ML20031E491
| ML20031E491 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/30/1981 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Tallman W PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| NUDOCS 8110150623 | |
| Download: ML20031E491 (75) | |
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$EP 3 01981 Docket Nos.: 50-443 and 50-444 lir. Willian C. Tallnan Chaiman and Chiet 2xecutive Officer Public Service Company of New llampshire 100 Elm Street ilanchester, tjew ilampshire 03105
Dear !!r. Tallman:
Subject:
Acceptance Review of Application for Operating Licenses for Seabrook Station, Units 1 and 2 On July 21, 1981, you tendered your application for operating licenses for SeabrooK Station, Units 1 and 2.
Your application included General and Financial Information, an Environ:r. ental Report - Operating License Stage (ER-OL), and a Final Safety Analysis Report (FSAR).
(The latter two documents preceded the basic application, having been torwarded on Junt 29, 1961.)
We have coupleted our review of the General and Financial Infomation, ER-OL, dnd FSM and have concluded that the infomation filed taken as a whole is sufficiently complete for docketing your application and for initiation of the safety and environmental reviews. SuDstantive deficiencies may exist in some sections that need to be corrected during the review.
Your filing of the application should incluoe three (3) originals signed under oath or af firmation by a duly authorized officer of your organization.
In adaition, your filing should include fif teen (15) copies of the General and Financial Infomation, forty-one (41) copies of the ER-OL, and fortn (40) copies of tne FSM. As required by section 50.30 and section 50.21, 10 LFR Parts 50 and 51 respectively, you should retain an additional ten (10) copies of the General and Financial Information, one hundred nine (109) copies of the ER-OL, and thirty (30) copies of the FSAR for direct distribution in accordance
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with Enclosure 1 of tnis letter and further instructions which may be provided E
later. Within 10 days af ter filing, you raust provide an affidavit tnat distri-nf o
bution has been node in accordance with tnis enclosure. All subsequent amend-En ments to the ER-OL and FSAR will require forty-one (41) and sixty (60) copics O
n respectively, for distribution.
mh Un October 2d,1960, tne Conaission approved a "Claritication of Tlil action
,4 Plan Requirements," now contained in 11UREG-0737, which supercedes previous o
tantGs on the subject.
It is noted that the Seabrook FSAP auaresses the U$
requirements contained in tiUREG-0737.
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4 SEP 3 01981 Your application indicated that your earliest projected fuel load date is
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Hoveaber 1933.
On this basis, the key nilestones in the FSAR and ER-OL review j
have been established as follows:
Issuance of Safety Evalution Report (SER)
- Septeaber 1902
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Issuance of the Supplenent to the Safety i
Evaluation Report (SSER)
- October 1982 i;
Issuance of Oraft Envirotriental Statement (DES )
- May 1982 Issuance of Final Environ ental Statenent I
( FES )
- October 1992
'Je request that you keep us inforned of any significant changes to your construc-tion schedule for proper project and scheduling actions. tle shall follow a revised review procedure whereby only a single set of questions will be trans-
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nitted to you for responses.
After your responses have been reviewed, a draft SER will be prepared and will be the subject of a series of meetin]s l
designed to close out open f tons.
l During the course of our prelininary review of your FSAR and ER-OL, the en-l closed " Request for Additional Infornation" (Enclosures 2 and 3 respectively)
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were generated.
In addition to Enclosures 2 and 3, other additional infonna-tion is needed to expedite our review. Enclosure 4 contains this request for additional infor1ation. In nost cases, Public Services Conoany of !!ew Haapshire was previously infonaed of this additional infor"tation in the form of generic letters, requests for additional inforaation and/or I&E Bulletins. As part of our review of the application against the Comission's regulations we re-quest that you verify Seabrook neets the applicable requirements in 10 CFR 20, 50 and 100.
Your responses to these requests should be completed as soon as possibl e.
Your letter of transmittal for docketing of the application should include a comitment by Public Service Company of t!ew Hampshire to provide the requested information within sixty days.
If the responses are not received within this period of tina it may become necessary to revise the review schedule.
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l If, during the review, you believe there is a need to appeal a staff position, l
your appeal should be brought to my attention as early as possible so that the 1
l aporopriate neetings can be arranged. This procedure is an infornal one i
designed to allow the opportunity for applicants to discuss with nanagement l
areas of disagree'3ent in the Case review. Briefly, each side of the issue in question is to develon the position it intends to take and forward the position statement to the Division of Licensing. Fro 1 these positions, an agenda will be developed containing appropriate discussion itels and will be distributed prior to any aeetina. There are nrovisions for two stages of actual appeals ncetings.
The first stage involves URR nanagenent at the Assistant Director Level.
If the natter is not resolved at the Assistant Director level, the I
second stage meeting is held with the appropriate Division Directors in attendance..
Your representatives should be of conparable nanagement level to those expected
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to attend from IRC.
If a satisfactory solution has not been developed by the end of the second stage meeting, an appeal to the Director of MR may be submitted. As with other applicant / staff meetings, a suurnary report will be prepared and distributed per the current service list, including forwarding a copy to the Public Document Room.
The Project Manager assigned to the review of your application is Mr. Louis L. Wheeler, tir. Wheeler's telephone number is (301) 492-7792.
Sincerely, trJginni signed by
$WrreliG. EN#
Darrell G. Eisenhut, Director Division of Licensing Office of t!uclear Reactor Regulation cc: See next page.
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DATEf NRC FORM 318110 801 N R C M O240 OFFICIAL RECOFiD COPY
' " " '9esa29 824
SEABROOK William C. Tallman Chairman and Chief Executive Officer Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105 John A. Ritscher, Esq.
E. Tupper Kinder, Esq.
Ropes and Gray Assistant Attorney General 225 Franklin Street Office of Attorney General Boston, Massachusetts 02110 208 State House Annex Concord, New Hampshire. 03301 Mr. Bruce b. Beckley, Project Manager Public Service Company of New Hampshire Mr. Arnie Wight 1000 Elm Street New Hampshire House of Representatives Manchester, New Han ; hire 03105 Science, Technology and Energy Committee State House Concord, New Hampshire 03301 Resident Inspector Seabrook Nuclear Power Station c/o U. S. Nuclear Regulatory Commission Ms. Elizabeth H. Weinhold P. O. Box il49 3 Godfrey Avenue Seabrook, New Hampshire 03874 Hampton, New Hampshire 03842 Mr. John DeVincentis, Project Manager Robert A. Backus,' Esq.
Yankee Atomic Electric Company O'Neill, Backus and Spielman 1671 Worcester Road 116 Lowell Street Farmingham, Massachusetts 01701 Mar.chester, New Hampshire 03105 Mr. Cole, Project Manager Norman Ross, Esq.
United Engineers and Constructcrs 30 Francis Street 30 South 17th Street Brookline, Massacht atts 02146 Post Office Box 8223 Philadelphia, Pennsylvania 19101 Karin P. Sheldon, Esq.
Sheldon, Harmon & Weiss Mr. W. Wright, Project Manager 1725 I Street, N. W.
Westinghouse Electric Corporation Washington, D. C.
20006 Post Office Box 355 Pittsburg, Pennsylvania 15230 Laurie Burt, Esq.
Office of the Assistant Attorney General Environmental Protection Division One Ashburton Place Boston, Massachusetts 02108 i
fl. Pierre G. Cameron, J r., Esq.
General Counsel Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105
DISTR 1BUTION LIST ENVIRONMENTAL REPORT ADVISORY COUNCIL ON HISTORIC PRESERVATION ENVIRONMENTAL PROTECTION:\\ AGENCY Mr. Peter H. Smith (1)*
EPA Regional Office Advisory Council on Historic Preservation 1522 K Street, NW - Suite 536 Regional Radiation Representative (2)
Washington, D.C.
20005 Environmental Protection Agency Region I cc w/o encl:
JFK Federal Building Boston, Massachusetts 02203 Mr. George Gilman, Commissioner Department of Resources and Economic Develo pment HEALTH AND HUMAN SERVICES Post Office Box 856 Concord, New Hampshire 03301 Mr. Charles Custard (2)
U.S. Department of Health & Human Services Room 537F Humphrey Building ARMY ENGINEERING DISTRICT 200 Independence Avenue, SW Washington, D.C.
20201 U.S. Army Engineering Division New England (1) 424 Trapelo Road HOUSING AND URBAN DEVELOPMENT Waltham, Massachusetts 02154 Mr. Richard H. Broun, Director (2)
Office of Environmental Quality COMMERCE U.S. Department of Housing & Urban Develo pment Mr. Bruce Barrett (6)
Room 7276 HUD Building U.S. Department of Commerce 451 Seventh Street, SW Room 3425 Commerce Building Washington, D.C.
20410 Washington, D.C.
20230 Mr. Robert Ochinero, Director (1)
HUD Region National Oceanographic Data Center Environmental Data Service - D7 - Rm. 428 Mr. Edward Thomas Martin (2) 2001 Wisconsin Avenue, NW., Page Bldg. #1 800 JFK Federal Building Washington, D.C.
20235 Boston, Massachusetts 02203 ENERGY INTERI00 Federal Energy Regulatory Commission Mr. Bruce Blanchard, Director (18)
Office of Environmental Project Review Dr. Jack M. Heinemann (1)
U.S. Department of the Interior Federal Energy Re591atory Commission Room 4256 Room 3347 18th and C Street, NJ 825 North Capitol Street, NE Washington, D.C.
20240 Washington, D.C.
20460 Numbers in parenthesis indicate number of copies.
1-1
RIVER BASIN COMMISSION STATE OFFICIALS Honorable John R. Ehrenfeld (1)
State House Annex (1)
Chairman, New England River ATTN: Assistant to the Director Basins Commission Office of. Comprehensive Planning 141 Milk Street, 3rd Floor Concord, New Hampshire 03301 Boston, Massachusetts 02109 Mr. Timothy W. Hayward, Vice Chairman (1)
New England River Basins Commission New England Regional Cunmission 53 State Street Boston, Massachusetts 02109 0FFICIALS OF ADJOINING STATES TRANSPORTATION Energy Facilities Siting Council (1) 14th Floor Mr. Joseph Canny (1)
One Ashburton Place Office of the Assistant Secretary Boston, Massachusetts 02108 for Policy & International Affairs U.S. Department of Transportation 400 7th Street, SW - Room 9422 Washington, D.C.
20590 Capt. Wm. R. Riedel (1)
LOCAL OFFICIAL Water Resources Coordinator W/S 73 U.S.C.G. - Room 1112 Office of the First Selectman (1)
U.S. Departnent of Transportation Town of Seabrook 2100 Second Street, SW Seabrook, New Hampshire 03874 Washington, D.C.
20590 Mr. Lee Santman, Director (1)
CLEARINGHOUSES ATTN:
Mr. Joe Nalevanko Materials Transportation Bureau State Clearinghouse 2100 Sccond Street, SW Washington, D.C.
