ML20036B969
| ML20036B969 | |
| Person / Time | |
|---|---|
| Site: | 05200001 |
| Issue date: | 05/28/1993 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Berglund R GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 9306070374 | |
| Download: ML20036B969 (5) | |
Text
46A c/Le ? &..f, ff UNITED STATES i ii
~'E NUCLEAR REGULATORY COMMISSION U
f WASHINGTON, D.C. 20555 0001 8
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May 28, 1993 Docket No.52-001 Mr. Robert C. Berglund, General Manager Advanced Reactor Programs GE Nuclear Energy 175 Curtner Avenue San Jose, California 95125
Dear Mr. Berglund:
SUBJECT:
ADVANCED BOILING WATER REACTOR (ABWR) TECHNICAL SPECIFICATIONS (TS)
ISSUES We are in the final phase of the review of the application for certification of the ABWR design.
As the scheduled date for completion of the final safety evaluation report (FSER) nears, it is essential that the staff provide feedback to GE Nuclear Energy (GE) on the quality and timeliness of applicant submittals.
Specifically, the development of instrumentation and control (I&C) technical specifications (TS) and the development of sound justifica-tions for. extended system and equipment outage times (completion times) for the ABWR need attention in order to reach prompt resolution.
Since 1991, the topic of TS development has been discussed at numerous meetings between the staff and GE. GE chose not to submit TS in advance of the Boiling Water Reactor Owners Group (BWROG) efforts under the Technical Specifications Improvement Program. This generic activity with the BWROG was completed in September 1992.
In order to not impact ABWR schedules, GE provided samples of draft TS for ABWR I&C systems between April and June 1992.
By letter dated November 17, 1992, the staff provided its review comments on the draft I&C sample TS. The staff determined that several issues naeded to be addressed to adequately reflect the I&C design. As of this date, GE has not responded to this letter. The' staff was surprised to learn that the cognizant GE design engineer had not seen the letter until last month.
Further, apparently he has been unable to fully support the I&C STS develop-ment because he has been assigned to other. higher priority work.
GE also provided proposed TS in the form of marked up standard technical specifications (STS) on February 1,1993 (less I&C and electrical). - On March 31, 1993, GE provided the electrical and I&C TS for the ABWR.
The staff's review of the March 31, 1993,. package is not yet complete. However, based upon our review to date, the staff will require significant interaction with GE and timely responses to questions to support TS review completion, including appropriate TS bases, by the end of August 1993.
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I Mr. Robert C. Betglund May 28, 1993 The next concern wth the GE-proposed TS deals with the technical basis for outage times.
In a June 27, 1992, meeting with the staff, GE maintained that the ABWR design, compared to the BWR-6 design, includes additional divisions and trains which could provide the potential for more flexibility of opera-
. tion. These design features could be the technical basis for longer outage times.
Based on this, GE proposed outage times in the TS submittals which
]
exceed those included in the standard TS.
Each of these differences must be justified based upon an annlysis of the additional design features which are relied upon during the extended outage times.
The staff conducted meetings and calls with GE staff and requested that :idditional justification be provided for the outaga times based on a risk-type analysis, as discussed in a letter to GE dated September 11, 1992.
In a letter dated April 22, 1993, GE provided a one-page discussion of the core damage frequency based on an engineering safety feature division being out of service. The staff provided i
feedback and indicated that in order for it to approve deviations from the standard TS completion times, GE would need to provide a much more thorough treatment of the subject. Absent appropriate justification, the staff will use the outage times for these systems specified in the BWR-6 or applicable generic STS.
Given the fact that closure of probaHlistic risk assessment issues is already on the critical path for completion of the ABWR FSER, I believe that risk-based justifications for ABWR TS will require additicnal technical resources from GE, if you wish to pursue extended outage times.
GE needs to decide to apply added resources to the ABWR TS process, drop extended completion times, or cmsider a schedule delay.
You should be prepared to discuss ABWR TS comph.0 ion (with emphasis on I&C issues) at the senior management meeting in June.
Sincerely, (Original signed by Jerry N. Wilson for)
Dennis M. Crutchfield, Associate Director for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/ enclosure:
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Docket File PDST R/F TMurley/FMiraglia WRussell PDR DCrutchfield RBorchardt CPoslusny SNinh SMagruder JNWilson ACRS (11)
J0'Brien, RES BHardin, RES LShao, RES GGrant, 17G21 JMoore, 15818 BGrimes, 11E4 AThadani, 8E2 FCongel, 10E2 4
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NAME: PShea CPollusny:tz BGrimes AThadani JRichardson Q
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DATE: 05/2 /93 05/3/93 05/27/93 05/28/93 05/28/93 N
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NAME:
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/T GE Nuclear Energy Docket No.52-001 cc:
Mr. Patrick W. Marriott,~ Manager Mr. Joseph Quirk Licensing & Consulting Services GE Nuclear Energy.
GE Nuclear Energy General Electric Company.
175 Curtner Avenue 175 Curtner Avenue, Mail Code 782 San Jose, California 95125 San Jose, California 95125 Mr. Robert Mitchell General Electric Company 175 Curtner Avenue San Jose, California 95125 Mr. L. Gifford, Program Manager Regulatory Programs GE Nuclear Energy 12300 Twinbrook Parkway Suite 315 Rockville, Maryland 20852 Director, Criteria & Standards Division Office of Radiation Programs U. S. Environmental Protection Agency 401 M Street, S.W.
