice ins:ection recuirements. Our deter =ination of your
- =cliance will be based on :ne edition of Section XI of :ne ASME Cece
-efe-ea.ced in your FS*R er later editicas of Se::ica XI referenced in the FICE.UL REr2ISTER :na; ycu.=ay elect to a;;1y.
Y:ur res: nsa to this ita= sh uld dafine the a;clicable edition (s) an:
su:secticns of Secticn XI cf the ADiE Code. If any of the examination recuirements of tne particular edition of Se::icn XI you referenced in :ne r5AR cannot be met, a recuest f=r relief must be sub=itted, including c::alete technical justification :: supper your recuest.
Detailec guidelines for tne pre:aration anc ::r.:en cf the ins:ection progra:.s to be sub=itted f:r staff review and f=r relief re:uests are a: acnec as an Appendix to Secti:n 121.0 cf Our review cuestions.
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APPENDIX TO SECTION 121.0 GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PP.0 GRAMS AND RELIEF REQUESTS PUP.5UANT TO 10 CFR 50.55a(9)
A.
Descriction of the Preservice/ Inservice Insee: tion Procram I
This =r:cra= should cover the recuirements set forth in Section 50.55a(b) and (g) of 10 CFR Part 50; the ASME Boiler and Pressure Vessel Code,Section XI Subsections IAW, IWS, IWC,and IWD; and Stancard Revien Plans 5.2.4 and,
6.6.
The guidance provided in this enciesure is -intanced to illus: rate the type and extent of information that shoulo ce orovided for NRC,
review.
It also describes the infor=ation necessary f:r "recuest f:r relief" of items that cannot be fully inscacted to the recuire=ents of i
Section XI of the ASME Code.
By utili:ing tnese guidelines, acclicants can significantly recuce :ne need for recuests for additional informa-tica f r:m :ne NRC staff.
5.
Contents f the Submittai The information listed below shculd be inciuced in :ne submittal:
1.
For each facility, include the apolicable date for the ASME Cece and :ne a::recriate accenda ca:e.
2.
The period and interval for which this program is acolicable.
5.
Provideftne crocosed coces and addenda :: de used for recair,
- difica:1cns, a:di:icns er alternations to the facility wni:n might be i=:lemented during this inscection cerie:.
4 Indicate One c::::nents and lines that y:u nave exe==:ed under the rules of Section XI of the ASME Code. A reference to the acclicable paragraph of :ne code that grants tne exem: tion is necessary. The insmection recuirements for ext =ctac c ::enents sh:uld be stated (e.g., visual inspection during a crassure test).
5.
Icentify the ins ection and pressure testing recuirements of the applicable pertion of Section XI that are cremed icaractical because.cf the limitations of cesign, gecmetry, er materials of constructicn of the ccm:enents. Provice ne infer:ation recuested 1
in the fo11cwing section of this appendix for the inspections and pressure tests identified in Item 4 above.
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l C.
Recuest for Relief from Certain Inscection end Testine Recuirements It has been the staff's experience that many requests for relief from testing recuire=ents sub=itted by applicants and licensees have not been supported by adequate descriptive and detailed technical infor-mation. This detailed information is necessary to:
(1) document the imoracticality of the ASME Code requirements within the'limita-tions of design, geometry, and =sterials of construction of commonents; and '(2) detennine whether the use of alternatives will provide an
. )
i acceptable level of quality and safety.
i Relief, recuests submitted with a justification such as "imeractical,"
" inaccessible," or any other categorien1 basis, recuire additional infor=ation to cer=it the staff :: mak.e an evaluatien of tha reli.ef recuest. The objective cf the guicance crevicec in :nis section is to illustrate the extent of the infer =stien that is recuired by the GRC staff :: =ake a pr:ser eval:1:i:n and := adequately cocumen:
the basis for granting the relief in :ne staff's Safety Evaluation Recert. The NRC staff believes su:secuent recuests for additional
. infer =atien and delays in c:==leting :ne review can be c=nsiderably reduced if this information is crevicec initially in :ne a:olicant's sub=ittal.
For enca relief recuest sub=it:sc, :ne felicwing inf:r=a:icn shoulc be in'clude::
1.
An identification of the c:::enen:(s) and/cr tne examina icn recuire=ents for which relief is recuested.
The nu= er of items assccia ad with :ne recuss:sc relief.
2.
3.
The ASME Code ciass.
4 An identification of :ne s:ecific ASMI Occe recuire=ent na: nas been ce:ar=ined to be i=:ractical.
5.
The infor=a:icn to sup:O r: the deter =ination tna: the recuire=en:
is i=:ractical; i.e., state and ex: lain the casis fer recuesting relief.
5.
An identificatien of the alternative examina:icns :na: are pre:osed:
(a) in lieu cf :ne recuirements ef' Se::icn XI: cr (b) to supole=ent exa=ina:1cns cerfpr=ec car:ially in c:=cliance with the recuire=ents of Section I!.
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7.
A description and justification of any changes ex:ected in the overall level of plant safety by perfoming the proposed s
alternative examinations in lieu of the examination required by i
Section XI.
If it is nct possible to perform alternate examinations, discuss the impact on the overall level of plant t
quality and safety.
For inservice inspection, provide the following additional information regarding the inspection frequency:
i 8.
State when the request for relief would apply during the insoection period or interval (i.e., whether the recuest is to de?tr an examination).
9.
State when the procosad alternative exa=ina:icns will be.
implemented and performed.
- 10. ~5 tate the time period for which the recuested relief is needec.
i Technical justification or ca:a ast be su=itted a succor. tne relief recuest. 0:iniens witacu: substantiation that a change wil'.
not affect the cualf:y level are unsatisfac::ry.
If the relief is recues.ed f:r inaccessibility, a caailed cascriptica er drawir.;
wnich decicts tne inaccessibili y cus: accc=pany ne re:uest. A
~
relief recuest is not re:uired for tests crescribed in Section X:
- na: :o not apply to your fa:ility. A stater.:n ef "n/A" (n:-
applicable) er "N:ne" will suffice.
O.
Recuest for Relief for Radiation C:nsiceratiens Ex:csures of :es: cersennel :: radiation to acc:=clish :ne examina-tiens :rescribed in Section XI of :ne ASME Coce can es c.
1 :=r:an:
fac::r in cetermining wnetner, Or uncer wna: c:ndi:icas, an exa=ina:icn mus :e :erfor=ed.
A re:uest fcr relief =ust be su::i::ec by :ne licensee in :ne manner ces:ribed acove for inaccessibility anc cus be su:secuently approved by the NRC staff.
