ML20046C730

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Forwards Draft Safety Issues Index,Generic Issue Review Assignments,Status of ABWR USI-GSI Review & Staff Comments Provided During Conference Calls
ML20046C730
Person / Time
Site: 05200001
Issue date: 07/21/1993
From: Joshua Wilson
Office of Nuclear Reactor Regulation
To: Marriott P
GENERAL ELECTRIC CO.
References
NUDOCS 9308120019
Download: ML20046C730 (21)


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July 21, 1993 Docket No.52-001 i

I Mr. Patrick W. Marriott, Manager Licensing & Consulting Services GE Nuclear Energy 175 Curtner Avenue San Jose, California 95125

Dear Mr. Marriott:

-l

SUBJECT:

STAFF REVIEW COMMENTS ON GENERIC ISSUES RELATED TO THE ADVANCED BOILING WATER REACTOR (ABWR) DESIGN GE Nuclear Energy (GE) provided submittals on April 30, May 4 and 18, and July 2,1993, and a facsimile on July 8,1993 (provided as Enclosure 1) addressing unresolved safety issues (USIs) and generic safety issues'(GSis) for the ABWR. As part of its' review of these documents, the staff has-held four telephone conference calls to obtain additional information and discuss needed standard safety analysis report (SSAR) changes for a number of issues.

On July 15, 1993, GE submitted revised SSAR mark-ups for several issues; however, the staff has not completed its review of this submittal.

The staff conducted conference calls with' GE on June 17 and 25, and July 2 and 9, 1993, to discuss the staff's comments on task action plan items, new generic issues, and human factors issues under the cognizance of the following-review branches: Civil Engineering and Geosciences, Electrical Engineering, Reactor Systems, Performance and Quality Evaluation, Instrumentation and j

Controls, Human factors Assessment, Radiation Protection, and Safeguards-(see

' ). The staff also provided some general comments on the Three Mile-Island (TMI) Action Plan items during these conversations.

The results of these calls and the staff's review of GE's July 2,1993, submittal regarding task action plan items, new generic issues, and human...

factors issues as of July 13, 1993, are summarized in Enclosure 3.

This shows

-that of the 44 individual issues discussed in detail so far, GE needs.-to provide SSAR mark-ups for at least 26 issues (GE'.s July 15 submittal provided i

mark-ups for 9 of these). also indicates that an additional four

~ issues may require mark-ups based on the resolution of. related ABWR open items, discussions for which are presently under way.-

The staff expects to be ready to discuss the 23 listed Plant Systems Branch items and remaining comments on the TMI Action Plan items in the near future.

To facilitate your preparation of SSAR mark-ups to resolve the staff's 1

comments and/or responses to staff questions, Enclosure 4 outlines the concerns discussed during the conference calls which need to be addressed.

930812oo19 930721

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e Mr. Patrick W. Marriott July 21,1993 GE's complete resolution of the staff's concerns in and prompt turnaround of mark-ups and provision of other requested information is essential to main-taining the ABWR review schedule.

1, which is a draft update of the Safety Issues Index that will be j

included as Table 198.1-1 of the ABWR SSAR, lists the titles of the issues addressed in the other enclosures. The staff has annotated this draft, as 1

committed to GE in the July 9 conference call, to indicate apparent errors which GE should also consider in completing its work on generic issues.

Should you have any questions or desire further discussion on the information provided in this letter, please contact either Melinda Malloy, (301) 504-1178, or Chet Poslusny, (301) 504-1132.

Sincgrg, Jerry N. Wilson, Acting Director Standardization Project Directorate Associate Directorate for Advanced Reactors l

and License Renewal Office of Nuclear Reactor Regulation

Enclosures:

1.

Annotated Revised SSAR Table 19B.1-1 (Draf t),

Faxed to M. Malloy on 7/8/93 i

2.

Generic Issue Review Assignments By Branch (Rev. 5 - 7/13/93) i 3.

Status of ABWR USI-GSI Review as of 7/16/93 4.