Washington, D.C.
20460 Mr. Sterling Franks V. S. Department of Energy NE-42 Washington, D.C.
20585 Mr. Steve Goldberg Budget Examiner 725 17th Street, N.W.
Room 8002 Washington, D.C.
20503 Mr. Frank A. Ross U.S. Department of Energy, NE-42 Office of LWR Safety and Technology 19901 Germantown Road Germantown, Maryland 2087' Mr. Raymond Ng 1776 Eye Street, N.W.
Suite 300 Washington, D.C.
20006 Marcus A. Rowden, Esq.
Fried, Frank, tiarris, Shriver & Jacobson 1001 Pennsylvania Avenue, N.W.
Suite 800 Washington, D.C.
20004 Jay M. Gutierrez, Esq.
Newman & Holtzinger, P.C.
1615 L Street, N.W.
Suite 1000 Washington, D.C.
20036 t.
O ADVANCED B0ILING WATER REACTOR-(ABWR)-INSTRUMENTATION AND
-CONTROL-(I&C)-SYSTEMS TECHNICAL SPECIFICATIONS'.(TS)-
J PILOT REVIEW j
l Staff Comments-and Ouestions J
1.
Provide a description of each channel bypass capability thatLwill be-q included in the I&C safety systems.
For each. capability, specify' if, one individual -sensor can be bypassed, several' sensors,- and/or all. sensors 'in -
that channel. The draft description currently states. that all outputs ofl the DTM will be bypassed. Describe the bypass of the sensor inputs which do not use the DTM. Specify appropriate channel bypass LCOs.. Identify
-5 support and supported system operability relationships' of each channel bypass capability to the sensors, multiplexors, digital trip modules, trip logic unit, safety system logic unit, and _other components.
j 2.
Provide a listing or a matrix of the combinations of bypasses that GE is I
I proposing.
For each bypass combination, list the TS-required action for loss of redundancy and loss of function conditions.
{
3.
Provide justifications for TS surveillance' intervals. The RPS bases-state that the surveillance requirements will be essentially the 'same as for the BWR 6 STS.
Provide a justification for this similarity'(in accordance with the staff's evaluation of the BWR 6 topical reporte)_
given.that the I&C' equipment is significantly different., Include che, expected mean time between failures for components within the; system.
4.
Provide justification for indefinite bypass'of one RPS' instrumentation trip channel.
Include a description of the FMEA and PRA studies which support the indefinite bypass.
Identify the components.which would be bypassed. Also provide a listing of the ECCS functions which would also be in an indefinite two-out-of-three mode due to shared sensors,
-t multiplexors, etc. Provide verification that-single failure ~ criteria is maintained with one channel bypassed.
Provide an analysis of the affect of indefinite char.nel bypass on system reliability.
5.
Provide the TS allowable values.
6.
Provide the reference section for the TS bases.
Include the setpoint methodology reference.
Provide a description of the procadural method:
that GE proposes for including items (such as.setpoint n,t.Jodologies) that will be developed later via ITAAC or DAC.
~
7.
Change the units of measurement in.'the TS to be consistent with the SSAR notation.
r 8.
Provide a TS definition of " channel."
Include the combinations-of
" channels" that can be affected by degraded, bypassed, or. tipped condi-.
tion.
If necessary, distinguish between different " channel" combinations-using individual " channel"- definitions.
For example, a' single sensor-bypassed could be a bypass to the RPS and ECCS. A single multiplexor
" channel" failure could affect one channel of. the four channel:RPS-input, one channel of the four~ channel ECCS input, several inputs to'several-displays, and one actuation channel of the one, two, or three train.ECCS systems. A bypass at the RPS digital trip module does not affect the.two ESF digital trip modules for that channel.
g 9.
Provide a drawing with the channel designations clearly identified.
- 10. Describe the actions to be taken upon self-diagnostic alarms.
Specifi-cally, address the methodology to be used in making the determination that a particular device is operable or inoperable.
Identify which surveillances are automatic, manually initiated but automatically performed or manually performed.
Identify whether the surveillance is local or remotely performed.
11.
Provide the TS definition for failures which are attributed to software design errors.
Address the potential common-mode failure aspects.
Identify the appropriate LCOs for different categories of identified software design errors, based upon the impact of the. error on system (s) operability.
12.
Provide the LCOs for display equipment failures / bypasses, including remedial actions and completion times.
13.
Identify the affect of power supply failure on the " channel" designa-tions.
Evaluate both ac and dc bus loss.
14.
Provide a description of how the specific surveillance is'to be per-formed.
Control room monitoring, local indication, test computers, self-diagnostics, etc.
- 15. The ECCS instrumentation May 15, 1992, draft provides Table 3.3.5.1-2, which lists the function and the applicable modes and surveillance requirements.
SSAR Table 19.3-2 lists the success criteria for transient and LOCA events.
Some of the success paths (feedwater, fire protection system) are not included in the TS requirements.
Provide GE's selection criteria for determining what equipment is included in the TS.
16.
Identify instrumentation that actuate or realign safety systems as the result of monitored process parameter (s) exceeding their setpoints and whose operability requirements are not periodically verified as part of other TS instrumentation systems.
Provide instrumentation LCOs with appropriate configuration control,. including remedial actions and surveillance requirements for this instrumentation.
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