20590 Coordinator of Federal Funds (10)
Room 124 State House DOT REGIONAL OFFICE Concord, New Hampshire 03301 Mr. David W. Hays (1)
Secretarial Representative Regional / Metropolitan U.S. Department of Transportation Transportation Systems Center Strafford Rockingham Regional (1) 55 Broadway Council Cambridge, Massachusetts 02142 1 Water Street Exeter, New Hampshire 03833 1-2
,0THERS 1 Librarian
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Thermal Reactors Safety Group Brookhaven National Laboratory Building 1,30 Upton, Long Island, New York 11973 Ms. Liz Hannon
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Atomic Industrial Forum 101616th Street, N.W. - Suite 850 Washington, D.C.
20036 I
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DISTRIBUTION LIST GENERAL AND FINANCIAL INFOEMATIC';, FINAL SAFETY ANALYSIS REPORT AND AMBEMENIS STATE ORFICIAIS D:VIRC2T!TAL PROTECT 10!! AGENCY REGIG AL OFFICE (FSAR& Amendments)
State House Annex ATH!: Assistant to the Director Regional Radiation Representative Office of Comprehensive Planning U.S. Envirarmental Protection Agency Concord, New Hampshire 03301 Region I JFK Federal Building Energy Facilities Siting Council Boston, Massachusetts 02203 14th Floor One Ashburton Place Boston, Massachusetts 02108 NATIONAL 1ABORATORIES (FSAR & Amendments)
LOCAL OFFICIAL Mr. I. Charak, Manager
- NRC Assistance Project Office of the First Selectman Argonne National Laboratory Town of Seabrook 9700 South Cass Avenue Seabrook, New Hampshire 03874 Argonne, Illinois 60439 Mr. R. E. Iyon Reliability and Statistics Division E G & G, Idaho P. O. Box 1625 Idaho Falls, Idaho 83401 l
- Including Electrical Drawings.
1-4
100.0 DIVISION OF LICENSING 100.1 10 CFR 50.33(d)(3)(iii) requires each applicant to state (General Information)
"whether it is owned, controlled, or dominated by an alien, a foreign corporation, or foreign government, and if so, give details." Neither Public Service nor Taunton address this requirement.
100.2 Identify the FSAR section where details of conformance to each applicable TMI Action Item (NUREG-0737) can be found.
100.3 Provide a date when Appendix 3B will be available for review.
100.4 Provide an evaluation which demonstrates that Seabrook 1 and 2 comply with each of the regulations contained in Title 10, Code of Federal Regulations, Parts 20, 50, and 100.
Any areas of non-compliance with these regulations should be identified and justified.
2-1
210.u MECHAfilCAL EliGiliEERING BRAfiCH 210.1 Per Regulatory Guide 1.70, provide a table or otherwise clearly (3.2.1) identify all structures, systems and components which are designed for an operating basis earthquake.
210.2 Per Regulatory Guide 1.70, provide or reference the res~ults of the (3.9(B).3.4, analysis or test programs.
3.9 ( N).3.4 )
'c2u.o STP.UCTUP.AL EliGIfiEEPING BRANCH 220.1 Per Regulatory Guide 1.70, indicate your extent of compliance with (3.7.2, 3.7.3)
220.2 Per Regulatory Guide 1.70, provide the bases for establishing values (3.7.4.3) f or activating reaoout of seismic -instrumentation.
22 0. ;'
Per Regulatory Guide 1.70, provice tne specific edition, date or (3.8.1.2, addenda for each referenced document.
3.8.2.2, 3.8.3.2)
'220.4 Per Regulatory Guide 1.70, adoress tne extent of compliance with (3.8.1.4)
Article CC-3000 of the ASME Code Section II..
220.5 Per Regulatory Guide 1.70, adoress the extent of ccmpliance with (3.8.3.3, Standard ACl-349.
3.8.3.4, 3.8.4.4) 2-2
230.0 GEOSCIENCES BRANDi The following material properties should be determined for each 230.1 (2.5.2.5) stratum under the site: seismic compressional and shear velocities, bulk densities, soil properties and classification, shear modulus and its variation with strain level, and water table elevation and its variation.
230.2 The dominant frequency associated with the peak acceleration for (2.5.2.6) the SSE should be determined either from analysis or ground motion time histories or by inference from descriptions of earthquake phenomenology, damage reports, and regional chara'cteristics of seismic wave transmission.
230.3 The probability of exceeding the OBE during the operating life of (2.5.2.7) the plant should be discussed.
240.0 HYDROLOGIC AND GE0 TECHNICAL ENGINEERING BRAtlCH 240.1 -
SEE ENCLOSURE 3 240.28 240.29 Per Regulatory Guide 1.70, Revision 3, provide a regional map which (2.4.1.2) adequately shows the major hydrologic features.
240.30 in Section 2.4.5.3 maximum wave heights are quoted.
Specification (2.4.5.3) should be made as to whether these " maximum" values correspond to 99 percentile values from the derived distribution.
Signifi-cant (33-1/3%) wave heights should be provided.
2-3
251.0 Material Engineering Branch - Component Integrity Section FSAR Section 5.3 251.1 To demonstrate compliance with paragraph III.A.4 of Appendix G, 10 CFR Part 50, provide data on the qualifications of the personnel performing the fracture tougnness tests.
251.2 Provide CVN impact test data and energy absorbed vs temperature and mils lateral expansion vs temperature curves for the reactor beltline materials over the range of temperatures tested.
251.3 Provide the following pressure-temperature curves for the reactor beltline materials:
a.
Preservice hydrostatic tests b.
Inservice leak and hydrostatic tests c.
Heatup and cooldown operations d.
Core operation The pressure-tengerature curves must include those for start-up and those for end-of-life.
251.4 Provide the following data on the surveillance capsule materials:
1 Identify the base material, weld metal, and heat affected zone a.
material in the surveillance capsule by heat number and code I
2-4 1
number.
Indicate the RTNDT. Upper shelf and chemical composi-tion (Cu and P) for each material.
b.
Identify the lead factor and location for each surveillance capsule.
c.
Identify the capsule withdrawal schedule.
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252.0 MATERI ALS ENGliiEERING BRANCH 252.1 Describe the service history of vessels constructed using the fab-
-(5.3.3.3) rication methods specified in Section 5.3.3.3 and the vessel supplier's experience with the procedures.
252.2 Either provide the analysis of the Model F steam generator tube (5.4.2.3) wall thinning under accident conditions as per Regulatory Guide, 1.70, Revision 3, or provide a schedule for submittal of this information.
252.3 Either provide a discussion on nonmetallic thermai insulation, (6.1(B).l.1) if used, or provide a schedule for submittal of this information.
Z/U.0 ENVIRONMENTAL QUAllFICATION BRANCH 270.1 Per Regulatory Guide 1.70, discuss the extent of compliance with (3.11(B).2)
270.2 Per Regulatory Guide 1.70, discuss the extent of compliance with (3.ll(N).2)
Regulatory Guides 1.30 and 1.63.
270.3 Per recent NRC requirements, provide a discussion of Regulatory (3.11)
Guide 1.97, Revision 2, including NUREG 0588 and NRC Memorandum and Order CLI-80-21.
2-6
280.0 CHEMICAL ENGINEERING BRANCH 280.1 Describe the extent of conformance to the requirements of Appendix R (9.5.1) to 10 CFR 50 and justify any deviations from these requirements.
See for more detailed guidance.
280.2 Provide a list of any unusually hazardous materials to be used on
( 9. 5.1.1 )
site that could present unexpected fire hazards or complicate fire-fighting activities as identified in Regulatory Guide 1.70, Revision 3.
l 280.3 Provide or reference a discussion of the information in Items 4, 8.
(9.5.1.2) 9 and 10 of Section 9.5.1.2 of Regulatory Guide 1.70, Revision 3.
310.0 SITING ANALYSIS BRANCH 310.1 thru See Enclosure 3 i
310.5 31 0.6 Per Regulatory Guide 1.70, Revision 3, the description of nearby (2.2.2) facilities should include the number of persons employed by each.
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410.0 AUXILIARY SYSTEMS BRANCH 410.1 Insdfficient information for complete evaluation;need high and moderate (3.6) energy piping layout drawings and isometrics and discussions to show how safety related areas are protected fran pipe / failures, including environmental effects.
410.2 Emeroency Feedwater System (6.8)
(1)
- Statement that discharge header is neither high or moderate energy
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is incorrect since, in accordance with Fig. 6.8-1, the header is normally pressurized (isolation valves are shown as normally open).
This makes it a high energy system.
(2) Valves FV 4214, 4224, 4234, 4244 do not appear to meet containment isolation requirements since they are used for flow. throttling.
(3) Need additional information to demonstrate power diversity, i.e.,
will valv'es assume proper position on less oflall AC power (including EFW).
410.3 Fuel Handlino (9.1.4)
Need drawings and additional information to demonstrate that no damage to spent fuel or. safety related equipment can result from a spent fuel cask drop.
410.'
Ultimate Heat Sink (9.2.5)
The FSAR should include the results of an analysis that demonstrates that the ultimate heat sink has the capability to dissipate the maximum heat load, including the residual decay heat energy as calculated by using BTP ASB 9-2, beat output of equipment required for safe shutdown (e.g., diesel generators, pumps), and all other heat loads.
410.5 Per Reculatory Guide 1.70, address the effects of gravitational and (3.5.1.2) second ary missiles.
410.6 Provide or reference a discussion of the details of the means for (9.4.2.1) protection of system vents or louvers from missiles.
! 410.7 Provide or reference the analysis that demonstrates the capability of (6.8.3) the emergency feedwater systen to preclude hydraulic instabilities (characterized as water hammer) from occurring for all modes of l
operation as per Section 10.4.9.3 of Regulatory Guide 1.70, Revision 3.
2-8
420.0 INSTRUMENTATION AND CONTROL SYSTEMS BRANCH 420.1 As per Regulatory Guide 1.70, Revision 3, provide the design basis (7.4.1) information required by Section 3 of IEEE Standard 279-1971.
420.2 Provide the information identified as "later" in Table 7.5-1 or (7.5) provide a schedule for submittal of this information.
420.3 Describe the extent of conformance to Regulatory Guide 1.79, Revision (7.5.3.1) 2, including NUREG 0588 and Commission Memorandum and Order CLI-80-21, and justify any deviations from these requirements.
420.4 As per Regulatory Guide 1.70, Revision 3, the following information (7.7.1) should be provided with regard to the control systems not required for safety:
1.
Identification of the major plant control systems (e.g., primary temperature control, primary water level control, steam generator water level control) that are identical to those in a nuclear power plant of similar design by the same nuclear steam system supplier -
that has recently received a construction permit or an operating license; and 2.
A list and discussion of the design differences in those systems not identical to those used in the reference nuclear power plant.
This discussion should include an evaluation of the safety signifi-cance of each design difference.
430.0 POWER SYSTEMS BRANCH 430.1 Either provide the information identified as "later" in Tables 8.3-1 (8.3.1.1) and 8.3-2 or provide a schedule for submittal of this information.
t 2-9
440.0 REACTOR SYSTEMS BRANCH 440.1 Per Regulatory Guide 1.70, for the specific safety-related items
( 3.5.1. 2) identified in Tables 3.2-1 and 3.2-2 provide the following information:
l'.