We rec:eni:e tna; sc=e of the radiatien considerations will cnly be known a: the time of the test. However, the licensee generally is aware, from ex:erience a: c erating facilities, of in:se areas 'where relief will be necessary and should sub=i as a mini ;=, the felicwing information with :na repues fer relief.
1.
The :tal estimated man-rem ex:csure involved in :ne examinatie'n.
2.
The radiation levels a: :ne test area.
e.
.7-4' e
3.
Flushins or shielding capabilities which mignt recuce radiation levels.
4.
A proposal for alternate inspection techniques.
5.
A discussion of the considerations involved in reacte inspegtions.
6.
Si::rilar welds in redundant sys:g=s or similar welds in the same syst==s which can be inspected.
7.
Tne results of preservice inspection and any ins'ervice results i
'for the welds for which the relief is being recuested.
8.
A discussion for tne consecuences if the weld whicn was. net
~
examined, did fail.
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ENCLOSURE 8 TO 'LL APPLICANTE:
Due to a long history of problems dealing with inoperable and incorrectly installed snubbers, and due to the potential safety significance of failed snubbers in safety related syste=s and c =p:nents, it is requested that maintenance records for snubbers be documented as follows:
, Pre-service Examination A pre-service-examination should be made on all snubbers listed in tables This exami-3.7-4a and 3.7-4b of Standard Technical. Soecifications 3/4.7.9 nation should be made after snubber installation but not more than six months prior to initial system pre-operational testing, and should as a,mimimum verify
~
- the following:
(1)
There ari no visible signs of camage or i=ctired operability as a result cf storage, handiing, or instaliation.
The snubber location, orientatien, position setting, anc c:nfiguration (2)
(attachments, extensions, e::.) are ac:ording to cesign drawings anc speci fictions.
(3)
Snubbe: s are not seized, frozen or ja==ec.
(4) Ace:uate swing clearance is pr: viced t: allow snubber m:vement.
(5)
If a;;iitabie, fluid is to the re::= mended level and is not leakin; fr:m the snubber system.
Structurai c:nr.ections such as ; ins, f asteners anc etner : nnecting (5) hardware such as lo k nuts, tabs, wire, :::ter : ins are insta11ec c:rrectly.
If :ne peri:d Oe ween the initiai Ore-servi:e exz=ination and initial syste.
- re-oceratienzi tes: exceeds sin ::nths cus :: unex e: ed situati:ns, re. examination of items 1,4, and 5 shai'. :e ;erf:rted.
Snub:ers whi:n art mee
- ne a::ve re:uirements must installed inc:rrectly or c herwise faii be re: aired or-replaced and re-ext =ined in.at::rdance with the above criteria.
Pre-Oceratienal Testine Ouring pre-o:erational testing. snubber thermai ::vements for systems wh:se i
- erating te::erature exceeds 250* F sh:uld be verified as follows:
Ouring initial system heatue and c:cid:wn, at sce:ified temperature (a'
intervals 1:r any system whi:h attains ::erating er; era ure, verify the snub er ex:ected thermai c0ve.i.en.
For th:se systems whi$h de n : attain c:erating tem:erature, verify (b) via cbservation and/or calcula* ion that the snubber will acc==m:date j
the projected thirmal movc=ent.
Verify the snuSber swing clearance at specified heatu; and cocidown (d)
Anv ci'stre:encies Or in :nsistencies'~shall be evaluated for interval s.
cause and c5rr'e:ted prior t: pr:teeding : :ne next specified ' interval.
i 1
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The above described operability ' program for snubbers should be included and documented by the pre-service inspection ano pre-operational test programs.
The pre-service inspection must be a prerequisite for the pre-operatiera1 testing of snubter ther=al motion.
in Chapter 14 of the FSAR This test program should be specified i
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ENCLOSURE 9 SEISMIC AND DYNAMIC QUALIFICATIONS REVIEW Seismic and Dynamic Qualification and Qualification of Mechanical Equipment reviews consist of two elements. First is a review of the general program described in the FSAR. Second is a detailed on-site audit of equipment as installed and the qualification documentation.
In general, the FSAR contains very little infomation on how the applicant's equipment qualification program is actually being implemented.
Consequently, on-site audit is an important element of our review.
The attached information request is intended to inform the staff of your progress in the equipment qualification program.
e t
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Equipment Qualification Branch Audit Review Teams Request for Information To confirm the extent to which safety-related equipment meets the requirements of the General Design Criteria (GDC) of 10 CFR Part 50, f
the NRC staff, assisted by Technical Assistance Contractors, will conduct a plant site audit and review.
It is our intent to conduct a plant specific on-site Pump and Valve Operability Review Team (PVORT) audit and a Seismic Qualification Review Team (SQRT) audit.
Since the site audit is performed on a sampling basis it is necessary to ensure that 85 to 90 percent of the safety related equipment are qualified and installed before the audit.
In order that the staff is familiar with the seismic and dynamic qualification programs currently being conducted, it is recuested that all test orocrams be identified by submittine a brief description of the orogram, items being tested, the vendor or the testing laboratory involved, and the dates and location of the tests.
In formation about the ongoing test programs should be submitted as soon as possible so that the NRC staff can review and witness relevant tests for selected items.
A list of all safety-related equipment should be provided so that an assessment of the equipment qualification status can be made by the staff.
Equipment should be divided first by system then by component type.
Attach-ment #1 shows a tabular fntmat which should be followed to present the status summary of all safety-related equipment.
9-2
After the information on Attachment #1 is received, and it is determined that the equipment qualification is substantially complete, selections will be made of the equipment to be audited, and reviewed, by the SQRT and ?VORT. Specific information on equipment selected for audit by each
. review team will be requested.
The infomation that will be requested for those equipment selected by the SQRT is shown in Attachment #2. The information that will be requested for those equipment selected by PVORT is shown in Attachment #3.
In addition, the applicant will be requested l
to provide a complete set of floor response spectra identifying their 1
j 1
applicability to the equipment listed in Attachment #1.
For the equipment selected by the SQRT for audit, the combined Required Response Spectra (RRS) or the combined dynamic response will be reviewed.
The SQRT will examine and compare the equipment on-site installation v/s the test configuration and mounting, and determine whether the test, or analysis which has been conducted conforms to the applicable standards and agrees with the RRS.
In cases where the plant is a BWR facility, the equignent qualifying documentation must also provide evidence that the hydrodynamic loads in the (0 - 100) Hz frequency range have been accounted for.