Staff Comments Provided During Conference Calls cc w/ enclosures:

See next page i

Distribution w/ enclosures:

Docket-File _

PDST R/F DCrutchfield JNWilson l

PDR RBorchardt MMalloy CPoslusny l

SNinh SKoenick DTerao HBrammer DThatcher JLyons WBurton MRubin GThomas RGramm RCorreia TPolich MChiramal JStewart CGoodman REmch JLee RDube FYoung MWohl MFinkelstein,15B18 PShea Distribution w/o enclosures:

TMurley/FMiraglia WRussell JMoore, 15818 CGrimes ATGody, Jr.,17G21 ACRS (11)

JWiggins GBagchi AThadani/MVirgilio CBerlinger RPerch CMcCracken ERossi/RZimmerman RJones WBeckner AEl-Bassioni GZech JWermiel REckenrode BBoger/CThomas LCunningham PMcKee BGrimes FCongel/EButcher jrr-(9 C$

OFC:

LA:PD ADARftf:PDST: ADAR PM:PDST:ADAR SC:PDST:ADAR ().

T:ADAR i

NAME: PShead MMalloy CPoslusny RBorchardt JNWil on i

r DATE: 07 # 1/9 07/ji/93 07/M/93 07/M/93 07/3/93 f

0FFICIAL RECORD COPY: GI-LTR.MM

=

Mr. Patrick W. Marriott Docket No.52-001 i

General Electric Company I

4 cc:

Mr.' Robert Mitchell Mr. Joseph Quirk l

l General Electric Company GE Nuclear Energy 175 Curtner Avenue General Electric Company San Jose, California 95125 175 Curtner Avenue, Mail Code 782 I

San Jose, California 95125 l

Mr. L. Gifford, Program Manager Regulatory Programs Mr. Raymond Ng j

GE Nuclear Energy 1776 Eye Street, N.W.

12300 Twinbrook Parkway Suite 300 Suite 315 Washington, D.C.

20006 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 U.S. Department of Energy NE-42 Washington, D.C.

20585

-l Marcus A. Rowden, Esq.

Fried, Frank, Harris, Shriver & Jacobson i

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 Mr. Steve Goldberg i

Budget Examiner 725 17th Street, N.W.

Room 8002

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Washington, D.C.

20503 Mr. Frank A. Ross U.S. Department of Energy, NE-42 i

Office of LWR Safety and Technology

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19901 Germantown Road Germantown, Maryland 20874 1

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c JLi. OS '93 10:17A'1 G E ttCLEAR BLDG J P.2/6 ABWR 2 mms Standard Plant Table 19B.1-1 SAFETY ISSUES INDEX i

NRC SSAR Title Priority Subsection Centric htnet A 1 WaterHammer Resolved 19B12 A 7 MarkIlong-Term Program Resolved 193 13 A-B MarkIContainmentPoolDpamicLoads 14ngTerm Program Resolved 19B.24 A 9 ATWS Resolved 19B2.5 A-10 BWR Fecdwater Nozzle Cracking Resolved 19B2.6 A 13 Snubber Operability Assurance Resolved 19B 17 A-24 Qualification of Class 1E Safety Related Equipment Resolved 19B18 A.25 Non Safety Loads on Class 1E Power Sources Resolved 19B19 A-31 RHR Shutdown Requirements Resolved 19B.210 A-35 Adequacy of Offsite Power Systems Resolved 19B111 A-36 Control of Heavy Leads Near Spent Fuct Resolved 19B112 A-39 Determination of Safety Relief Valve Pool Dynamic Loads and Temperature Limits Resolved 19B113 3

A-40 Seismic Design Criteria - Short Term Program Resolved 19B 114 A-42 Pipe Cracks in Boiling Water Reactors Resolved 19B115 A-44 Station Blackout Resolved 19B.2.16 A 47 Safety implications of Control Systems Resolved 193117 A 48 Hydrogen Connol Measures and Effects of Hydrogen Bums on Safety Equipment Resolved 19B.2.18 I

B-10 Behavior of BWR Mad Ill Containments Resolved 19B119

- B 17 Critena for Safety-Related Operator Actions fdclh/m C ^'

-OOL.'_p;. S 6 AL Jto B 36 Develop Design,TcSting and Maintenance Criteria for Atmosphenc Cleanup System Air Filtration and Agsorpuon q Units for Engineered Safety Feature Systems and for Normal Ventilation Systems Resolved 19B121 B-55 Improved Reliability of Target Rock Safety Relief Valves N/%.b:4 19B.222 B 56 DieselReliability 141igh Lavd 19B123 B-61 Allowable ECCS Equipment Outage Periods Resolved 19B124 B-63 Isolation of Low Pressure Systems Connected to the Reactor Coolant fressine Boundary Resolved 19B.2.25 B-66 Control Room Infiltration Measurements Resolved 19B,2.26 C-1 Assurance of Continuous 14ng Term Capability of Hermetic Scals on Instrumentation and Electrical Equipment Resolved 19B.227 i