Reference drawing or piping and instrument diagram, where application, 2.
Identification of the missiles to be protected against, their source and the basis for selection, 3.
Missile protection provided.
440.2 Specify the available and required net positive suction head for (5.4.7.2) the RHR pumps.
440.3 Discuss material compatibility and chemical effects as per (6.3.2.4)
Regulatory Guide 1.70, Revision 3.
450.0 ACCIDENT EVALUATION BRANCH 450.1 As per Regulatory Guide 1.70, Revision 3, provide a description of the charcoal filter train, including design specifications, flov parameters, and charcoal type, weight, and distribution;HEPA filter type and specifications; and specifications of any additional components.
The degree to which the recommendations of Regulatory Guide 1.52, " Design, Testing, and Maintenance Criteria for Postaccident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants,"
are followed should be indicated and claimed filter efficiencies listed.
Portions of this information that appear elsewhere in the FSAR may be referenced by section number.
450.2 Provide supporting documentation, in the form of appendices to ER-OL Chapter 7, that shows the derivations of the Class 9 accident probabilities listed in Section 7.3.
In addition to these derivations, provide any other information that may be pertinent to verifying the Class 9 accident probabilities.
2-10
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451.1 See enclosure 3 451.8 c
451.9 Per Regulatory Guide 1.70, Revision 3, provide data on the dura-(2.3.2.1) tion of periods of fog.
460.0 EFFLbENT TREATMENT SYSTEMS BRANCH 460.1 Provide information or a schedule when the information will be available (11.4) for the solid waste management system as required by Section 11.4 of Regulatory Guide 1.70, Revision 3.
470.0 RADIOLOGICAL ASSESSMENT BRANCH 470.1-470.5 See enclosure 3 470.6 Provide or reference a discussion of the radiation instrumentation (12.3.4) that will be used to meet the criticality accident monitoring require-ments of Section 70.24 of 10 CFR Part 70 for the storage area for new fuel.
470.7 Indicate whether, and if so how, the guidance provided by Regulatory (12.3.4)
Guides 8.12 and 1.97, Revision 2, and ANSI N13.1-1969 has been followed; if not followed, describe the specific alternative methods used.
470.8 Indicate whether, and if so how, the guidance provided by Regulatory (12.5.2)
Guides 8.3, 8.4, 8.8, 8.9. 8.12, 8.14, and 1.97, Revision 2, has been followed; if not followed, describe the specific alternative methods used.
2-11
480.0 CONTAINMENT SYSTEMS BRANCH 480.1 Either provide the information identified as "later" in Table 6.2-83 (6.2.3.2) or provide a schedule for submittal cf this information.
480.2 Either provide the information for Section 6.2.6.5 as per Regulatory (6.2.6.5)
Guide 1.70, Revision 3, or provide a schedule for submittal of this inf ormation.
480.3 (6.2.1.4)
Discuss energy inventories and additional information required for confirmatory analyses as per Regulatory Guide 1.70, Revision 3, Section 6.2.1.4.
480.4 Show that the containment volume used in the analysis has been maxi-(6.2.1.5) mized to ensure a conservative prediction of the minimum containment pressure and discuss uncertainties in determining this volume.
492.0 CORE PERFORMANCE BRANCH 452.1 Per the requirements of Regulatory Guide 1.70, Revision 3, describe (4.4.6) the vibration and loose-parts monitoring equipment to be provided.
The procedures to be used to detect excessive vibration and the occurrence of loose parts should be discussed.
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640.0 "L-- "4' ndU ii hi kEVHW hhMiCh s
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Per the requirements of Regulatory Guide 1.70 Revision 3, Section (14,2) 14.2.6, provide the requirements pertaining to the disposition of test procedures and test data following completion of the test program.
640.2 s
Provide schedules which show the time allowed for conducting pre-
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(14.2.10) operational tests, fuel loading, low power tests, and power ascension tests.
Your response should address the compatibility of these schedules with the schedule for hiring and training of test personnel.
640.3 Our review of tne preoperational and startup test descriptions ;..e-(14.2.11) sented in Table 14.2-3 disclosed that many are not sufficiently descriptive for us to conclude that satisf actory acceptance criteria have been established.
Stating that a system or component operates satisf actorily is not an acceptable description of the test acceptance criteria.
It is of ten not necessary to state numerical values for the criteria in the test description; however, the. acceptance criteria of the test description should state clearly what the acceptance criteria of the test procedures will be (e.g., technical specification limits, Chapter 15 assumptions, design basis values.) Clarify the acceptance criteria of each preoperz.ional or startup test description which refers to cemonstrating satisf actory performance for its acceptance criteria.
c 2-13
a.
910.0 PHYSICAL SECURITY LICENSING BRANCH (SAFEGUARDS CONTINGENCY PLAN REVIEW)
A review of the plan indicates that the following revisions are required.
For ease of administration it is suggested that you submit revised plan pages bearing the appropriate revision number and date.
Specific Comments 910ol Add the following events..within this section:
(1.3.1)
Security System Degradation (intrusion detection, alarn annunciation, security system power and access control devices).
Loss of Protected Area Lighting Loss of Onsite/Offsite Communications Sabotage Device Rendered Inoperable, Tampered Equipment Restored, In-truoer Captured or Escapec For the above listec events, aisc add the appropriate event information witnin the Generic Planning Base and the kesponsibility Matrix Sections.
910.2 Revise tne secono paragraoh of this section to deiste references to (1.3.2) cccpensatory measures identified in tne security pian.
insse compensatory measures are necessary actions resconcing to specific contingency events ano shoulc appear in the contirtency planning cocumer.t.
910.3 Acc notification of the NRC to the Decisions and Actior.s *,:;tions ir.
(2.2.3)
Events Di anc D'.
91 0.4 kes por.s ibili t y Matri)
(4.C; Tnreat Situation A2
.idd " Event F.3" to ine next step sectior..
inreat Situation Di L D2 Adc notification of the !;RC to tne matrix.
Tnreat Situation El Add " Event 11" to the next step 'section.
2-14 l
l
Threat Situatiob. Mi Revise the Generic Planning Base and the Responsibility Matrix next 5tep Sections to reference either Event A2 or Event A3 but not both.
General Comments Identify both the minimum' and
- normal" decision makers for the following event steps:
D3-2,- D3-3, D3-4, 13-3 12-4, 13-1, 13-2, 13-5, Mi-2, M1-3, F1-1, H2-2, M2-4, M2-5, M3-3, M3-4, 51-1, 52-2, and 5-3.
Identify the minimum decision maker for the following:
13-4, M2-3, 51-3, and 51-4.
C 6
I l
2 15
240.0 HYDROLOGIC AND GE0 TECHNICAL ENGINEERING BRANCH 240.1 General (ER)
The Sumary and Conclusions section of the CP FES, numbers 7b and c, respectively, stipulated that a description and results of analyses or studies, and additional current and wind studies, be provided so that the staff could confim the adequacy of the final design of the discharge diffuser, and that a study bg undertaken (and provided) with the objective of detemining means to minimize the discharge of total residual chlorine. Please provide the infomation in the appropriate sections of the ER and cross reference the FES.
240.2 Descriptions of floodplains, as required by Executive Order 11988, (2.4)
Floodplain-Management, have not been provided.
The definition used (ER) in the Executive Order is:
Floodplain:
The lowland and relatively flat areas adjoining inland and coastal waters including floodprone areas of offshore islands, including at a minimum that area subject to a one percent or greater change of flooding in any given year, Provide descriptions of the floodplains adjacent to the site.
a.
On a suitable map (s) provide delineations of those areas that will be flooded during the one percent (100 year) flood, both before and af ter plant construction or operation.
b.
Provide details of the methods used to determine the floodplains in response to a. above.
Include your assumptions of and absis for the pertinent parameters used in the computation of the flood flows and water elevations.
If studies approved by the Federal Insurance Administration (FIA) are available for the site and other affected areas, the details of the analysis used in the reports need not be supplied.
You can instead provide tne reports from which you obtained the floodplain information.
Identify, locate on a map and describe all plant structures and c.
topographic alterations in the floodplains.
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.
Provide the details of your analysis used in response to d. above.
e.
The level of detail is similiar to that identified in item b. above.
3-1
240.3 Surface Waters (2.4.1)
(ER)
Provide a narrative description of the ocean areas, Hampton Harbor and nearby streams with respect to the site.
~
240.4 Principal Flow Patterns (2.4.1.1.a)
(ER) a.
Pravide the period of record used to estimate seasonal effects of different flow types, and discuss the extent to which conditions can be different.
b.
'(Para. 2) What are the units for stated flows in other directions?
c.
(Para. 2) Are flows at depth in a shoreward direction, or do they have a shoreward conponent?
240.5 Tides (2.4.1.2)
(ER)
Where were tides measured? Were they open coast measruements, or were measurements made in protect-d areas.
240.6 Water Temoerature (2.4.1.3)
(ER)
Wnere were and are temperature measurements made? Provide information for both coastal and harbor areas.
240.7 Salinity (2.4.1.4)
(ER) a.
Where were the date collected?
b.
What were the ranges in salinity noted in Hampton Harbor, and what differences between seasons were noted?
c.
To what extent was salinity stratification in Hampton Harbor noted?
240.8 Dissolved Oxygen (2.4.1.5)
(ER)
Where along the coast, and in Hampton Harbor were data collected?
240.9 Sedimentological Conditions (2.4.1.6)
(ER) a.
6.iere were the eight stake locations?
b.
What has been the experience with shoreline changes along the coast and in Hampton Harbor?
c.
What has been the experience with sediment deposition in Hampton Harbor?
d.
Have there been any projections of shoreline changes along the open coast, or in Hampton Harbor; or of deposition near the intake, discharge or Hampton~ Harbor?
If so, what do they indicate?
3-2
240.10 Utilization of Groundwater (2.4.2.1)
(ER) a.
How many wells have been developed, or are you intending to develop, onsite? Where are or will they be located, from which hjdrologic
- formation will they draw water and at what elevations?
l b.
Where does the town of Seabrook obtain its water?
c.
During the CP no mention was made of obtaining fresh water from onsite wells.
What is the reason for not supplying all the plants'
, fresh water needs from the town of Seabrook and why does the change not constitute a significant environment impact?
240.11 Tables and Figuras (2.4)
(ER) a.
What are the titles for columns 2 and 3 of Table 2.4-3?
b.
Where do the data presented on figure 2.4-1 apply?
c.
Where do the data presented on figure 2.4-2 apply?
d.
On figure 2.4-3:
1.
What is the true north; plant north?
2.
Does the grid system correspond with Table 2.4-3?
3.
What are the contour intervals, and to what datum?
4.
Where are adjacent water bodies (i.e., Hamp.on Harbor) located with respect to the plant?
240.12 Plant Water Use l
(3.3) l (ER) a.
