ML20045B816

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Discusses Review of SECY-93-087, Policy,Technical & Licensing Issues Pertaining to Evolutionary & Alwr Designs, Dtd 930402.Forwards Addl or Amplifying Comments Numbered Consistent w/SECY-93-087
ML20045B816
Person / Time
Site: 05200002
Issue date: 05/27/1993
From: Matzie R
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To: Chilk S
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20045B811 List:
References
NUDOCS 9306210122
Download: ML20045B816 (6)


Text

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. K E ASEA BROWN BOVERI May 27, 1993 Mr. Samuel J. Chilk .

Secretary

. Office of the Secretary U.S. Nuclear Regulatory Commission l Washington, D.C. 20555

Subject:

SECY-93-087, " Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light Water Reactor (ALWR) Designs

Dear Mr. Chilk:

[

This

~

ABB-CE has reviewed SECY-93-087, dated April: 2, 1993.

document has significant ramifications for our System 80+" ALWR .

design which is currently in the final phases of NRC. staff review We have bee'n in close for an FDA and Design Certification.

communication with the NRC staff on all. issues-pertaining to the '!'

review of System 80+ and have been working with-them to resolve those issues. We would like to.take this opportunity to offer.our preliminary comments on SECY-93-087.

ABB-CE has also reviewed the May 11, 1993. letter from'the Electric Power. Research Institute (EPRI) to Mr.- Crutchfield of the NRC staff, and we are in agreement with the views ~on SECY-93-087' expressed therein. Enclosed are' additional or amplifying comments-which are numbered consistent with SECY-93-087.

Thank you very much for taking the comments of EPRI and ABB-CE into -

account as you reach decisions on these important topics.

Very truly yours, L

90.1 R. A. Matzie y

Vice President Nuclear Systems Development ,

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Enclosure:

As Stated cc: J. DeVine (EPRI)

P. Lang (DOE)

K. Karr (INPO)

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ABB-CE COMMENTS ON SECY-93-087 Page.1 T

I.A - Use of a Physically Based Source Term ABB-CE strongly encourages the NRC and the industry to continue _ the implementation of the physically based source term, and we support  ;

EPRI's comments on this issue. ABB-CE is far along the-path of ,

~

implementation of the physically based source term on the. . .

System 80+5 design. Resolution of the " low . volatile" fission product issue as stated by EPFI would demonstrate even lower offsite doses and increase the likelihood of' improved ALWR emergency planning for System 80+ when the industry program moves '

in that direction. ,

II.I - Post Accident Sampling Systems )

Again, ABB-CE strongly endorses the remarks of EPRI in their May ,

11, 1993 letter and the arguments which they have put forth to the ,

NRC staff and ACRS on this topic previously.

ABB-CE believes that'the concerns set forth in SECY-93-087 (page-

42) to justify retaining the NUREG-0737 requirement for the PWR to take pressurized post-accident samples to analyze for dissolved' gases are not fully ' applicable to evolutionary PWRs in general, and System 80+ in particular. This is explained below:~ ,

STAFF CONCERN: The possibility exists of partially mitigated-severe accidents which do not involve early- reactor- t depressurization, as was demonstrated in the TMI-2 accident. '

ABB-CE RESPONSE: Safety-grade depressurization systems have been incorporated into evolutionary PWRs to address this possibility as a result of TMI lessons learned.

STAFF CONCERN: PWRs may have a problem in maintaining reliable natural circulation and decay heat removal in the presence of non-condensible gases that would evolve during depressurization. .The SECY-93-087 rationale goes on to explain that.this is'. basically a passive PWR staff concern because the passive plants "are highly dependent ~on natural circulation."

ABB-CE RESPONSE: The concern expressed has been addressed by an improved System 80+ Safety Injection System and reactor vessel head =

venting capability. Furthermore, ABB-CE has performed.a computer simulation of a natural circulation cooldown of the System 80+

Reactor' Coolant System (RCS)- from normal operation to -Shutdown cooling System (SCS) entry conditions. This simulation has been approved by the NRC and was performed in accordance with U.S. .NRC- -

Branch Technical Position (BTP) RSB 5-1. Potencial steam bubble i formation in the reactor vessel upper head is rigorously modeled, 6

ABB-CE COMMENTS ON SECY-93-087 Page 2 the concurrent loss of offsite power and a single failure. This analysis concludes the System 80+ RCS can be cooled and depressurized to SCS entry conditions in conformance with the BTP RSP 5-1 requirements. Once depressurized to shutdown cooling entry condition, the System 80+ RCS would use the SCS to provide forced cooling for decay heat removal. Similar analyses /operatione apply to other evolutionary PWRs.