For the equipment selected by the PVORT for audit, the applicant must provide evidence that appropriate manufacturers' tests have been conducted,~ reviewed, and approved, and that the equipment meets, or exceeds the design requirements.
The applicant must also provide qualification test and or analysis results that provide assurance that the equipment will operate (function) during and following the Design Basis Events (DBE) and all appropriate combinations thereof.
9-3
9 The specific information' requested in Attachments #2, and #3 should be provided to the NRC staff two weeks prior to the plant site visit.
The applicant should make available at the plant site all the pertinent documents and reports of the qualification for the selected equipment.
After the visit, the applicant should be prepared to submit certain selected documents and reports for further staff review.
The purpose of the audits is to confirm the acceptability of the qualification procedures, and implementation of the procedures t.o all safety-re. lated equipment based on the review of a few selected pieces.
If a number of deficiencies are observed or significant generic concerns arise, the deficiencies should be removed for all eouipment imoortant to safety subject to confirmation by a follow-up audit of randomly selected items before the fuel loading date.
The site audits will also include a review of the extent to which the documentation of equipment qualification is complete.
The acceptance criteria for requirements en records is provided in Section 3.10 of the Standard Review Plan Revision 2 (NUREG-800).
Another element of the seismic and dynamic qualification review deals with the containment isolation valves for the purge and vent systems to assure their ability to close against postulated accident pressure inside contain-ment.
Information needed for this review and the basis for the review are provided in Attachments 4 and 5.
I 9-4
[
ATTACHMENT NO. I to ENCLOSURE 9 0 MASTER LISTING OF SEISMIC. AND DYNAMIC QUALIFICATI0ti
SUMMARY
AND STATUS OF SAFETY-RELATED EQUIPMENT 8 ASSOC IEED EXPLANATORY NOTE j
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MASTER LlSTlhlG OF S EDSHIC AND DYNAMIC QUALIFICATION
SUMMARY
AND STATUS OF SAFi?T.Y.PELATeb limitPNEN,]} *..
et htl T tw.ts:
pocket NO:
UTILITY:
A/Es NSSS:
ras n or ),
l ^
FOR EOlllPMEN T LISTED BELOW rise suppi.png is : Aty D, NSSS D, OTIIER O.
SAFTY SYSTEM & FUNCTION ARE :
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na rie us v n,,, (ra,Vfer Q '%> vsus ucce n o r> r ia n mA?i ns.
no.
nn ea0 rion rusa wc nan wa> att 6* a) 'ON iL"a I
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T;
f NOTES TO MASTER LISTING i
(1) The infomation on P1 ant Name, Do::ket No., etc., are pertinent to the power station and will be the same for all sheets.
(2) The equipment is listed by supplier (circle one after " SUPPLIED BY:") and by system (indicate name and function of system after
" SYSTEM AND FUNCTION:").
Typical safety systems, for example, are Engineered Safeguard Actuation, Reactor Protection, Containment Isolation, Steamline Isolation, Main Feedwater Shutdown and Isolation,'
Emergency Power, Emergency Core Cooling, Containment Heat Removal, Containment Fission Product Removal, Containment Combustible Gas Control, Auxiliary Feedwater, Containment Ventilation, Containment Radiation Monitoring, Control Roan Habitability System, Ventilation for Areas Containing Safety Equipment, Component Cooling, Service Water, Emergency Systems to Achieve Safe Shutdcwn, Postaccident Sampling and Monitoring, Radiation Monitoring, Safety-Related Display Instrumentation.
The supplier will usually he either A/E or NSSS.
Use separate sheets for each system.
Use additional sheets when a givan system has more equipment than can be listed on one sheet.
(3)
"IDENT. NO." is to be filled in by the organization preparing the list.
Each equipment listed should have separate ide~ntification number.
The following form is reconmended:
(a) For A/E supplied equipment, the number may be "B0P-XXX."
If more than one group is preparing forms, the number may be "B0P-M-XXX" (Mechanical) or " BOP-IC-XXX" (Instrumentation and C ontrol ).
(b) For NSSS supplied equipment, the number, may be NSSS-M-XXX, NSSS-IC-XXX, etc.
(c) The number written on each line (for each listed equipment) should be an ordered numeric listing for the above indicated-XXX (-001 through completion).
These numbers need not follow in order for each system (-002 and -004 may be with one system, but -003 may be with another system).
(d)
Inside the parerithesis should be the " BOP-M," "hSSS-IC," etc.
(4) The " TYPE" refers to its generic name, such as pressure transmitter, indicator, solenoid value, cabinet, etc.
Equipment type should be described by indicating for example, motor driven pump, turbine driven pump, motor operated valve, air operated valve,18" valve, t
etc. Following abbreviations can be used where appropriate.
Valves:
BV - Ball valve, BFV - Butterfly valve, CV - check valve, DV - Diaphragm valve, GV - Gato valve, GLV - Glove valve, SV - Safety Valve, RV - Relief Valve Pumps:
CP - Centrifugal pump, PDP - Positive displacement pump, DDP - Deep draft pump, JP - Jet pump 9-7'
O (5)
Quantity refers to the number of the same equipment used in the pl ant.
(6)
Under mounting condition indicate the following as applicable:
CF for concrete floor mounting CW for concrete wall mounting DM for direct mounting HM for hanger mounting RM for rack mounting CM for cabinet mounting EM for equipment mounting Mounting details such as number of bolts, weld length, etc. need l
not be indicated here.
(7) The columns "SEI5MIC" and "0THER DYNAMIC" need only be checked (X) if applicable.
In the case of BWRs indicate "H" under~ "0TiiER DYNAMIC" column where qualification includes hydrodynamic loads.
(8)
Under " REQ'D INPUT (IPA)," the applicable "g" level should be p rovided.
(9)
Under Qualification Method under a'nalysis, indicate "S" for static, and "D" for dynamic; under test frequency, indicate "SF" for single, and "MF" for multiple; and under text direction, indicate "SD" for single, "MD" for multiple.
(10) Equipment status is to be addressed separately to qualification and to installation..
i The applicable letter should be provided under the column headed
" QUAL," according to the following code:
A The qualification and associated documentation are complete.
B The qualification testing is finished but associated documentation is not yet submitted or still in review.
C The qualification plan / procedure is documented, but testing has not yet begun.
D Equipment to be qualified.
E Equipment is judged not qualifiable and will be replaced with qualified equipment.
F For BWR plants only:
Equipment is qualified for seismic loading only.
Requalification will be perfonted to account
'for the suppression pool hydrodynamic loading effects.