C 10 Effective Operation of Containment Sprays in a LOCA Resolved 19B.2.28 C-17 Interim Acceptance Criteria for Solidification Agents for Radioactive Solid Wastes Resolved 19B.229 New Generic funee 15 Radiation Effects on Reactor Vesse! Supports High 19B130 23 Reactor Coolant Pump Seal Failures High 19B.231 25 Automatic Air Header Dump on BWR Scram System Resolved 19B132 40 Safety Concems Associated with Pipe Breaks in the BWR Scram System Resolved 193.233

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Amendment

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4 JUL OB '93 10 IBAM G E NUCLEAR BLDG J P.3/6 J

I:@FT' ABWR mes Standard Plant l

Table 19B.1-1 l

SAFETY ISSUES INDEX (Continued) i NRC SSAR Title Priority Subsection New Generic Issues (Continued) 45 Inoperability ofInstrumentation Due to Extreme Cold Weather Resolved 19B.234 51 Proposed Requirements for Improving the Reliability of Open Cycle Service Water Systems Resolved 19B.235 57 Effects of Fire Protection System Actuation on Safety-Related Equipmentilhdh;"dd 193.236 6733 Improved Accident Moni}oring Resolved 19B.237 73 ihmir;d TraiiuG DGe deJeM, & CorWetstf,% ej 6C

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75 Generic Implications of ATWS Events at the Salem Nuclear Plant Resolved 19B.238.,

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78 Monitoring of Fatiguc Transient Limits for Reactor Coolant System Thedh "-

'"M 19B.239

--99-Urd'rd Reestee-VesselSr' c'-P %- PM

' t... d Q eidewn dL/t.444 y ermidsahm d 6C = 7]t/u T r'-f

2rn!

83 Control Room Habitability ftsbla. New Res.

19B.240 86 Long Range Plan for Dealing with Stress Corrosion Cracking in BWR PipinF Resolved 19B.2.41 87 Failure of HPCI Steam Line Without Isolation Resolved 19B.2A2 89 Suff Pipe Clamps Medium 19B2.43 103 Design for Probable Maximum Precipitation Resolved 19B.2.44 105 Interfacing Systems LOCA at BWRs High 19B.2A5 106 Piping and Use of Highly Combustible Gases in Vital Areas Medium 19B.2A6 11R Tendon Anchorage Failure Resolved 19B248 120 On.LineTestability or rrotecuon systems Rey,pc4 Medown us.4.4n L 121 Hydrny cent for Larce, Dry PWR Containments Resolved 19B.2.50 124 Auxihary Feedwater System Reliability xcsonco us.&

128 Electrical Power Reliability Resolved 19B.2.52 i

142 Leakage Through Electrical isolators in Instrumentation Circuits Medium 19B.2.53 141 Availability of Chilled Water Systems nd ".;cm C;J...;

High 19B.2.54

'";Qn;4eRedoes;p----.a-. C Q.nq'R6 Ats. AMl.

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151 Reliability of A.urJ Tzr~: W: h Redrculadon

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LPump Trip Ikr;e9 An MW.S RewiveA 19B 2 56 ;

1 153 Loss of Esxnnil Service Water in LWRs Hfgh 19B.2.57.

I 155 Ecs. AAl.

Nenea.

19B.2.58 N rwe 1 More Realistic Source Term AssumptionsIurMila.wce c4 96.rfvp Ted; f

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Human Factors Issuet HF.1.1 shift Staffing Resolved COL App.

HF.4.4 Guidelines for Upgrading Other Procedures High COL App.

l HF.5.1 Local Comrol Stations High COL App.

HF.5.2 Review Criteria for Human Factors Aspects of l

Advanced Controgd Instrumentation.

High COL App.