The text indicates on-site wells and the town of Seabrook are the I
two sources of fresh water.
Figure 3.3-1, however, indicates l
Hampton Falls Wells.
Please explain this discrepancy.
l b.
Is the 120,000 gpm consumptive fresh water usage for one unit, or two?
c.
Table 3.3-1 and numbers in the text do not appear to ugree; l
please verify?
f d.
Will the emergency towers be operated at low flow rates in the winter to prevent freezing?
If so, will blowdown be significant during such periods?
3-3
240.13 Table 3.3-1 (ER)
Item 9 appears too high for the limited testing and use contemplated a.
for the emergency cooling towers.
Please verify.
b.. Does the note for item 10 apply to one unit or two?
240.14 Figure 3.3-1 (ER) a.
The text indicates cooling tower blowdown will be routed to the setting basin.
If so, please amend the figure accordingly.
b.
Please indicate the discharge from the settling basin into Hampton Harbor.
c 240.15 Description of Heat Dissioation System (3.4.2)
(ER)
Please include a brief ocscription of the emergency standby system, or-cross ieference applicable text in other sections.
240.16 Intake System (3.4.2.2)
(ER)
? lease clarify the number of intake structures; 1, 2 or 3.
240.17 Discharge System (3.4.2.3}
(ER)
(Para. 2) Either the discharge flow rate or the numerical value given and its units are not correct.
Please cs. rect.
240.18 Figure 3.4-1 4
(ER) a.
What are contour interval units, and to what datum?
b.
Where is the diffuser?
c.
Wnere are the 3 (?) intakes?
240.19 Figure 3.4-3 (ER)
Why has the design of the intake structure (s) been altered over that presented in the CP ER?
240.20 Sanitary and Other Waste Systems (3.7)
(ER)
What limitations have been imposed, or will you impose, on dissolved solids and temperature in settling basin effluents.
240.21 Federal Thermal Criteria (5.1.1.1)
(ER)
Discuss any consequences of mechanical draft tower blowdown through
{
the settling basin.
i 3-4
240.22 New Hampshire Thernal Criteria (5.1.1.2)
(ER) a.
Under no. 2, where are the points established?
b.
Under no. 3, what is the delineated mixing zone?
~
240.23 Physical Effects (5.1.2)
(ER) a.
Describe what if any activities will be undertaken to confirm the thennal design studies?
b.
Ref. 90 is wrong.
Please correct.
240.24 Cooling Tower Discharge (5.3.2)
(ER)
See question 240.12 para. d.
240.25 Environmental Effects of Accidents (7)
(ER)
Calculate the radiological consequences of a liquid pathway release from a postulated core melt accident.
The analysis should assume, unless otherwise justified that there has been a penetration of the reactor basemat by the molten core mass, and that a substantial portion of radioactively contaminated sump water was released to the ground.
Doses should be compared to those calculated in the Liquid Pathway Generic Study (fiUREG-04'C,1978).
Provice a summary of your analysis procedures and the values of parameters used (sucn as permeabilities, gradients, populations affected, water use).
It is suggested that meetings with the staff of the Hydrologic Engineering Section be arranged so that we may share with you the body of information necessary to perform this analysis.
240.26 Environmental Radioloaical Monitorinc (6.2.1.2)
(ER)
Will settling pond effluent be monitored?
240.27 Discharge System (10.3)
(ER)
See question 240.12 part c.
240.28 Environmental Approvals and Consultations (12)
(ER)
What permits are required, and what is their status, for settling basin effluents.
e 3-5
ENVIRONMENTALENGINEERINGBR[NCH 290, 291 290.1 Terrestrial Resources 290.1 Provide a site map indcating location of additional space (ER Section 4.1) cleared for equipment laydown and construction facilities and provide an estimate of the amount of upland woods cleared.
290.2 Provide a description of the grounding systems and line clearances (ER Section 5.5) which will be used to reduce operating induced voltages and currents in conducting objects, such as fences and large vehicles, in the vicinity of the right-of-way.
Provide an estimation of the maximum electrical fields (in kilovolts per meter) at a one meter height beneath the proposed transmission lines and at the edge of the right-of-way.
Provide an assess-ment of the biological significance of the electrical fields to be generated by operation of the Seabrook transmission facilities.
290.3 Provide the list of federal and state endangered and threatened (ER Section 6.1.4.3) plant and animal species referred to in ER Section 6.1.4.3.
290.4 There is no discussion of audible noise in ER-0L Section 3.9 (ER) as stated in ER-OL Section 5.5.
l 3-6
4 291.0 Aquatic Resources Section 2.1.3.4 Recreational and Comercial Fisheries. This section states that anglers catch greater than one million pounds of stripec snnually from the marine waters within a 50-mile radiur of Ss
.k.
291.1 a)
Provide similar estimates of annual angler harvests for the (ER) other major recreational finfish species noted in the ER.
291.2 b)
Provide estimates of annual recreational harvests of soft (ER) clam (Mya) and lobster within the 50-mile radius; 291.3 c)
Provide estimates of annual harvests of finfish and shellfish (ER) within Hampton-Seabrook estuary.
Section 2.2.2 Aouatic Ecology. This section provides sumary discussions on biota and studies since 1975, and references several documents.
Provide copies of the following:
291.4 a)
" Summary Document:
Assessment of Anticipated Impact of Construction and Operation of Seabrook Station on the l
Estuarine, Coastal, and Offshore Waters, Hampton-Seab ook, l
flew Hampshire."
flormandeau Associates, Inc.
1977.
l 291.5 b)
Copies of environmental monitoring reports covering the (ER) period between that considered in the " Summary Document" and the present time.
s 3-7
=
291.6 c) An updated and current revision of the March 1977 "Index (ER) to Environmental and Related Infomation (Biological, Hydrographic, Hydrothemal, Hydraulic and Archaeological) -
Seabrook Nuclear Station."
291.7
-Provide data on the occurrence (known or expected) of endangered (ER) marine animals (federal and state) in the Seabrook site vicinity.
291.8 Provide a bibliographic listing and reprint copies of all journal (ER) and professional conference proceedings publications (by applicant and applicant's consultants) that have resulted from studies and monitoring of the coastal, estuarine, and freshwaters associated with Seabrook Station.
291.9 Section 3.4 Heat Dissipation System.
Provide, in table fonn, (ER) a comparison of all system specifications as they now exist with those that were evaluated in the 1974 AEC FES-CP stage.
291.10 Provide a brief historical discussion of the regulatory requirements (ER) that resulted in the present system specifications.
l t
Section 6.2.2 Operational Monitoring, Surface Waters 291.11 Provide the details of the proposed plan of study for 316(a) and (b)
(ER ).
monitoring under the NPDES Permit.
l 3-8
2112 Provide a copy of the proposed NPDES Permit for plant operation submitted to EPA (as indicated in ER-OL Section 12).
~
I 291.13 Provide a copy of the 401 Certification issued by the State of (ER)
New Hampshire (as per Section 12).
291.14 Discuss any new information (i.e., since the publication of the (ER)
FES-CP,' on existing water quality stresses in the Browns River or in the Gulf of Maine near the station intake and discharge structures 291.15 Quantitatively discuss the ability of the municipal water supply (ER) of the town of Seabrook te supply the station with fresh water.
The discussion should address normal and drought periods.
291.16 Indicate the expacted frequency and duration of the circulating (ER) water system backflush operations.
Characterize the effluent (e.g., cycles of concentration, physical and chemical characteristics) of the service water system discharged to the Browns River during this time.
291.17 Provide copies of NPDES Permits NH0020330 and NH0020338.
l (ER) l l
291 18 Provide a copy of the February 1977 noise survey by New England l
Power Service Company.
3-9
310.0 SITING ANALYSIS BRANCH 310.1 Section 2.1.2.3 notes four surveys (seasonal resident population, overnight (2.1.2.3)
(ER) accomedations, campgrounds, and parking lot capacities) which are neither described in terms of methodology or in terms of a reference citation The Applicant should provide copies of these surveys to the NRC.
310.2 Section 3.9 indicates that transmission line facilities remain unchanged (3.9)
~
(ER) from that presented in Section 3.9 of the Seabrook Station ER-CPS "except as noted below."
In fact Sections 2.6 and 4.2.1 indicate changes.
The Applicant should reconsidr/ the statement in Section 3.9 of the ER-OL and develop a full discussion which indicates the following:
(1) all lines and corridors associated with Seabrook Station, (2) status of construction and planning, (3) potential visual and physical impact on historical and archeological resources which are either on or potentially eligible 'or inclusion on the National Register of Historic Places, (4) the status of hearings on transmission line planning and construction before state hearing bodies, and (5) the consistency of the Applicant's plans for transmission lines with the NRC's consideration of transmission line routes in the Seabrook FES-CP (12/74).
310.3 The Applicant should indicate the estimated property taxes to be paid (ER) during the first year of operation by special district, local jurisdiction and state.
310.4 Section 8.1.6 indicates employment of 450 at the site.
Does this figure (8.1.6)
(ER) include security. janitorial, and maintenance personnel?
If not, these figures should be provided.
How many existing residents does the Applicant estimate will be employed at the site? The Applicant should indicate
~
the basis for the response.
3-10
310.5 The Applicant should indicate the types of goods and services that will be purchased locally. The Applicant's response should indicate the dollar value of such purchases and the market area of purchJse.
f a
b I
4 i
D 3-11
l r
320.0 UTILITY FINANCE BRANCH
~
320.1 Explain the basis of the statement at p.1.2-1 that "The production (ER) of electricity from this plant [Seabrook] will displace approximately 23,000,000 BBLS of oil per year...."
320.2 Quantify the expected effect, if any, of Seabrook 1 and 2 on base-(ER) load consumption of coal.
320.3 for the year 1980 provide (a) a breakdown of electricity generated
( ER) by fuel type (coal, nuclear, etc.) and (b) the average production cost by fuel type.
320.4 Indicate the proportion of the estimated capital costs for Seabrook (ER) 1 and 2 which has already been spent.
320.5 Provide the following:
(ER)
A production cost analysis which shows the difference in system production costs associated with the availability vs. unavailability of the proposed nuclear addition.
Note, the resulting cost dif-ferential should be limited solely to the variable or incremental costs associated with generating electricity from the proposed nuclear addition and the sources of replacement energy.
If, in your analysis, other factors influence the cost differential, explain in detail.
a.
The analysis should provide results on an annual basis covering the period from initial operation of the first unit through five full years of operation of the last unit.
b.
Where more than one utility shares ownership in the proposed nuclear addition, the analysis should include results for the aggregate of all participants.
However, given that Seabrook 1 and 2 are expected to be centrally dispatched as NEPOOL units, this analysis may be performed for NEP00L as a whole.
c.
The analysis should assume electrical energy requirements grow at (1) the system's latest officia', forecasted growth rate, and (2) zero growth from latest actual annual energy requirements.
d.
All underlying assumptions should be explicitly identified and expl a ined.