' 9-8
The applicable letter should be provided under the colunn headed
" INSTALLATION," according to the follcwing code:
A Installation is completed.
Equipment is ready for service.
i B
Equipment mounting / hookup is completed, but significant parts of the equipment are not yet installed.
C Equipment is located at its inte'nded service location, but mounting and/or hookup is not completed.
D The equipment is not installed and is not available for inspection.
(11) The Required Response Spectra (RRS) package should be provided along with the Master Listing.
Only response spectra applicable to the listed equipment should be included, each numbered for reference under the column headed "RRS REF."
In many cases, several equipment will reference the same RRS.
(12) Codes and Standards Applicable codes, standards and Regulatory Guides should be indicated here, for example, ASME Section III Class 2; IEEE-344,1975, 323-1974, 382-1972; ANSI N278-1, Regulatory Guide 1.100, 1.148 etc.
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Attachment #2 to -
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ENCLOSURE 9 Seismic and Dynamic Qualification Summary of Equipment I.
Plant Name:
Type:
1.-
Utility:
PWR:
2.
NSSS:
BWR:
-l 3.
A/E:
Other II.
Component Name:
1.
Scope:
[
]NSSS
[
] BOP
[
] Other 2.
Model Number:
Quantity:
3.
Size or Range:
4.
Vendor:
5.
If the component is a cabinet or panel, name and model Number of the devices included:
6.
Physical
Description:
a.
Appearance:
b.
Dimensions:
c.
Weight:
7.
Location:, Euilding:
Elevation:
8.
Field Mounting Conditions
[ ] Bolt (No.
, Size
)
[
] Weld (Length
)
[ ]
9.
Mounting Orientation [e.g., on floor, cantilevered, suspended, etc.]
10.
a.
System in which located:
b.
Functional
Description:
c.
Is the equipment required for [
] Hot Standby [
] Cold Shutdown
[
] Both
[
]Neither
[
] Other 9-10
.11.
Pertinent ReferencelDesign Specifications for Qualification Requirements:
-+
a.
Seismic Input d.
Service Conditions b.
Hydrodynamic Load Input e.
Qualified Life c.
Fatigue Considerations III.
Is fouipment Available for Inspection in the Planti
[
3 Yes
[
] No
[
] Partial or limited availability IV.
Equipment Oualification Method:
[
] Test
[
] Analysis
[
] Combination of Test and Analysis Qualification Report *:
(No., Title and Date):
Company that Prepared Report:
Company that Reviewed Report:
Where Report is filed or available:
Applicable Codes And/0r Standards:
V.
Vibration Inout:
, 1.
Loads considered:
a.
[
] Seismic only b.
[
] Hydrodynamic only c.
[
] Vibration from normal operation d.
[
] Combination of (a), (b), and (c) 2.
Method of Combining RRS:
[
] Absolute Sun
[
] SRSS
[
]
jother, specify) 3.
Required Response Spectra ** (attach the graphs):
NOTE:
"If more than one report complete items IV thru VII. for each report.
- If other than RRS is used, describe method.
9-11
--y
=
~
y, y,
p-y-
s w-w-
p p
4.
Damping Corresponding to RRS:
Required Acceleration in Each Direct:
i
[
]2PA
[
] Other (speci fyl OBE S/S =
F/B =
Y=
k.
SSE S/S =
F/B =
V=
6.
Were fatigue effects considered:
[
] Yes
[
] No If yes, describe how they were treated in overall qualification program:
VI.
If Qualification by Test, then Ccmolete:
1.
[
] Single Frequency
[
] Multi-Frequency
[
] random
[
] sine beat
[
]
2.
[
] Single Axis
[
] Multi-Frequency
[
] Independent Axis
[
] In-phase motions 3.
Number of Qualifications Tests:
OBE SSE Other (speci fy) 4 Frequency Range:
5.
Natural Frequencies in Each Direction (Side / Side, Front /Back, Vertical):
S/S =
F/B =
V=
6.
Method of Determining Natural Frequencies
[
] Lab Test
[
] In-Situ Test
[
] Analysis 7.
TRS enveloping RRS using Multi-Frequency Test
[
] Yes (Attach TRS & RRS graphs) i j
[
] No I
9-12 i
.~
l 8.
Maximum Input g Level Test.
OBE S/S =
F/B =
V=
OBE S/S =
F/B =
V=
9.
Laboratory Mounting:
A.
[
] Bolt (No.
', Size ____)
[
] Wald (Length
)
[
]
B.
Orientation and Fixturing:
10.
Functional operability verifieo:
[
] Yest
[
]'o
[
] Not Applicable N
11.
Test Results including modifications made:
12.
Other tests performed (such as aging or fragility test, including results):
13.
Failure Modes (If appropriate
)
14 Margins Available:
[
]InputSpectrum
[
] Fragility VII.
If Qualification by Analysis, then complete:
1.
Method of Analysis:
[ ] Static Analysis
[
] Equivalent Static Analysis
[ ] Dynanic Analysis:
[
] Time-History
[
] Res;cnse Spectrum 2.
Natural Frequencies in Each Direction (Side / Side, Front /Back, Vertical):
S/S =
F/B =
V=
3.
Model Type:
[
] 3D
[
] 20 I
] 10
[
] Finite Element
[
] Beam
[
] Closed Form Solution
[
] Other 9-13 w
4
[
] Computer Codes:
~
0 9
Frequency Range and No. of modes
[ ] Hand Calculations 5.
Method of Combining Dynamic Responses from Seismic and Other Dynamic Loads:
[
]AbsoluteSum
[ ] SRSS
[
]Other:
Tspeci fy) 6.
Damping:
OBE SSE Basis for the damping used:
7.
Support Considerations in the model:
8.
Critical Structural Elements:
Governing Load or Response Saismic Total Stress A.
Identification Location Combination Stress Stress Allowable B.
Maximum Critical Maximum Allowable Deflection Deflection Location to Assure Functional Operabilitu 9.
Failure Modes:
10.
Margins Available:
[ ] Input Spectrum
['
] Stress or Deflection e
a M
I e
9-14
~-
ENCLOSURE 9 EQUIPMENT QUALIFICATION BRANCH PUMP,AND VALVE OPERABILITY REVIEW TEAM REQUEST FOR ADDITIONAL INFORMATION In light of increased emphasis on mechanical equipment qualification, the Pump and Valve Operability Review Team (PVORT) has been formed to
~
review the pump and valve operability assurance program for those utilities applying for their operating license. The PTORT will review these programs by selecting various pumps and valves that are important to safety and then verifying that these components are qualified to perform their necessary functions when subjected to those loads associated with normal, upset, emergency, and faulted plant conditions. The findings of the team's review will then beI-included in a staff's safety evaluation report (SER).