Isfurs Resolved With No New Reoulrements l

A-17 SystemsInteraction M N#lesr be Plad Resolved 19B.2.59 A-29 Nudest Power Plant Design for Reduction of Vulnerahility 3

to Industrial Sabotage Resolved 19B.240 a

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l JUL 09 o93 20:18T! G E KJCLEAR BLDG J P.4/6 3" RAf5 T~

l ABWR unim s l

Standard Plant h : More. N 4d N Table 19B.1-1 SAFETY ISSUES INDEX (Continued)

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yp6cd He.cs 6 NRC, eM I wMs4 W Priority Subsectioitgj

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Title Innet Resolved With No New Recuirements (Continuedi i

B 5 Ductility of Two Way Slabs and Shells and Buckling Jehavior of Stcc! Containments Resolved 19B.2.61 29 Bolting Degradation or Failare in Nuclear Power Plants Resolved 19B.2.62 S2 Beyond Designgs/s Accidents m Spent Fuci Poois Resolved 19B.2.63 I13 Dynamic Qualmcation Testing of Large Bore Hydraahc Snubbers Resolved 19B.2.64 L 09 M 9Cm U l.4A CsM

% - Resolvea(.

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TMT Intnet LA.I.1 ShiftTechnical Advisor Resolved COL.'.pp. 173,is, f i

! A.I.2 Shift Supenisor Administrative Duties Resolved C.^ pp. /98 3.)

LA.13 ShiftManning Resolved eGb4pp f9g,g,j I.A.I.4 Long-Term Upgrading Resolved COL App. f 94 y,j LA.2.l(1) Qualifications-Experience Resolved C *+p.f 9 g, y,j

.r LA.2.1(2) Training Resolved M.'pp. j94 g I.A.2.1(3) Facility Cenification of Competence and Fitness of Applicants.ar Operstor and Senior Operator Licenses Resolved CE Ayy. /94.3./

LA.23 Administration of Training Programs Resolved COL.'.pp. f tg,3,/.

I.A.2.6(1) Revise Regulatory Guide 1.8 Resolved COL App. ssyg.3,/

LA.3.1 Revise Scope of Criteria for Licensing Examinadons Resolved CA sy.- f fg,3 /

LA.4.1(2) Interim Changes in Training Simulators Resolved O,^.m' fe;.j9g,3,j I.A.4.2(1) Research on Training Simulators Resolved 19A.2.13 1.A.4.2(2 ) Upgrade Trainmg Simulator Standards Resolved 19A.2.13 LA.4.2(3) Regulatory Guide on Training Simulators Resolved 19A.2.13.

LA.4.2(4) Review Simulators for Conformance to Criteria Resolved 19A.2.13 LC.1(!) Small Break LOCAs Resolved C !.pp./94.2./

l LC.l(2) Inadequa.e Core Cooling Resolved CE '.;;. /96. 3 */

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!.C.1(3) Transients and Accidents Resolved 1A.2.1 I.C.2 Shift and Relief Turr.over Procedures Resolved COL f.gg. /14.1./

1.C.3 Shift Supervisor Responsibilitics Resolved tet-Ar9. /96,3. /

l LC.4 ControlRoom Access Resolved C^' App. / 9d,3,j I.C.5 Pmcedures for Feedback of Operating Experience to Plant Staff Resolved 1

2.41 LC4 Procedures for Verification of Correct Performance of Operating Activities Resolved GQL. App. 196,1,/

l LC.7 NSSS Vendor Review of Procedures Resolved OOL App. /96.3,/.

LC.B PilckMonitoring of Selected Emergency Procedtres for Near-l Term Operating License Applicants.

Resolved CCL4p./96.3./

LD.1 Control Room Design Reviews Resolved 1A.2.2 LD.2 Plant Safety Parameter Display Console Resolved IA.2.3

. LD.3 Safcty System Status Monitoring Medium 19A.2.17 LD.5(2) Plant Status and Post Accident Monitoring Resolved 19B.2.65 -

I.D.5(3) On-Line Reactor Surveillance System dis:1,lc Nees.Res.

19B.2.66 LF.2(2) Include QA Personnel in Review and Approval of Plant Procedures Resolved 19A.2.43 LF.2(3) Include QA Personnel in [11 Design, Construction, Installation.Tesung, and Operation Activities Resolved 19A.2.43 F

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Am=dmm 19B.14 i

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51L OB '93 80t19AM G E ffJCLEAR BLDG J P.5/6 ABWR m as Standard Plant N

Table 19B.1-1 SAFETY ISSUES INDEX (Conlinued)