O 3-12
For each year (and for each growth rate secenario) the following e.
results should be clearly stated:
(1) systen production costs with the proposed nuclear addition available as scheduled; (2) system production costs without the proposed nuclear addition available; (3) the capacity factor assumed for the nuclear ad-dition; (4) the average fuel cost and variable 0 & M for the
" nuclear addition and the sources of replacement energy (by fuel type) - both expressed in mills per kWh; and (5) the proportion of replacement energy assumed to be provided by coal, oil, gas, etc.
3-13
I 451.01 a) To expedite the meteorological review, provide hour-by-hour (2.3) meteorological data from the onsite meteorological measurements (ER) program for the period April 1979 - March 1980 using the enclosed guidance on tape attributes.
b) One complete year (i.e., no missing hourly data) of data is used by the staff in the calculation of Reactor. Accident Consequences (CRAC) computational procedure. Data recovery for the one-year period April 1979 - March 1980 was less than 100%, indicating that data need to be substituted for the staff to perform the CRAC anaTysis.
Provide substituted data for.all missing periods, identify the source of substituted data, and provide a brief description of the bases for selecting substituted data.
451.02 For reviews of Operating License Applications, at.aast two years (2.3)
(preferably three or more) of onsite meteorological data are to be (ER) submitted with the Environmental Report (see Regulatory Guide 4.2, Revision 2). Only one year (April 1979 - March 1980) has been submitted with the Seabrook Environmental Report. Two years of data (December 1971 -
November 1972 and December 1972 - November 1973) were submitted during review of the Construction Permit Application.
However, after each one-year period of meteorological data collected at the Seabrook Site, the measurements program has been changed, preventing combination into a multi-year period of record.
a) Provide a comparison of data from the most recent one-year period with earlier periods, contrasting wind speed distributions, wind direction frequencies, and occurrences of atmospheric st6bility classes by annual cycles, b) Provide comparisons of calculated.short-term.X/Q values (used in Chapter 7 of the ER) and annual average X/Q values (used in Chapter 5 of the ER) for each one-year period of record.
c) Provide joint frequency distributions (or hour-by-hour data on magnetic tape) of wind speed and wind direction for the 43-ft level by temperature difference between the 43-f t and 150-f t levels for period April 1980 - March 1981.
451. 03 Section 2.3.1 of the ER provides a qualitative description of air (2.3) quality in the vicinity of the site and states that these conditions (ER) will not " adversely affect station operation." Describe station sources of criteria air pollutants, including, estimated emissions, and compare these emissions to the DeMinimus criteria established by the Env'ronmental Protection Agency.
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 modeling.
3-14
451.N The discussion of.the effects of operation of the heat dissiration (ER) syster (Section 5.1.of the ER). states lhat one of the "specif.ic determinations relevant to the dischar'ge of cooling water" is that "backflushing operations for fouling control shall be performed only during times when meteorological and hydrological conditions are such that the plire flows offshore and/or tenserature increases are minimized at the Sunk kocks." Furthermore, during backflushing a machanical draft cooling tower would be used for the service water system.
a) Describs the procedure for intecratir.; o nearciogical data into thi procedure fer initiating backfluthing cp rcticn:.
b) Indicate the expected frequency of operation of the mechanical draft cooling tower, and provide the bases for the statement-that fogging and icing effects "would occur only in the vicinity of the cooling tower."
Indicate if such fogging and icing effects would be confined to the station site.
451.05 The description of the. current onsite meteorological measurements program (6.1.3) states that the low-level wind speed and direction sensors and temperature (ER) difference sensor are located at a height of 43 feet above the surface.
The standard height for low-level sensors is 10 m (see Regulatory Guide 1.23, 1972, and proposed revision 1, September 1980). Provide justification for this deviation from the recommended height of low-level instruments.
451.06 Four 15-minutes averages are stored on disc for each hour of onsite (6.1.3 data (see p. 6.1-4).
Describe the procedure for determining an (ER) hourly average of each meteorological parameter (i.e., is an hourly average determined from one 15-minute average or through averaging of four 15-minute averages?).
451.'07 The description of the atmospheric dispersion model used for (6.1.3) calculation of annual average relative concentration (X/Q) and (ER) relative deposition (D/Q) values requires additional clarification.
a) Describe how fumigation and trapping were considered (see p. 6.1-5).
b) Identify the points of release of radioactive material to the atmosphere and compare the release characteristics with the criteria in Regulatory Guide 1.111 for the determination of partially elevated and partially ground level releases.
c) Discuss the appropriateness of a straight-line trajectory model.for use at the.Seabrook site, considering spatial and temporal variations in airflow.
Provide adjustments to the straight-line model, if necessary.
~
451.08 The existing.onsite meteorological measure m ts program is described (6.2)-
in Section 6.1.3 as a pre-operational prog; n.
The meteorological (ER) program is not described as an operational program in Section 6.2.
Describe the proposed operational meteorological measurements program, and compare the program with the pre-operational program described in Section 6.1.3.
3-15
470.0
_ RADIOLOGICAL ASSESSMENT BRANCH 470.1 In accordance with 10 CFR Part 50 Appendix I, Section II.D. specify (ER) whiqh option has been selected for use in calculating the population dose estimates.
470.2 Provide the dates that the information contained in Tables 2.1-14 and (ER)
Figures 2.1-9 through 18 are based on.
470.3 Update Tables 2.1-10 to include the projected transient population for (ER) the year 2000.
470.4 Table 2.1-17 and Tables 2.1-25 through 2.1-30 based on 1974 and 1977 data, respectively) as well as all other tables c(ontained in the Seabrook (ER)
Nuclear Station environmental report should be updafed to reflect the latest information available.
470.5 Section 6.1.5 of the Environnental Report should be updated to include (ER) tables as illustrated in USNRC Branch Technical Position "An Accept-able Radiological Environnental Monituring Program" Revision 1, Novem-ber 1979.
3-16
Request for Additional Information Seabrook Station, Units 1 and 2 Jocket flos.:
50-443/444 here are many areas in which reouirements have been added or modified, or in
.nicn staff, concerns have been raised in the review of othee cending OL acolica-lons.
To excesite the review crocess for your aoplication, it is reouested
- nat you evaluate tnese areas ano, unere accroariate, upgrade your FSAR to
'nclude how these requirements are met or how these staff concerns are resolved.
Nu should submit these changes to the FSAR. in amenoment form, within sixty
- ays from the docketing cate.
)
Envirarmntal Nalification cf Safety Related Electrical Eouictent -
Jc= mission Memorancum ano Orcer of :'ay 23, 1980 defines tne current staff reouirements for cualification of this eouioment.
Additional guidance on this matter was orovided in a subsecuent NRR order dated
- lovember 26,1980 (concerning record reouirements)
Supplements 2 ano 3 dated Seotember 30, 1980 and October 24, 1980, resoectively to IE Bulletin flo.70-018, and a generic letter dated October 1,1980 to all holders of cps and OLs.
(2)
Emergency Precareaness - Guidance on the orecaration of emergency plans is cresented in lCREG-0654 (FE!*.A-REP-1), " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Prepareoness in Suoport of Nuclear Power Plants". The requirements for the emergency resconse facilities are included in UUREG-0696. " Functional Criteria for Emergency Response Facilities,"
Further guioance on emergency pre-paredness is provided in the revised Appendix E to 10 CFR Part 50.
(3)
Safety - Related Structures. Systems and Comoonents (0-list) Controlled by the 0A Program - Staff requests for additional infonnation regarding this issue have been sent to a number of OL applicants. A recent request from the Diablo Canyon review is provided as enclosure 5.
(4)
Fracture Prevention of Containment Pressure Boundary (GDC 51 ) - Enclosure 6 provides clarification on how the staff detennines compliance with GDC 51.
(5)
Fire Protection - The current requirements for the fire protection pro-grams are defined in the new Appendix R to 10 CFR Part 50. As further guidance, a copy of a recent staff request for additional information on pending OL applications is provided as Enclosure 7.
(6)
Effects of Masonry Walls on Class I Structures - Staff concerns and a request for information were provided in a generic letter dated April 24, 1980 to all CP and OL applicants.
(7)
Core Thent.ocouole Readouts in the Control Room - (TMI Action Item II.F.2 in NUREG-0737) - Discussion of this item should address how core thenno-couple readouts are provided in the control room including location and rate of printout (see Part (4) of attachment 1 to Item II.F.2).
4-1
. (8)
Preservice and Inservice Inspections - Staff guidance in this review area has been sent to a number of pending OL applicants. A copy of that guidance is provided as Enclosure 8.
(9)
Preservice Inspection and Testing of Snubbers - The staff 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 9.
(10) Effects of Containment Coatings and Sump Debris on ECCS and Containment Spray Operation - A copy of the staff concerns on t41s issue, including a request for additional information which has been sent to a number of OL applicants, is provided as Enclosure 10.
(11) Seismic Qualification - A staff request for additional information in this review area has been sent to a number of pending OL applicants. A copy of that request is provided as Enclosure 11.
(12) Special Low Power Test Program (Task Action Plan Item I.G.1) - The staff has established guidance on this matter for transmittal to all pending and prospective OL applicants.
A copy of that guidance is provided as enclosure 12.
(13)
Corporate and Plant Level Organization and Management - NUREG-0731,
" Guidelines for Utility Management and Technical Resources," provides guidance rega-ding acceptable corporate level and plant staff organizational structures and staffing levels.
NUREG-0737 describes requirements regarding Shift Technical Advisors, licensed operator staffing, working hour limitations, and administrative procedures developed following the TMI-2 accident (TMI Action Plan itens I. A.l.1, I. A.l.2, I.B.1.1, I.B.l.2, I.C.2, I.C.3, I.C.4, I.C.5 and I.C.6).
G 4-2
EtiCLOSUR[ 5 Section 17.1.2.2 of the standard format (Regulatory Guide 1.70) requires the identification of safety-related structures, systems, and co por ents (Q-list) controlled by the QA program.
You are requested to supplement and clarify the Diablo Canyon Q-list in lable 3.2-4 of the FSAR in accord-ance with the following:
The following items do not appear on the Q-list (FSAR Table 3.2-4).
a.
Add the appropriate items to the 0-list and provide a committent that the remaining items are subject to the pertinent reouire-ments of the FSAR operational quality assurance program or jus-tify not doing so.
1.
Safety-related masonry walls (see IE Bulletin fio. 80-11).
2.
Breakwaters.
3.
Leak detection systc.a (see FSAR Section 3.5).
4.
Missile barriers which protect safety-related items.
5.
Onsite power system (Class lE).
a)
Electrical penetrations of containr.ent - l:on-vital includine priuary and backup fault current protective devices.
b)
Raceway fire steps and seals.
c)
Emergency light battery packs.
6.
Radiation monitoring (fixed and portable).
7.
Radioactivity monitoring (fixed and portable).
8.
Radioactivity sampling (air, surfaces, liquids).
9.
Radioactive contamination measurement and analysis.
10.
Personnel monitoring internal (e.g., whole body counter) and external (e.g., TLD system).