' The basic criteria used by the PVORT to determine the acceptability of i
' *he applicant's pump and valve operability assurance program are stated in SRP 3.9.3.I Two other documents are also used for basic guidance:
SRP 3.10,2 and IEEE-627.3 Specific references are provided within the
(,.'
first two documents. All of these references, as well as good engineering judgement, will aid the PVORT in making recomendations concerning the adequacy of the applicant's pump and valve operability assurance program.
To aid the PVORT in this review, the staff requires that a " Pump and Valve Operability Assurance Review" form be prepared by the applicant for each selected component and submitted to the staff two weeks prior.to the team's plant-site visit. The applicant should also make available for review all pertinent documents and reports concerning the qualification of the selected components,.
Specifically, the documentation package for each of the selected components should include documents that will provide the type of information listed in SRP 3.10, page 3.10-9, a-1, as well as purchase specifications and plant test procedures, (applicable sections)'.'
l The PVORT is particularly interested in insuring that sequential testing l
and failure mode determination (aging) are' addressed; and that analyses are supported by test documents, whenever possible..Another topic of
(
discussion 'during the audit will be the applican't's maintenance /surveilance s
9-15
I program and how that program ia.tarfaces with the applicant's operability assurance program.
(
It should be noted that'it is beyond the charter of the PVORT to make assessments involving the applicant's overall seismic and environmental qualification programs even though seismic and environmental qualification are addressed and included in the pump and valve operability assurance program.
\\
REFERENCES.
I 1.
U.S. Nuclear Regulatory Comission Standard Review Plan, l
Section 3.9.3, NUREG-75/087.
1 2.
U.S. Nuclear Regulatory Comission Standard Review Plan, Section 3.10, l
NUREG-0800 (Formerly NUREG-75/087).
~ ~
i
(
IEEE Standard for Design Qualification of Safety Systems Equipment 3.
r used in Nuclear Power Generating Stations, IEEE Std. 627-1980.
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l 9-16
~ PUFF AND VALVE OPERABILITY ASSURANCE RTVIEW I.
PLANT INFORMATION 1.
Name:
Unit No.
2.
Docket No.:
3.-
Utility:
4 NSSS:
A/E:
6.
C.P. Docket Date:
C.P. SER Date:
s II. GENERAL COMPONENT
- INFORMATION
~'
l.
Supplier:
[]NSSS [] BOP 27 ' Lo' cat'iiin: ' ~~ a.~ Building / Room -
~
~
~
-s b.
Elevation c.
System 3.
Component I.D. No. on P&ID dwg:
g }',:
4..
If component is a [] P' ump complete II.5'.-
If component is a [] Valve complete II.6.
~
~
5.
General Pumo Data a.
~ Pump b.
Prime-mover Name Name Mfg.
Mfg.
Model Model S/N S/N Type Type l
The component, whether pump or valve, is considered to be an assembly
/,
composed of the body, internals, prime-mover (or actuator) and' functional accessories.
\\
l 9-17
a.
Pump,(continued) b.,- Prime-mover (contipued)
Overall Overal1 i
Dimensions Dimensions Weight Weight i
Mounting Mounting Met, hod Method Required B.H.P.
H.P.
Prime-mover requirements:
Component System System (include normal, maximum P arameters:
Design Normal Accident '
andmi,nimum).
Press
' Motor (voltage)-
Temp Flow Head Turbine (pressure)
Media
~
Required NPSH at maximum flow e
If MOTOA.1.ist:
Jf-~
W Available NPSH -
Duty cycle Operating Speed Stall current Critical Speed Class of insulation List functional accessories:*
Functional accessor.ies are those additional sub-components that are required to make the pump assembly operational, (e.g., coupling, lubricating oil system, speed control system, feedback, etc.)
Include manufacturer and model number.
i
'~
9-18 e
~ -
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l l
6.
General Valvo Data l
a.
Valve b.
Actuator (if not an integral l
unit) l.
I Name Name Mfg.
Mfg.
Model Model S/N S/N Type Type.
Size Size s.
Weight Weight Mounting Method Mounting.
Method Required Maximum Operating Delivered Torque Torque Power requirements:
f'.
Component System System
(~ '
Parameters:
Design-Normal Accident
.:.(include normal, maximum and minimum).
Press Electrical Temp Flow Media Pneumatic / Hydraulic
~
Max AP across valve
~
Closing time 9 max AP Opening time @ max AP List functional accessories:*
e 4
9-19 v
c_
m
III. FUNCTIOy 1.
Describe components normal and safety functions (include accident initiating signals, if applicable):
i.. -
Normal:
l l
Safety:-
l 2.
The components normal state is:
- [] Operating
-[]Sta,ndby 3.
Safety function:
f a.
[] Emergency raactor b.
-[]Containmentheat shutdown removal f.2ICA c.
[] Containment isolation
- d. - [] Reactor heat removal gf.s e.
[] Reactor core cooling f.
[] Prevent significant release of radio '
active material to environment g.
[] Does the component function to mitigate the consec'uences of one or more of the following events? []Yes []No If "Yes", identify.
[]LOCA
[]HELB
[]MSLB
[] Other Functional accessories are those additional sub-components that are reouired to make the valve assembly) operational, (e.g., limit switches, solenoid valves, accumulators, etc.
Include manufacturer and model number.
i s
9-20 e
i 4.
Safety requirements:
[]IntermittentOperation
[]Duringpostulatedevent t
i
^' '
[]ContinuousOperation
[] Following postulated event If component operation. is required following an event, give approximate length of time component must remain operational.
(e.g., hours, dcys, etc.)
4 5.
For VALVES:
i Does the component
[] Fail open.[] Fail closed
[] Fail as is Is this the fail safe position?
[] Yes
- []No Is the valve used for throttling purposes?
[]Yes
[]No What is the maximum acceptable internal and external leakrate?
IV. OUALIFICATION 1.
Reference by specific number the design codes,and standards used as a guide to, qualify the component:
(?),
2.
Have acceptance criterias been established and documented in the test plan (s) for the component?
[]Yes
[]No 3.
Are the margins
- identified in the qualification documentation?
[] Yes
[]No 4.
Was the component that was qualified a model or an actual assembly?
If a model, what was its scale?