NRC SSAR-Title Priority Subsection TMI Issues (Continuedi

. LF.2(6) Increase the Site of Licensees' QA Staff Resolved 19A.2.43 1.F.2(9) Clarify Organizational Reponing Levels for the QA Organization Resolved 19A.2.43 1.G.1 Training Requirements Resolved 1.A14 LG.2 Sco;c of TestProgram Resolved 19B.2El ILB.1 Reactor Coolant System Vents Resolved 1A.2.5 II.B.2 Plant Shieldmg to Provide Access to Vital Areas aid Protect Safety Equipment for Post-Accident Operation Resolved 1A16 D.B.3 Post. Accident Sampling Resolved 1 A.2.'l II.BA Training for Mitigadng Core Damage Resolved CO*.,'.pp./98.7./

11.B.8 Rulemaking Proceeding on Degraded Core Accidents Resolved 19A.2.21 11.D.1 Testing Requirements Resolved 1 A.2.9 II.D.3 Relief and Safety Valve Position Indication Resolved 1A 110 II.E.1.3 Update Standard Review Plan and Develop Regulatory Guide Resolved CCa.my. /%8.I./

D.E.4.1 DedicatedPencitations Resolved 1A113 U.E.4.2 Isolation Dependability

. Resolved 1A114 11.E.6.1 Test Adequacy Study Resolved 19B168 II.F.1 Additional Accident Monitoring Instrumentation Resolved 1A115 D.F.2 Idemification of and Recovery from Conditions Leading to Inadequate Core Cooling Resolved 1A116 11.F.3 Instruments for Monitoring Accident Conditions Resolved 1A117 DJ.4.1 Revisc Deficiency Reporting Requirements Resolved'94.2.Vh /g.

e D.K.l(5) Safety.Related Valve Position Description Resolved 1A.2.18 II.K.1(10) Review and Modify Procedures for Removing Safety-Related Systems from Service Resolved 1A.2.19 II.K.1(13) Propose Technical Specificatio[ Changes Reflecting implementation of A11 Bulletin Items Resolved 19B.2fG-II.K.1(22) Desenbe Automatic and Manual Actions for Proper Functioning of Auxiliary Heat Removal Systems When FW System Not Operable Rcsohed 1A.2.20 II.K.1(23) Describe Uses and Types of RV LevelIndication for Automatic and Manual Initiation Safety Systems Resolved 1A 121 3,x. 300 4HsG) Repon Safety and Rchef Valve Failures Prompt:y and Challenges Annually Resolved 1 A.2.21.1 II.K3(11) Control Use of PORV Supplied by Control Comnponents, Inc. Until Further Review Complete Resolved 19B170 H.K.3(13) Separation of HPCI and RCIC System Initiation Levels Recolved 1 A.2.22 D.K.3(15) Modify Break Detection Logic to Prevent Spurious isolation of HPCI and RCIC Systems Resolved 1 A.2.23 11.K.3(16) Reduction of Challenges and Failures of Relief Valves-Feasibility Study and System Modification Resolved 1A.2.24 II.K.3(17) Report and Outage of ECC Systems - Licensee Report and TechnicalSpecification Changes Resolved 1A125 11.KJ(18) Modification of ADS logic-Feasibilhy St.Jy snd Modification for Increased Diversity for Some Event Sequences Resolved 1A.2.26 II.K.3(21) Restart of Core Spray and LPCI Systems on Low Level-Design and Modification Resolved 1 A.2.27

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JUL 09 '93 20r19cei G E ff. CLEAR BLDG J P.6/6 ABWR mums Standard Plant Table 19B.1-1 SAFETY ISSUES INDEX (Continued)

NRC SSAR Title Priority Subsection TMI Issues II.K3(22) Automatic Switchover of RCIC System Suetion - Verify Procedures and Modify Design Resolved 1A228 ILK 3(24) Confirm Adequacy of Space Coohng for HPCI and RCIC Systems Pesolved 1A2.29 H.K3.(25) Effect of Loss of AC Power on Pump Seals Resolved 1A.230 H.K3(27) Provide Common Reference 1.evel for Vessel Lcyc1 Instrumentation Resolved 4A f,"//M.2.11 H.K3(28) Study and Verify Qualification of Accumulators on ADS Valves Resolved 1A331 II.K3(30) Pevised Small. Break LOCA Methods to Show Compliance

~-

wie 10 CFR 50. Appendix K Resolved 1A.232 II.K3(31) Plant-Specific Calculations to Show Compliance wis 10 CFR 50.46 Resolved 1A.233 11.K3(44) Evaluation of Anticipa:ed Transients with Single Failure to Venfy No Sigmficant Fuel Failure Resolved 1 A.233.1 II.K3(45) Evaluate Depressuriaation with Other Than Full ADS Resolved /fA.a.itl A2.33.1 II.K3(46) Respon>e to List of Concems from ACRS Consultant Resolved 1A.2333 m.A.I.1(1) Implement Acdon Plan Requirements for Promptly Improving Licensee Emergency Prepardness Resolved COL App. tid.J./