11.
Instrument storage, calibration, and maintenance.
12.
Decontamination (facilities, personnel, and equipr.ent).
13.
Respiratory protection, including testing.
14.
Contamination control.
15.
Radiation shielding.
16.
!!eteorological data collection programs.
17.
Expendable and consumable items necessary for the functional performance of safety-related structures, systems, and corpo-nents (i.e., weld rod, fuel oil, boric acid, snubber oil, etc.).
5-1
b
- 18. licasuring and test equipment used for safety-related struc-tures, systems, and components.
19.
Ground slope east of building complex.
20.
Firewater storage reservoir ponds.
21.
$ydrogen recombiner, including piping and valves.
22.
Containment pressure indication system.
23.
Containment water level indication systems.
24.
Containment hydrogen indication syster..
25.
Valve operatnrs for safety-related valves.
- 26. I otors for safety-related pumps.
5-2
b.
The following items from the Q-list (FSAR Table 3.2-4) need expansion and/or clarification as noted. Revise th list as indicated or jus-tify not doing so.
1.
Portions of the turbine generator building (sheet 4) which enclose the emergency diesel-generator units and ancillary systems as well as other safety-related components should be under the controls of the operational QA program.
2.
New fuel storage racks (sheet 3) should be under the con-trols of the operational QA program.
3.
Intake structure and conduit (sheet 5) should be under the controls of the operational QA program.
4.
Containment structure semp, sump screen, and vortex sup-pression should be under the controls of the operational QA program.
5.
Reactor cavity sump pump (sheet 18) should be under the con-trols of the operational QA program.
6.
Clarify that the primary system PORV, safety valves, and PORV block valves and their actuators are included under
" Reactor Coolant Systems Valves," (sheet 25).
7.
Clarify that the main steanline safety valves and steamline PORVs and their actuators are included under " Valves for the Above (Main Steam Piping-SG to MSIV) Portion of System" (sheet 23).
8.
Identify the safety-related instrumentation and control sys-tems to the same scope and level of detail as provided in Chapter 7 of the FSAP..
9.
The 250V DC Motor Control Center SD 121 (sheet 36) should be under the controls of the operational QA program.
10.
Circulating water conduits (sheet 5) should be ur. der the controls of the operational QA prograr.
5-3
- c. of I;UREG-0737, " Clarification cf it'.I Actior. Plan Require-ments" (flove.-ber 1980) identified numerous items that are safety-related and appropriate for OL application and therefore should be on the 0-list.
These items are listed below.
Add the appropriate items to the Q-list and provide a commitment that the remair.ing items are subject to the pertiner.1 requirements of the FSAR operational quality assurance program or justify not doing so.
IJUREG-0737 (Enclosure 2)
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) Auxiliary feedwater system.
II.E.1.1
- 7) Auxiliary feedwater system initiation and II.E.1.2 fl ow.
8)
Emergency power for pressurizer heaters.
II.E.3.1 9)
Dedicated hydrogen penetrations.
II.E.4.1 10)
Containment isolation dependability.
II.E.4.2 11 ) Accident monitoring instrumentation.
II.F.1 12)
Instrumentation for detection of inadequate II.F.2 core-cooling.
13)
Power supplies for pressurizer relief valves, II.G.1 block valves, and level indicators.
- 14) Automatic PORY isolation.
II.K.3(1)
- 15) Automatic trip of reactor coolant pumps.
II.K.3(5) 16)
PID controller.
II.K.3(9)
- 17) Anticipatory reactor trip on turbine trip.
II. K. 3(12) 18)
Power on pump seals.
II.K.3(25) 19)
III.A.l.1/III.A.2 20)
Emergency support facilities.
III.A.l.2 21)
Inplant 12 radiation monitoring.
III.D.3.3 22)
Control-room habitability.
III.D.3.4 54
T EriCLOSUP.E 6 Fracture Prevention of Containment Pressure Boundary (GDC-51)
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 Ferritic materials of the containment pressure boundary which are assessed by the staff are those of components such as freestanding containment vessel, equipment hatches, personnel airlocks, primary containment drywell head, heads containment penetration sleeves, proccess pipes, end closure caps and flued heads-and penetrating piping systems downstream of penetration process pipes extending to and including the system isolation valves.
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 Sumer 1977 Addenda to ASME Code Section III.
6-1
Ef;CLOSUDE 7 FIRE FROTECTICi REVIEW SEABROOK STATIO!i U;;ITS 1 & 2 00CKET N05. 50 458 L 50-459 In acccedance with section 9.5.1, Iranch Technical Fosition ASE 5.5-1, position
"~
C.4.a.(1) of NRC Standard Review Fian and section III.G cf new Appendi: R to '
10 CFR Part 50, it is the staff's pcsition that cabling for redundant safe shutdown syste=s should be separated by wall'.;aving a three-hour. fire rating cr e;uivaient protection (see secticn III.G.2 cf Appendix R).
That is, cabling required for or associated with the primary cethod of shutdown, should be physically separated by the equivalent of a three-hour rated fire barrier' fro:
catling required for or associated with the redundant or alternate method of shutdcwn.
Tc assure that redundant shutdown cz'ble systems and all other cable systems that are associated with the shutdown cable systems are separated frc:
each cther s: that both a. e n:t subject 10 damage frc: a single fire hazard, we require the foiloving in'ermaticn for each syste: needed to bring the plant to a 5a fe shutcewr..
1.
Provice a table that lists all equipment including instrumentatien and vital -
supp:rt syste: equipment required to achieve and maintain h: and/cr cold shutd:wn.
Fcr each equipment listed:
Differentiate between equipment required to achieve and =aintain hot a.
shutd:wn and equipcent required to achieve and maintain cold shutdown, b.
Define each equipment's location by fire area, Cefine each equipment's redundant counterpart.
c.
7-1
Identify each equipment's esser.tial cabling (instrumentation, d.
cc.. trol, and power).
For ee:h cable identified: (1) Describe the cable, routing (by fire area) from source to termination, and (2) identify each fire area lo:ation where the cables are separated by less than a wall having a th.ee-hour fire rating fr:c cables for any redundant shutd sn system, and List any pr:ble: areas idantified by itec 1.d.(2) above that will e.
be corrected in accordance with Se: tion III.G.3 of Appendix P.
(i.e., alternate er dedicated shutdown capebility).
2.
Provide a table that lists Class lE and 1;:n-Class IE cables that are associated with the essential sa fe shutdcwn systems identified in ite:
1 a bo ve.
For each cable listed:
(- See note or. Page 2}.
Cefine the cables' association to the safe shutd:wn syste: (c m::n a.
p:-er source, c:==:n ra:evay, separatien less than IEEE Stancard-guidelines, cables for equipmer.t whese spurious c;eratien 332 will adversely a ffect shutdowr. :ystems, etc.),
b.
Cescribe each associated cable routing (by fire area) fr== source to ter=ination, s.nd Ider.tify each location here the associated cables are separated c.
by less than a wa'il having a three-hour fire rating fr:: ca bles required for or associated with any redundant shutdown syste:.
7-2
3.
prsvide one of the f:llcwing for cach of the circuits identified in ite:
2.. c a b:v e :
(a)
The results of an analysis that den:nstrates that failure caused by open, ground, or hot short of cables will not affe:t it's associsted shutdown siste=,
- Note *
(b)
Identify each circuit requiring a solution in accordance with secti n III.G.3 cf Appendis A, er (c) Identify each circuit meeting or that will ce modified to meet the recuirements of section III.G.2 of AppGncix R (i.e., three-hour wall, 20 feet of ciear~ space witn automatic fire suppressicn, or on -hour barrier witn autcmatic fire suppressien).
4 To assure complian:e with GD" li, we require the f:li: wing infor ation be previded f:r the c:ntr:1 ro::.
If credit is to be taken f:r an alternate or dedicated shutt: r. method for other fire a'reas -(as identified by ite:
1.e er 3.b ab:ve) in accordance with secti:n III.G'.3 'cf new A;pendix R to 10 CTR Part 50, the following informatien will also be required f:r each of these plant areas.
i l
A table that lists all equipment including instrumentation and vital a.
support systa: equipment that are requireg by :ye p;5;zr,eezy;g og achieving and a t'ntaining. h:t and/or c:ld shutd:wn.
3
(
NOTE 1
l Optien 3a is c:nsidered to be ene method of meetir.g the recuirements of Secticn II.G.3 Appendix R.
If option 3a is selected the informaticn recvested in items 2a and 2c above should be provided in ceneral terms and the intor-mation recuestet 5y 2b need not be providec.
7-3
b.
A table that lists all equipment i[lcluding instruser.tation and vital suppcrt syste: equip..ent that are required by the alterr. ate. dedicated, or remete cathod of achieving an'd maintaining hot and/cr cold shutdown.
Identify each alternate shutdown ecuipment listed in itto 4.b above c.
with essential cables (instrumentation, control, and p:wer) that are located in the fire arra centainind,the primary shutdown equipment.
F:r each iqui[ ent listed provide ene of the following:
(1)
Detailed electrical schematic crawings that show the essential cables that are duplicated elsewhere and are electrically isolated from the subject fire areas, er i
(2)
The results of. an analysis that denenstrates that failure (cpen, ground, or hot sh:rt) of each cable ider.tified will n:t affect the c ; ability to achieve and maintain het or c:ld shutd:wn.
- d. -Frovide a table that lists Class lE and.N:n-Class lE cables that are associated with the alternate, dedicated,or re: acte method of shutdown.
For each ite: listed, identify each ass:cf ated cable located in the fire area containing the primary shutdo'=n equipment.
For each cable so identified pr:Yide the results of an analysis that dencastrates that failure (open, ground, or bot short) of the assoc!.ated cable vill not adversely affect the al terr.a te, dedica ted.or remote sethod o f shutd:wn.
7.
5.
The residual heat removal syst'e5 is generally a lcv pressure syste that interfaces with the high pressure pridary coclant system. To preclude a LOCA through this interface, we require c:epliance with the recc: enda-tions of Branch Technical Fosition R55 5-1.
Thus, this interface rest likely consists of two redundani.and independent motor operated valves with diverse interlocks in accordance with Branch Technical Position IC55 3.
These two c.otor operated valves and their 4ssociated cable cay be subject to a single fire ha:ard.
It is our concer.i that this single fire could cause the two valves to open resulting in a fire-initiated LOCA through the subject high-low pressure syste: interface.
To assure that this interface
,and other hich, low pressure interfaces are _adtjuataly pr tes;ed from the effects of a single fire, we require the folicsing inf rmatice.:
a.
Identify.each high-lew pressure ir.terface that uses retur. dant
.eie:trically c:ntr:lled devices (such as two series cctor cperater valves)
- isciate er preclude rupture cf any primary coelar.:
bcundary.
b.
Identify each device's essential cabling (p:ver and c: trol) and describe the cable routing (by fire area) frc: sour:e to ter=ination.
Identify each location where the identified cables are separated c.
by.less than a wall having a three-hour fire rating fr::,c a bl es for the redundant device.