If an actual assembly, was it qualifieo as an assemoiy or uy sub-assembliet?
(i.e., valve, actuator, pump, ariver)
- Margin is the difference between design basis parameters and the test parameters used for equipment qualification.
~
9-21 y
5.
List all component tests performed or to be performed that demonstrate qualification:
1 a
Il i
I, l
1 l
l i.
6.
List all component analyses performed that demonstrate cualification:
i:
f*.
\\
7.
As a result of any of the tests (or analysis), were any deviations from design requirements identified?
[].Yes
[]No If "Yes", briefly describe any changes made in tests (or analysis) or to the component to correct the deviation.
e 9-22
8.
Was the tested component precisely identical (as to model, size, etc.) to the in-plant component? []Yes
[]No If "No", is installed component [] oversized or [] undersized?
9.
Is component orientation sensitive?
[]Yes []No [] Unknown If "Yes", does installed orientation coincide with test / analysis orientation? []Yes []No
- 10. List all plant loading conditions considered during tests or analysis; (e.g., normal, upset, emergency, faulted).
l i
- 11. What is the fundamental frequency of the compdnent?
- 12. ' Does the component have a unique design or utilize unique material in its construction?
(Examples are special gaskets or packing, one of a kind components, limitations on nonferrous materials, special coatings or surfaces, etc.)
~
[]Yes [ ]No If "Yes" identify:
- 13. What is the design (qualified) life of the component, exclusive of normal maintenance items such as packing, bearings, seals, diaphragm, gaskets, and other elastomers?
- 14. Which of the components normal maintenance items requires the most frequent replactment/ repair?
What is the normal time interval between replacements / repairs?
- 15. List the harshest environmental conditions that the component could be exposed to during or following an accident, [e.g.,
temp., pressure, humidity, submergence, radiation (type and dose),etc.]:
's 9 23
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Attachment #4 to
' ENCLOSURE 9 Operability Qualification of Purge and Vent Valves Demonstration of operability of the containment purge and vent valves and the ability of these valves to close during a design basis accident is necessary to assure containment isolation. This demonstration of operability is required by Branch Technical Position (BTP). CSB 6-4 and S.R. P. 3.10 for containment purge and vent vf.ves which are not sealed closed during operational conditions 1, 2, 3 and 4
- 1. -For each purge and vent valve covered in the s: ope of this review, the following documentation demonstrating compliance with the
" Guidelines for Demonstration of O Valves" (attachid, Attachment #5) perability of Purge and Vent is to be submitted for staff review:
A.
Dynamic Torque Coefficient Test Reports (Butterfly valves only) - including a description of the test setup.
B.
Operability Demonstration or In-situ Test Reports (when used)
C.
Stress Reports D.
Seismic Reports for Valve Assembly (valve and operator) and associated parts.
E.
Sketch or desci'iption of each valve installation showing the following (Butterfly valves only):
1.
direction of flow i
2.
disc closure direction 3.
curved side of disc, upstream or downstream (asymetric discs) 4.
orientation and. distance of elbows, tees, bends, etc.
within.20 pipe diameters of valve 5.
shaft orientation 6.
distance between valves F.
Demonstration that the maximum combined torque developed by the valve is below the actuator rating.
2.
The applicant should respond to the " Specific Valve Type Questions" (attached) which relate to his valve.
9-25
3.
Analysis, if used, should be supported by tests which establish torque coefficients of the valve at various angles. As torque coefficients in butterfly valves are dependent on disc shape aspect ratio, angle of closure flow direction and approach flow, these things should be accurately represented during tests.
Specifically, piping installations (upstream and downstream of the valve) during the test should be repre-sentative of actual field installations.
For example, non-symetric approach flow from an elbow upstream of a valve can result in fluid dynamic torques of double the magnitude of those found for a valve with straight piping upstream and downstream.
4 In-situ tests, when performed on a representative valve, should be performed on a valve of each sinze/ type which is determined to represent the worst case load. Worst case flow direction, for example, should be considered.
For two valves in series where the second valve is a butterfly valve, the effect of non-symetric flow from the first valve should be considered if the valves are within 15 pipe diameters of each other.
5.
If the applicant takes credit for closure tire vs. the buildup of contain-ment pressure, he must demonstrate that the method is conservative with respect to the actual valve closure rate. Actual valve closure rate is to be determined under both loaded and unloaded cenditions and periodic inspection under tech. spec. requirements should be performed to assure closure rate does not increase with time or use.
i e
b l
9-26 e
,,,9
"' y MM
- ^
%. w ENCt.050RE 9 GUIDELINES FOR DEMONSTRATION OF OPERABILITY OF PURGE AND VENT VALVES OPERABILITY In order to establish operability it must be shown that the valve actuator's torque capability has sufficient margin to overcome or resist the torques and/or forces (i.e., fluid dynamic, bearing, seating, friction) that resist closure when stroking from the initial open position to full seated (bubble tight) in the time limit specified. This should be predicted on the pressure (s) established in the containment following a design basis LOCA.
Considerations which should be addressed in assuring valve design adequacy include:
'1.
Valve closure rate versus time - i.e., constant rate or other.
2.
Flow direction through valve; AP across valve.
3.
Single valve closure (inside containment or outside containment valve) or simultaneous closure. Establish worst case.
4.
Containment back pressure effect on closing torque margins of air operated l
valve which vent pilot air inside containment.
5.
Adequacy of accumulator (when used) sizing and initial charge for valve closure requirements.
6.
For valve operators using torque limiting devices - are the settings of the devices compatible with the torques required to operate the valve during the design basis condition.
7.
The effect of the piping system (turns, branches) upstream and downstream
- of all valve installations.
8.
The effect of butterfly valve disc and shaft orientation to the fluid '
mixture egressing from the centainment.
DEMONSTRATION f
~
Demonstration of the various aspects of operability of purge and vent valves may be by analysis, bench testing, insitu te'st'ng or a combination of these means.
Purge and vent valve structural elements (valve / actuator assembly) must be evaluated to have sufficient stress margins to withstand loads imposed while valve closes during a design basis accident. Torsional shear, shear, bending, tension and compression loads / stresses should be consi ered.
Seismic loading should be addressed.
Once valve closure and structural integrity are assured by analysis, testing or a suitable combination, a determination of the sealing integrity after closure and long term exposure to the containment environment sh uld be evaluated.
Emphasis should be directed at the effect of radiatien and of-
~
the containment spray chemical solutions on seal material.
Other aspects such as the effect on sealing from outside ambient temperatures and &bris should be considered.