STAFF CONCERN: Also, in these reactors, non-safety systems would need to be used to perform the final cooldown depressurization.

The reactors referred to are again passive PWRs.

ABB-CE RESPONSE: Evolutionary PWRs continue to use the safetv-grade SCS to continue cooldown and depressurization.

ABB-CE is concerned that the staff has not appropriately differentiated between the attributes of evolutionary and passive PWR designs related to this issue.

Since the review schedule of the passive plants is substantially behind the evolutionary plants, it is not fair to await resolution of the passive plant-related concerns to dictate the policy for the evolutionary plants. Ironically, if the passive plant applicants eventually prevail in getting this current requirement rescinded, the evolutionary PWR design could be locked into a pressurized sampling system design because it will already have an FDA and possibly a design certification.

It is not a trivial matter to design the post-accident sampling system to obtain and analyze pressurized samples. As reported in NUREG/CR-4330, the number of valves in the system can be reduced by a factor of ten if pressurized samples are not required (from 40 or 50 valves, to 4 or 5 valves). EPRI has determined that such a simplification results not only in a capital cost savings of approximately one million U.S. dollars per plant ($1M/ plant) , but also in a substantial reduction in operation and maintenance (O&M) costs. A simplified post-accident sampling system without pressurized sampling capabilities will be easier to put into operation during plant start-up, will eliminate expensive debugging problems encountered at existing facilities, and will require less maintenance, fewer modifications and less attention by the plant staff. In summary, ABB-CE believes that a requirement for pressurized sampling by the post-accident sampling system contravenes the conclusion of NUREG/CR-4330, and would result in an unnecessarily complex and costly design without a significant enhancement to safety.

Based on the arguments put forth by EPRI and the ACRS, ABB-CE requests the Commission to release all ALWR's from the requirements of 10 CFR 50.34 (f) (2) (viii) and item III.B.3 of NUREG-0737 related to having the capability to analyze dissolved gases and chloride.

If this is not possible, ABB-CE requests the Commission to

ABB-CE COMMENTS ON SECY-93-087 Page 3 recognize the differential between the evolutionary and passive PWR designs as it relates to the staff's stated concerns and delete this requirement for evolutionary PWRs.

II.D - Leak-Before-Break (LBB)

In the section entitled " Design Basis with LBB" SECY-93-087'(page 34 adaLes that "the broad scope rule introduced an acknowledged inconsistency into the design basis by excluding the dynamic- 7 ef fects of postulated pipe ruptures while retaining non-mechanistic:

pipe rupture for the containment, ECCS, .and environmental' qualification (EQ) of safety-related electrical and mechanical equipment." The SECY goes on to describe the distinction it draws between " local dynamic" and " global" effects from pipe ruptures. '

ABB-CE agrees with the distinction between local and global effects, but recommends that the actual maximum break . areas associated with failure of pump seals, valve packings, ' flanged connection, bellows, manways, rupture disks and branch' lines be-applied in the context of the " global" analyses. The maximum break  ;

areas are well defined for each ALWR.

This realistic application of break . sizes is particule .

appropriate in conjunction- with the ' core coolability. and containment pressure / temperature analyses .of - low probability, beyond design basis scenarios such as multiple failures in mechanical / fluid safety systems or common mode failures of digital protection systems.

-T II.M - Reliability Assurance Program (RAP)

ABB-CE agrees that the RAP should be divided into two stages (design and operational) and we agree ^that-ITAAC should not be developed for the RAP. However, we disaaree with the interim staff position on RAP which stipulates that "a high level commitment to .'

a RAP applicable to design certification (D-RAP) should be required as a non-system generic Tier 1 requirement'..."