7 '5 '
__= -__-___.
For the areas identified in ite.m 5/c above (if any), provide the d.
b:ses and justification as to the.',acceptchility of the existing design or tny prop; sad c.odifications.
e e
W 8
e O
7-6 I
ENCLOSURE 8
".RESERVICE... PECTION BRANCH We require that your inspection program for Class 1, 2 and 3 components be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a, paragraph (g).
Accordingly, submit the following information:
(1) A preservice inspection plan which is consistent with the required edition of the ASME Code. This inspection plan should include any exceptions you propose to the Code requirements.
(2) An inservice inspection plan submitted within six months of the anticipated date for commercial operatier..
This orerervice inscettion plan will be reauired to support the safety evaluation report finding regarding your compliance witn preservice and inservice inspection requirements. Our determination of your co=aliance will be baseo on the edition of Section XI of the ASME Code referenced in your FSAP. or later editions of Section XI referenced in the FEDERAL REGISTER that yce may elect to apply.
Your response to this item should define the applicable edition (s) and subsections of Section XI of the ASME Code.
If any of the examination recuirements of tne particular edition of Section XI you referenced in the FSAR cannot be met, a reouest for relief must be submitted, including complete technical Justirication to support your request.
Detailed guidelines for tne preparation and content of the inspection programs to be submitted for staff review and for relief recuests are attacned as an Appendix to Section 121.0 of our review questions.
4 6
8-I
APPENDIX TO SECTION 121.0 GUIDANCE FOR PREPARINC PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUESTS PURSUANT TO 10 CFR 50.55a(9)
A.
Descriotion of the Preservice/ Inservice Inspection Procram This procram should cover the reauirements set forth in Section 50.55a(b) and (g) of 10 CFR Part 50; the ASME Boiler and Pressure Vessel Code, Section XIc Subsections IAW, IWB, IWC and IWD; and Standard Review Plans 5.2.4 and 6.6.
Tne guidance provided in this enclosure is intended to illustrate the type and exteat of information that should be provided for NRC review.
It also describes the information necessary for "recuest for relief" of items that cannot be fully inspected to the reauirements of Section XI of the ASME Code.
By utilizing these guidelines, applicants can significantly reduce the need for requests for additional informa-tion from the NRC staff.
B.
Contents of the Submittal The information listed below should be included in th2 submittal:
1.
For each facility, include the applicable date for the ASME Code and the appropriate addenda date.
2.
The period and interval for which this program is applicable.
3.
Provide:the proposed codes and addenda to be used for repairs, modifications, additions or alternations to the facility which might be implemented during this inspection period.
4.
Indicate the components and lines that you have exempted under the rules of Section XI of the ASME Code. A reference to the applicable paragraph of the code that grants the exemption is necessary. The inspection requirements for exempteo components should be stated (e.g., visual inspection during a pressure test).
5.
Identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed imoractical because. of the limitations of design, geometry, or materials of construction of the components.
Provide the information recuested in the following section of this appendix for the inspections and pressure tests identified in Item 4 above.
8-2 C.
F.equest for Relief from Certain Insoettien and Testi.* Recuirements It has been the staff's experience that many requests or relief from testing requirements submitted by applicants and licensees have not been supported by adequate descriptive and detailed technical infor-mation.
This detailed informatirn is necessary to:
(1) document the impracticality of the ASME Code requirements witnin the limita-tions of design, geometry, and materials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.
Relief, requests submitted with a justification such as " impractical,"
" inaccessible," or any other categorical basis, recuire additional information to permit the staff to make an evaluation of that relief request.
The objective of the guicance provided in this section is to illustrate the extent of the ir. formation that is recuired by the HRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the staff's Safety Evaluation Report. The HRC staff believes subsecuent requests for additional information and delays in completing the review can be considerably reduced if this information is provided initially in the applicant's submittal.
For each relief request submitted, the following information should be included:
1.
An identification of the component (s) and/or the examinatior requirements for which relief is requested.
2.
The number of items associated with tne requested relief.
3.
The ASME Code class.
4.
An identification of the specific ASME Code requirement that has be2n determined to be impractical.
5.
The information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesting relief.
6.
An identification of the alternative examinations that are proposed:
(a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance
~
with the requirements of Section XI.
8-3 7.
A description and justification of any changes expected in the overall level of plant safety by performing the proposed alternative examinations in lieu of the examination required by Section XI.
If it is not possible to perform alternate examinations, discuss the impact on the overall level of plant quality and safety.
For inservice inspection, provide the following additional information regarding the inspection frequency:
8.
State when the request for relief would apply during the inspection pe-iod or interval (i.e., whether the request is to deYer an examination).
9.
State when the proposed alternative examinaticns will be
~
implemented and performed.
10.
State the time period for which the requested relief is needed.
Technical justification or data must be sumitted to support the relief request.
Opinions without substantiation that a change will not affect the quality level are unsatisfactory.
If the relief is reques.ted for inaccessibility, a detailed description or drawine which depicts the inaccessibility must accompany the request.
A relief request is not recuired for tests prescribed in Section XI that do not apply to your facility. A statement of "N/A" (not applicable) or "None" will suffice.
D.
Recuest for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examina-tions prescribed in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examination l
must be performed.
A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.
We recognize that some of the radiation considerations will only be known at the time of the test.
However, the licensee cenerally is aware, from experience at operating facilities, of tnose areas where relief will be necessary and should submit as a minimum, the following information with the request for relief.
i 1.
The total estimated man-rem exposure involved in the _.saminatio'n.
2.
The radiation levels at the test area.
8-4
- - 3.
Flushing or shielding capabilities which might reduce radiation levels.
4.
A proposal for alternate inspection techniques.
5.
A discussion of the considerations involved in remote inspections.
6.
Similar welds in redundant systens or similar welds in the same systems which can be inspected.
7.
The results of preservice inspection and any inservice results
'for the welds for which the relief is being requested.
8.
A discussion for the consequences if the weld which was.not examined, did fail.
I 4
8-5
TO ALL APPLICAriTS:
Ef4 CLOSURE 9 Due to a long history of problems dealing with inoperable and incorrectly installeo snubbers, and due to the potential safety significance of failed snubbers in safety related systems and components, 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 3.7-4a and 3.7-4b of Standard Technical Specifications 3/4.7.9 This exami-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 are no visible signs of damage or impaired operability as a result of storage, handling, or installation.
(2)
Tne snubber location, orientation, position setting, and configuration (attachments, extensions, etc.) are according to design drawings and specifictions.
(3)
Snubbers are not seized, frozen or.jarmaed.
(4)
Adequate swing clearance is provided to allow snubber movement.
(5)
If applicable, fluid is to the reco:mnended level and is not leaking from the snubber system.
(6)
Structural connections such as pins, fasteners and other connecting hardware such as lock nuts, tabs, wire, cotter pins are installed correctly.
If the period between the initial pre-service examination and initial system pre-operational test exceeds six months due to unexpected situations, re-examination of items 1,4, and 5 shall be performed.
Snubbers which are installed incorrectly or otherwise fail to meet the above reouirements must be repaired or-replaced and re-examined in.accordance with the above criteria.
Pre-Operational Testinc l
During pre-operational testing, snubber thermai movements for systems whose operating temperature exceeds 250* F should be verified as follows:
(a)
During initial system heatup and cooldown, at specified temperature intervals for any system which attains operating temperature, verify the snubber expected thermal movement.
1 (b)
For those systems which do not attain operating temperature, verify via observation and/or calculation that the snubber will accommodate the projected thermal movement.
(c)
Verify the snubber swing clearance at specified heatup and cooldown intervals.
Any discrepencies or inconsistencies shall be evaluated for cause and corrected prior to proceeding to the next specified interval.
9-1
The sbove described operability ' program for snubbers should be included and documented by the pre-service inspection and pre-operational test programs.
The pre-service inspection must be a prerequisite for the pre-operational testing of snubber themal motion. This test program should be specified in Chapter 14 of the FSAR.
t O
l l
9 6
0 9-2
Containment Sump and its effect on long term coolina following a LOCA_
During our reviews of license applications we have identified concerns re.ated to the containment sump design and its effect on.long tenn cooling following a Loss of Coolant Accident (LOCA).
~
These concerns are related to (1) creation of debris which could potentially block the sump screens and flow passages in the ECCS and the core, (2) inadequate NPSH of the pumps taking suction from the r.ontainment s c:p, (3) air entrainment from streams of water or steam which can cause loss of adequate tiPSH, (4) forma-tion of vortices which can cause loss of adequate tiPSH, air entrainment and suction of floating debris into the ECCS and (5) inadequate emergency procedures and operator training to enable a correct response to these problems.
Preopera tional recirculation tests performed by utilities have consistently identified the need for plant modifications.
The tiRC has begun a generic program to resolve this issue. However, more irrrediate actions are required to assure greater reliability of safety system operation.
We therefore require you take the following actions to provide additional assurance that long term cooling of the reactor core can be achieved and maintained following a postulated LOCA.
1.
Establish a procedure to perform an inspection of the contairment, and the containment sump area in particular, to identify any materials which have the potential for becoming debr,is capable of blocking the containment sump when required for recirculation of coolant water.
Typically, these.
materials consist of: plastic bags,' step-off pads, health physics instru-mentation, welding equipment, scaffolding, metal chips and screws, portable 10-1
l inspection lights.
- secured wood, construction materials and tools as well as other misce..aneous loose equipment.
"As licensed" cleanliness should be assured prior to each startup.
This inspection shall be performed at the end of each shutdown as soon as practical before containment isolation.
2.
Institute an inspection program according to the requirements of Regulatory Guide 1.82, item 14.
This item addresses inspection of the containment sump components including screens and intake structures.
3.
Develop and implement procedures for the operator which address both a possible vortexing problem (with consequent pump cavitation) and sump blockage due to debris. These procedures should address all likely scenarios and should list all instrumentation available to the operator (and its location) to aid in detecting problems which ray arise, indications the operator should look for, and operator actions to mitigate these problems.
4.
Pipe breaks, drain flow and channeling of spray flow released below or impinging on the containment water surface in the area of the sump can cause a variety of problems; for example, air entrainment, cavitation and vortex formation.
l Describe any changes you plan to make to reduce vortical flow in the neighborhood of the sump.
Ideally, flow should approach uniformly from all directions.
l 5.
Evaluate the extent to which the containmcnt sump (s) in your plant meet the requirements for each of the items previously identified; namely l
10-2 l
debris, inadequate NPSH, air entrainment, vortex forration, and operator actions.
The following additional guidance is pro!ided for performing this evaluation.
(1) Refer-to the recommendations in Regulatory Guide 1.82 (Section C) which may be of assistance in performing this evaluation.
(2)
Provide a drawing showing the location of the drain sump relative to the containment sumps.
(3)
Provide the following information with your evaluation of debris:
(a)
Provide the size of openings in the fine screens and compare this with the minimum dimensions in the pumps which take suction from the sump (or torus), the minimum dimension in any spray nozzles and in the fuel assemblies in the reactor core or any other line in the recirculation flow path whose size is comparable to or smaller than the sump screen mesh size in order to show that no flow blockage will occur at any point past the screen.