9-27
~
.,,. 0 The following considerations apply when testing is chosen as a means for demonstrating valve operability:-
Bench testing can be used to demonstrate suitability of the in-service valve by reason of its traceability in design to a test valve. The following factors should be considered when qualifying valves through bench testing.
1.
Whether a valve was qualified by testing of an identical valve assembly or by extrapolation of data from a similarly designed valve.
2.
Whether measures were taken to assure that piping upstream and down-stream and valve orientation are simulated.
3.
Whether the following load and environmental factors were considered at Simulation of LOCA b.
Seismic loading c.
Temperature soak d.
Radiation exposure e.
Chemical exposure d.
Debris B.
Bench testing of installed valves to demonstrate the suitability of the specific valve to perform its required function during the postulated design basis accident is acceptable.
1.
The factors listed in items A.2 and A.3 should be considered when taking this approach.
In-Situ Testing In-situ testing of purge and vent valves may be performed to confirm the suitability of the valve under actual conditions. When performing such tests, the conditions (loading, environment) to which the valve (s) will be 5tbjected during the test should simulate the design basis accident.
NOTE:
Post test valve examination should be performed to estfalish structural integrity of the key valve / actuator components..
l 9-28
.m-,
,y
_s y
ENCLOSURE 10 u
('
m
(
UNITED STATES NUCLEAR REGULATORY COMMISSION o
s j
wasHWGTON. D. C. 20555 g.....,o February 25, 1981 TO ALL LICENSEES OF OPERATING NUCLEAR POWER REACTORS AND APPLICANTS FOR OPERATING LICENSES (EXCEPT FOR ST. LUCIE UNIT NOS.1 & 2)
SUBJECT:
EMERGENCY PROCEDURES AND TRAINING FOR STATION BLACKOUT EVENTS (Generic Letter 81-04)
' A recent decision by the Atomic Safety and Licensing Appeal Board (ALAB-603) concluded that station blackout (i.e., loss of all offsite and onsite AC power) should be considered a design basis event for St. Lucie Unit No. 2.
An amendment to the Construction Permit for St. Lucie Unit No. 2 was subsequently.
issued on September 18,1980. The NRC staff is currently assessin blackout events on a generic basis,(Unresolved Safety Issue A-44).g station The results of this study, which is scheduled to be completed in 1982, will identify the extent to which design provirions should.be included to reduce the potential.
for or consequences of a station blackout event.
However, the Board has recommended that more immediate measures be taken to ensure that station blackout events can be acconnodated while task A-44 is being conducted. Although we believe that, qualitatively, there appears to be sufficient time available f6TTowing a station blackout event to restore AC power, we are not sure if licensees have adequately prepared their operators to act during a station blackout event.
Consequently, we request that you review your current plant operations to determine your capability to mitigate a station blackout event and promptly impleme'nt, as necessary, emergency procedures and a training program for station blackout events. Your review of procedures and training should consider, but not be limited to:
The actions necessary and equipment available to maintain the reactor a.
coolant inventory and heat removal with only DC power available, including
. consideration of the unavailability of auxiliary systems such as ventilation and component cooling.
b.
The estimated time available to restore AC power and its basis.
The actions for restoring offsite AC power in the event of a loss. of c.
the grid.
d.
The actioris for restoring offsite AC power when its loss is due to postulated onsite equipment failures.
10-1
L:
c w,
(
~
(
/
The actions The actions necessary to restore emergency onsite AC power.
required to restart diesel generators should include consideration of e.
loading sequence and the unavailability of AC power.
Consideration of the availability of emergency lighting, and any actions f.
required to provide such lighting, in equipment areas where operator or maintenance actions may be necessary.
Precautions to prevent equipment damage during the return to normal For example,
g.
operating conditions following restoration of AC power.
the limitations and operating sequence requirements which must be followed to restart the reactor coolant pumps following an extended loss of seal injection water should be considered in the recovery procedures.
The annual requalification training progra.n should consider the emergency procedures and include simulator exercises involving the postulated loss of all AC power with decay heat removal being accomplished by natural circulation and the steam-driven auxifiary feedwater system for PWR plants, and by the steam-driven RCIC and/or HPCI and the. safety-relief valves in BWR plants.
We conclude that the actions described above'should be completed as soon as In addition, so that we may they reasonably can be (i.e., within 6 months).
determine whether your license should be amended to incorporate this require-ment, you are requested, punuant ti frSO.54(f), to furnish within ninty (90) days of receipt of this letter, an assessment of your existing or planned facility procedures' and training programs with respect to the matters In the event Please refer to this letter in your response.
described above.
that completion within 6 months can not be. met, please propose a revised date and justification for the delay.
This request for information was approved by GAO under a blanket clearance number R0072 which expires November 30,1983. Coments on burden.and duplication may be directed to the U.S. General Accounting Office, Regulatory Reports Review, Room 5105, 441 G Street, W., Washington, D.C.
20548.
Sincerely.
LD1) t
'Darre G.1 Eisenhut, Director Division oi' Licensing Office of Nuclear Reactor Regulation l
10-2
ENCLOSURE 11 -
h; INITIAL TEST PROGRAM REVIEWS e
i COMMON REVIEW PROBLEMS OF FSAR CHAPTER 14 I
1 Changes to your test program or test procedures resulting from our review could impact your license schedule if the changes require that you (1) increase your staffing for the initial test program, (2) modify and rerun preoperational test procedures which may have already been completed, or (3) modify startup test procedures.
This is because increases in staffing normally require some lead time, preoperational test procedures must be written, approved, and made available, to NRC 60 days prior to fuel loading, and startdp test procedures must be written, approved, and made available to NRC 60 days prior to fuel loading.
Based upon recent reviews of the initial test program for OL applications, we celieve that our review time can ce significantly reduced if, at the start of our review, your FSAR addresses and accounts for staff information requests on previous applications.
All of our recent reviews have contained numerous requests and positions identical or similar to those which had to{owingpagese resolved dyring previous reviews. These positions are listed on the foi
~1 We request.that you consider..these_posjtions.
Incorporating the resolution of these items into your FSAR prior to our review will reduce.NRC review. time and should ensure that the revie.w of your _ initial test program desceiption will rot impact your schedule for fuel load or startup.
i An area of particular concern is that of acceptance criteria in Chapter 14.2.12 test cescriptions.
Regulatory Guide 1.70 paragraph 14.2.12 states that test descriptions should include a " summary description of... acceptance criteria".
This item can be satisfied by providing a list of acceptance criteria parameters and cne " source" or " basis" of acceptance ranges, rather. than actual acceptance criterii valJes.