ABB-CE has provided a description of the design reliability assurance program - (D-RAP) in CESSAR-DC ' which meets the , design associated goals of the RAP as outlined in SECY-93-087. We believe that this commitment to D-RAP is sufficient.- The D-RAP is only one of a series of programs which the COL holder will;use to properly design, construct, operate, test and maintain the plant such that the reliability of the original design is retained. It was not'our initial intention to include the' RAP description in the SAR. We

believe that the D-RAP is in the category of _ Operating 1 Support Information which is between the designer .and l the ; operator and i which should have the flexibility to develop according to the requirements of the end user. Based-on the NRC staff's request,  ;

4 ABB-CE COMMENTS ON BECY-93-087 Page 4 requirements of the end user. Based on the NRC staff's request, ABB-CE incorporated the D-RAP description previously submitted on the System 80+ docket into CESSAR-DC in February 1993. Now the staff is requesting that design certification applicants make the D-RAP a Tier 1 commitment.

The criteria for inclusion in Tier 1 is principally based on the level of safety importance. However, the D-RAP does not have the same level of safety importance as the issues which the staff and industr; have previously agreed belong in the Tier 1 category.

This is particularly the case for evolutionary ALWRs.

Elevation of the D-RAP to Tier 1 in the design certification rulemaking process provides enforcement authority to the staff to ensure that the terms of the D-RAP are rigidly maintained. This creates justifiable concerns on the part of potential purchasers of these ALWR designs that a plant could be shutdown if some measure of the reliability of a risk-significant structure, system or component decreased below the value assumed in the PRA regardless of the overall safety of the plant. While all parties to the SECY-93-087 decision-making process would agree today that there is no such intention, elevation of D-RAP to Tier 1 status may provide the groundwork for that type- of future contention and is thus destabilizing from a licensing perspective.

A Tier 1 D-RAP commitment is not necessary to ensure that the design can be constructed and operated safely as some may argue.

Safe operation as related to the design is assured through Tier 1 systems and structures certified design commitments and their associated ITAAC, commitments in Tier 2, as well as the plant's Technical Specifications and Emergency Operating Procedures and compliance with NRC regulations including the maintenance rule.

The relationship of the RAP and the maintenance rule is still undefined, but it is possible that the activities related to the maintenance rule may encompass the D-RAP. Elevation of D-RAP to' Tier 1 might, however, create unforeseen conflicts at the regulation level since neither program has yet been implemented.

It does not seem rational to us that there be a generic Tier 1 program commitment without having a demonstrable acceptance criteria. However, following much prior effort and a prolonged debate between industry and NRC staff, it was concluded that acceptance criteria which are both meaningful and unambiguous cannot be written for programmatic topics such as the D-RAP. It seems inevitable to ABB-CE that if there is a generic Tier 1 commitment to the D-RAP, it will lead to the need for a demonstrable acceptance criteria.

ABB-CE requests that the Commission disapprove inclusion of the D-RAP in Tier 1.

. _~ ___. _ _ .__

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  • ABB-CE COMMENTS ON BECY-93-087 Page 5 III.G - Simplification of Offsite Emergency Plan.4ing:

ABB-CE agrees with and has actively supported the ALWR program initiative on simplified emergency planning, which is coordinated by EPRI. We note a recent letter from the ALWR Utility Steering Committee Chairman to the NRC which states, " ... any ALWR, includina evolutionary olants, (emphasis added) should have the opportunity to demonstrate that it meets the criteria and thus be carr M arad #nr ALWR emergency planning."

ABB-CE has examined the technical bases and criteria being developed in the ALWR program and has evaluated the System 80+

design against those criteria. Results have been submitted to the NRC staff and have been included in CESSAR-DC. As expected, the active safety systems such as containment spray show the robustness of the design and demonstrate that System 80+ easily meets the Protective Action Guideline of 1 rem whole body dose at the site boundary. Since this issue is equally applicable to both passive and evolutionary designs, it is recommended that issue III.G (Simplification of Offsite Emergency Planning) be presented in

  • Section II of SECY-93-087 which addresses "Other Evolutionary and Passive Design Issues" to avoid the implication that it is applicable to only the passive designs.

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