(b)
Estimate the extent to which debris could block the trash ract or screens (50 percent limit).
If a blockage problem is identified, describe the corrective actions you plan to take (replace insulation, enlarge cages, etc.).
(c)
For each type of thermal insulaticn used in the containment, provide the following information:
(i) type of material including composition and density, (ii) ranufacturer and brand name, (iii) method of attachment, 10-3 99@Q M e
(iv) location and quantity in containment of each type, (v) an estimate of the tendency of each type to form particles small enough to pass through the fine screen in the suction lines.
(d)
Ettimate what the effect of these insulation particles would be on the operability and performance of all pumps used for recirculation cooling.
Address effects on pump seals and bearings.
l l
l t
10-4 l
Equipment Qualification Branch Seismic Qualification Review Team Request for Additional Information 1.
In accordance with the requirements of GDC 2 a'nd 4 all safety-related equipment is required to be designed to withstand the effects cf carth-quakes and dynamic loads from normal operation, maintenance, testing and postulated accident conditions.
GDC 2 further requires that such equipment be designed to withstand appropriate combinations of the effects of normal and accident conditions with the effects of earthquake loads.
o The criteria to be used by the staff to determine the acceptability of your equ'ipment qualification program for seismic and dynamic loads are IEEE Std. 344-1975 as supplemented by Regulatory Guides 1.100 and 1.92, and Standard Review Plan Sections 3.9.2s 3.9.3 and 3.10.
State the extent to which the equipment in your plant meets these requirements and the above requirements to combine seismic and. dynamic loads.
For equipment that does not meet these requirements justifica.* ion will be needed for the use of other criteria.
2.
To confirm the extent to which the equipment important to safety meets the requirements of General Design Criterion 2 and 4, the Seismic Quali-fication Review Team (SQRT) will conduct a plant site review.
For selected equipment, SQRT will review the combined required response spectra (RRS) or the combined dynamic response, examine the equipment configuration and
.mo'.~ ting, and then determine whether the test or analysis which has been c
.ted demonstrates compliance with the RRS if the equipment was quali-fied by test, or the acceptable analytical criteria if qualified by analysis.
3.
In order to select equipment types for a detailed review it is necessary te obta,in a list of all eauioment important to safety.
Equipment should be divided first by system then by component type.
Attachment #1 shows a tabular format which should be followed to present the status summary of seismic and cynamic qualification of all equipment important to safet:..
Attachment =2 snows suggestec categories of component type to be listed in Attachment #1.
Provide a complete set of fiocr response spectra identifying their applicability to the equipment listed in Attachment #1.
After the information on Attachment #1 is received, a selection will be made of the equipment to be reviewed by the site audit.
Specific infor-mation on equipment selected for audit should be presented as shown on Attachment #3 which should be provided to the ilRC staff two weeks prior to the plant site visit.
The applicant should make available at the plant site for SQRT review 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 site audit is to confirm the acceptability of the seismic and dynamic qualification of all equipment important to safety based on the review of a few selected pieces.
If a number of 11-1
deficiencies are observed or significant generic concerns arise, the deficiencies should be re:noved for all equiprent important to safety subject to confirmation by a follow-up audit ',f randomly selected items before the fuel loading date.
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ATTACHMENT #2 EQUIPMENT CATEGORIES PUMPS:
MOTOR DRIV.E TURBINE DRIVE
t.'.VES :
MOTOR OPERATED HYDPAULIC PNEUt% TIC CHECK RELIEF FANS & DAMPERS:
HA' Ci.ING & LIFTIllG EQUIPMENT:
ELECTRIC MOTORS:
GEi;ERATORS :
ELECTRIC DIESEL MOTOR C0" TROL CENTERS:
S'.-l ITCH CEAR:
ELECTRICAL DISTRIBUTI0ii EQUIPMEN PO'.-lER CUSES TPANS FORMERS BATTERY RACKS IllSTRU!ENTATION AllD CONTROLS:
INSTRUMENT RACK COMPUTERS DISPLAYS GAGES SENSORS t
11-4 e-
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St.ismic and Dynamic Qualification Summary of Equipment 1.
Plant !!ame:
Type:
1.
Utility:
PWR 2.
?!SSS:
BWR 3.
A/E:
Other II.
Corponent ?!ame:
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.
Locati er.:
Building:
Elevation:
8.
Field l'ounting 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 11-5
1 11.
Pertinent Reference Design Specifications for Qualification Requirements:
a.
Seismic Input d.
Service Conditions
- b. - Hydrodynamic load I put e.
Qualified Life c.
Fatigue Considerations.
III. Is Eauipment Available for Insoection in the Plant:
[ ] Yes
[
] No
[
] Partial or limited availability IV.
Equipment Qualification 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:
V.
Vibration Inout:
1.
Loads considere,d:
a.
[
] Seismic only b.
[
] Hyorodynamic only c.
[
] Vibration from normal operation d.
[
] Comb.ination of (a), (b), and (c) 2.
Method of Combining RRS:
[
] Absolute Sum
[
] SRSS
[ ]
(other, specify) 3.
Required Response Spectra ** (attach the graphs):
NOTE:
^1f more than one report complete items IV thru VII for each report.
- If other than RRS is used, describe method.
11-6
s 4.
Damping Corresponding to RRS:
Required Acceleration in Each Direction:
[
] ZPA
[
] Other (specify)
OBE 5/5 =
F/B =
V=
SSE 5/5 =
P/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 Complete:
1.
[
] Single Frequency
[ ] Multi-Frequency:
[
] random
[ ] sine beat
[
]
2.
[
] Single Axis
[
] Multi-Axis
[
] Independent axis
[
] In phase motions
- 3. ~ Number of Qualifications Tests:
- Other (specify) 4.
Frequency Range:
s 5.
Natural Frequencies in Each Direction (Side / Side, Front /Back, Vertical):
5/5 =
F/B =
V=
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t 6.
Method of Determing Natural Frequencies
[
] Lab Test
[ ] In-Situ Test
[
] Analysis 7.
TRS enveloping RR5 using Multi-Frequency ' Test
[
] Yes (Attach TRS & RR5 graphs)
[
] No l
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11-7 l
8.
Maximum Input g-level Test:
OBE S/S =
F/B =
V. =
OBE S/S =
F/B =
V=
9.
Latroratory !!ounting:
A.
[
] Bolt (No.
, Size
)
[
] Weld (Length
)
[ ]
B.
Orientation and Fixturing:
10.
Functional operability verified:
[ ] Yes
[
] No
[ ] Not Applicable 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:
[
] Input Spectrum
[
] Fragility VII. If Qualification by Analysis, then cc plete:
1.
Method of Analysis:
[
] Static Analysis
[
] Equivaient Static Analysis
[ ] Dynamic Analysis:
[
]. Time History
[
] Response Spectrum 2.
Natural Frequencies in Each Direction (Side /Sih, Front /Back, Vertical):
5/5 =
F/B =
V=
3.
Model Type:
[
] 3D
[
] 2D
[
] 1D
[
] Finite Element
[
] Beam
[
] Closed Form Solution
[
] Other 11-8
[
4 4.
[ ] Computer Codes:
Frequency Range and No. of modes considered:
[ ] Hand Calculations 5.
Method of Combining Dynamic Responses from Seismic and other Dynamic Loads:
[ ] Absolute. Sum
[
] SRSS
[
] Other:
(specify) 6.
Damping:
OBE SSE Basis for the damping used:
7.
Support Considerations in the model:
8.
Critical Structural Elements:
Governing Load or Response Seismic Total Stress A.
Identification Location Combination Stress Stress Allowable B.
Maximum Allowable Deflection Max. Critical to Assure Functional Opera-Deflection Location bility 9.
Failure Modes:
10.
Margins Available:
[
] Input Spectrum
[
] Stress or Deflection
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11-9 l
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thaLuduxL 12
~
Dear Mr.
SUBJECT:
TMI-2 ACTION PLAN ITEM I.G.1 - SPECI AL LOW POWER TESTING NUREG-0737, " Clarification of TMI Action Plan Requirements," and NUREG-0694, "TMI Related Requirements for New Operating Licenses", Item I.G.1, calls for the implementation of "a special low power testing program approved by NRC to be conducted at power levels no greater than 5 percent for the purposes of providing meaningful technical information beyond that obtained in the normal startup test program and to provide supplemental training".
Some PWR applicants have comnitted to a series of natural circulation tests.
To date such tests have been performed at the Sequoyah 1, North Anna 2, and Salem 2 facilities.
Based on tne success of tne programs at these plants, the staff has concluded that augmented natural circulation training should be performed for all future PWR operating licenses. This is.to be implemen-ted by including descriptions of natural circulation tests in your FSAR (Chapter 14 - Initial Test Program).
If they are not already included in your FSAR, the natural circulation tests and associated training snould be included either by modifying existing or adding new test descriptions in accordance with Regulatory Guide 1.70, Paragraph 14.2.12.
The tests should fulfill the following objectives:
Training Each licensea reactor operator (R0 or SRO viho performs RO or SRO duties, respectively) should participate in the initiation, maintenance and recovery f rom natural circulation mode. Operators should be able to recognize when natural circulation has stabilized, and should be able to control saturation margin, RCS pressure, and heat removal rate without exceeding specified operating limits.
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 and without 12-1 onsite and offsite power, the ability to uniformly borate and cool down to hot shutdown conditions using natural circulation, and subcooling monitor performance.
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.
Procedure Validation The tests should make maximum practical use of written plant procedures to validate the completeness e,1d accuracy of the procedures.
The natural circulation tests require a source of actual or simulated decay heat. The tests may be performed during initial startup using nuclear heat to simulate decay heat, or may be performed later in the initial fuei cycle when actual decay heat is adequate to permit meaningful testing.
- f the test objectives are not compromised, pump heat during forced circulation operation could provide an acceptable source of simulated decay heat (e.g., the Loss-of-Onsite and Offsite A/C Test performed at North Anna 2).
Applicants who perform a natural circulation boron-mixing and cooldown test to demonstrate compliance with Branch Tecnnical Position RSB BTP 5-1 may use that test to accomplish some or all of the above training and testing objectives.
This guidance is provided for all PRR OL applicants.
Regulatory Guide 1.66 and /or the Standard Review Plan will be revised at a future date to include natural circulation testing and the associated training.
OL applicants should submit test descriptions in accordance with Regulatory Guide 1.70, Paragraph
' 14.2.12, as part of their FSAk or an amendment thereto.
Detailed test proce-dures should be made available for NRC review 60 days prior to scheduled test performance (see Regulatcry Guide 1.68, Appendix B). Knen required by 10 CFR 50.59, a safety analysis must be prepared and distributed in accordance with the requirements stated therein.
Sincerely, i
Robert L. Tedesco, Assistant Director t
for Licensing Division of Licensing i
l l
12-2