In other words, the t2st description snould reference the cccunencs whicn :ne test procedure preparer will use (e.g., vendor test specifications, topical recorts, accident analyses, FSAR design bases, etc.).
This information will enable (1) cur reviewers to verify that test objectives will be met and (2) our inspectors, when reviewing test procedures, to verify correct acceptance criteria be tracing them back to the source.
O s
a j
11-1 l
INITIAL TEST PROGRAM FSAR CHAPTER 14 STAFF POSITIONS
- 1. To comply with Regulatory Guide 1.70 paragraph 14.2.12, test descriptions should be included in FSAR Section 14.2.12 fo r all systems, structures, and equipment to be tested. Regulatory Guide 1.68 provides guidance for the selection of tests to be conducted as part of the initial test program. Your Chapte'r 14 should contain test descriptions for all systems, structures, and equipment for which, (1) design, construction, and functional capability requirements are included in the FSAR and (2) are included in the criteria of Regulatory Guide 1.68, Position C.l.
Where test descriptions are included elsewhere in the FSAR (ie, containment leakage testing-Sect. 6.2.6, reactor internals vibration testing-Sect 3.9.2, etc.) information need not be repeated in Chapter 14. However, a cross-reference should be provided.
Inclusion of a test description in Chapter 14 does not necessarily imply that the test becomes subject to FSAR Chapter 17 Quality Assurance Program controls. Certain tests to be performed prior to fuel loading to verify system operability may be referred to as " acceptance tests" to distinguish them from "preoperational" tests subject to FSAR Chapter 17 Test Control.
2.
In accordance with staf f positions on TMI Task Action Plan items I.G.1 and II.E.1.1 respectively, the RCIC and AFW systems should be tested for capability to start and operate for two hours under simulated loss of all AC power conditions.
i 3.
In accordance with Branch Technical Position PSB-1 item 4, preoperational test data of certain Class IE electrical systems should be evaluated to' assure capability to supply, start and operate required loads under degraded voltage conditions.
4.
To comply with Regulato ry Guide 1.68 Append ix A. l.c, response time testing of RPS and ESF instrumentation systems should account for process-to-sensor delay (See ISA-dS67.06 for guidance).
- 5. The Loss of Of fsite Power with Loss of Turbine-Generator Test (Reg. Guide 1.68 Appe'ndix A.S.jj) should be initiated from a power level sufficient to permit initial use of automatic process control systems. The t?ct should be maintained long enough for plant systems to stabilite (ie.,>30 min.) following loss of power.
- 6. In accordance wi,th Regulatory Guide 1.41 integrated ESF systems preoperational testing should be conducted, verifying that each power source is capable of shedding, sequencing, and operating its divisional loads. Testing should verify divisional separation and independence.
a G
11-2
i
- 7. In accordance with* Regulatory Guide 1.68, Appendix A.5.t, the open and reclosure setpoints, capacities, response times, and operability for all pressurizer relief valves and safety valves, atmospheric dump valves, main steamline relief valves, intercept valves, turbine bypass valves and stop valves should be tested.
- 8. To comply with the test description requirements of Regulatory Guide 1.70 para 14.2.12, tests descriptions should include thorough descriptions of test methods. For dynamic response tests (Regulatory Guide 1.68 Appendix A.5.hh through A.5.nn) this includes initial plant conditions, how the tests are to be initiated, and expected plant responses (e.g.,whether o r not relief valve, turbine trip, reactor scram, or S/G safety valve lift is expected). For tests not to be conducted at the power level indicated in Regulatory Guide 1.68 or at the power level customarily prescribed by the applicable NSSS vendor and previously accepted by NRC, provide justification for using a d if f erent powe r level. Note: for BWR's substitute " power / flow test condition" for " power level".
- 9. To comply with the acceptance criteria requirements of
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Regulatory G,uide 1.70 para 14.2.12, test descriptions should provide specific acceptance criteria or a discussion of the source for the acceptance criteria to be used when test procedures are prepared. The test description should provide
" traceability" to acceptance criteria sources such as other FSAR sections, technical specifications, topical reports, vendor-furnished test specifications, and accident analyses.
- 10. Tests that do not apply to 10CFR50 Appendix A " General Design Criteria" items or functions and are not subject to FSAR Chapter 17 Test control should be identified so that they may be excepted from our standard license condition which requires prior NRC notification of major test changes during initial startup.
- 11. Provide descriptions of communications systems preoperational tests. See requirements of 10CFR50 App E.IV.E, IE Bulletin No. 80-15, Generic Letter 82-33, and Branch Technic &1 Position BTP CMES 9.5-1 Position C.5,g. (4 ).
- 12. To comply with Regulatory Guide 1.68.2, Position C.3, the remote shutdown test should include a separate or integral demonstration that the reactor can be scrammed from outside the control room.
- 13. Auxiliary Feedwater Systems preoperational test descriptions should include a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> endurance test as stated in Standard Review Plan Section 10.4.9.
- 14. NUREG-0694, "TMI Related Requirements for New Operating
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Licenses," Item I.G.I, requires applicants to perform "a special low power testing program approved by NRC to be conducted at r
power levels not greater than 5% for the purposes of providing meaningful technical information beyond that obtained in the 1
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normal startup test program and to provide supplemental training."
To comply with this requirement PWRs perform natufa'i circulation tests to fulfill the following objectives:
Testing--The tests should demonstrate the following plant characteristics:
Length of time required to stabilize natural circulation, core flow distribution, ability to establish and maintain natural circulation with or without onsite and offsite power, the ability to uniformly borate and cool down to hot shutdown conditions using natural circulation, and subcooling monitor pe rfo rmanc e.
Training--Each licensed reactor operator (RO or SRO who performs RO or SRO duties) should participate in the initiation, maintenance, and recovery from natural circulation mode.
Operators should be able to recognize when natural circulation has been stabilized and should be able to control saturation margin, RCS pressure, and heat removal rate without exceeding specified operating limits.
If these tests have been performed at a comparable prototype plant, they need.be repeated only to the extent necessary to accomplish the above training objectives. To the extent practicable, the above testing and training may be accomplished in conjunction with normal startup tests such as the loss-of-flow-test and the combined loss-of-offsite-power with loss-of-turbine-generator test. Plants having plant-specific simulators should utilize test data as feedback for simulator verification / update.
SWR license applicants snould comply with the recoxicndations of the Blin Owners Group (letter from P. B. Waters to D. G. Cisenhut dated February 4, 1981).
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