Bl.A.1.2(1) Technical Support Center ResolvedN.7.376% App Hl.A.1.2(2) On Site Operational Support Center Resolved /902.17eOh Apjk m.A.1.2(3) Near. Site Emergency Operations Facility Resolved %Z.MGOlrApr m.A.2.1(1) Publish Proposed Admendments to the Rules Resolved COL App. /9 6.7./

m.A.2.1(2) Conduct Public Regional Meetings Resolved GOirApp /f,a.p./

m.A.2.1(3) Prepare Final Commission Paper Recommending Adoption of Rules Resolved COL /.pp. /9,d.7 /

III.A.2.l(4) Revise Inspection Pmgram to Cover Upgraded Requirements Resolved COL 47. /98 3*/

m.A.2.2 Development of Guidance and Criteria.

Resolved 00L-App. /M. J./

UI.A33(1) Install Duect Dedicated Telephone Lines Resolved COL ?.pp. f M. 5./

III.A.33(2) Obtain Dedicated, Short-Range Raio Communication Systems Resolved COL /.pp. /78.7./

m.D.1.1(1) Review Information Submitted by Licensee Pertaming to Reducing Leakage from Operating Systems Resolved 1A.234 III.D33(1) Issue Lener Requiring Improved Ratation Sampling Instrumentation Resolved 19A.239 m /M 2 7A [

ID.D33(2) Set Criteria Requinng Licensees to Evaluate Need for Aditional Survey Equipment Resolved 19A.239 cv #9d.2.73f m.D33(3) IS$ue a Rule Change Providing Acceptable Methods for Calibration of Radiation-Monitoring Instruments Resolved 19A.2.39 I11.D.33(4) Issue a Regulatory Guide Resolved 19A.2.39 III.D3.4 Control Room Habir. ability Resolved 1A236

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Amnd:ncs 19B.1

i i

' TASK ACTION PLAN ITEMS, NEW GENERIC ISSUES, AND HUMAN FACTORS ISSUES APPLICABLE TO ABWR ASSIGNMENTS BY NRR REVIEW BRANCH (Revision 5 - July 13,1993)

ECGB EELH SPLB SRXB SPSB RPEB HICH HHFB PRPB PSGB OTSB l

A-1 A-17*

A-7 A-9 A-17*

75 A-47 A-47*

C-17*

A-29 B-61 A-10 A-24*

A-8 A-31 B-61*

145 B-17*

B-17 155.1 A-13 A-25 A-17 B-61*

153*

45 67.3.3*

1 A-40 A-35 A-24 23 67.3.3 75*

j A-42 A-44 A-36 25*

75*

HF 1.1 B-5 A-47*

A-39 40 120 HF 4.4 B-55 B-56 A-48 87 142 HF 5.1 B-63 128 B-10 105 151 HF 5.2 i

C-8 B-36 15 B-66 29 C-1 i

400 C-10 78 C-17 I

86 25 i

87 51 89 57 j

103 82 105*

83 113 106 218 121 124 143 153 ODenotes secondary reviewer responsibility Review Branch Key:

ECGB - Civil Engineering and Geosciences Branch 1

EELB - Electrical Engineering Branch SPLB - Plant Systems Branch SPSB - Probabilistic Safety Assessment Branch RPEB - Performance and Quality Evaluation Branch HICB - Instrumentation and Controls Branch HHFB - Human Factors Assessment Branch PRPB - Radiation Protection Branch PSGB - Safeguards Branch OTSB - Technical Specifications Branch i

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STATUS OF ABWR USI-GSI REVIEW AS OF 7/13/93 (Task Action Plan items, New Generic issues, and Human Factors issues Only)

Issues that do not need further GE input -- 13 Branch issues ECGB A-1, A-13, A-42, B-63,15, 86, 87,103,118 SRXB 23 EELB A-35 HICB 45,120 issues for which GE needs to provide originalor revised SSAR mark-ups -- 26 Branch issues ECGB*

A-10, A-40, B-5, B-55, C-8 (original mark-up), 29,78,89,113 EELB A-25, B-56,128 SRXB A-31, 40 RPEB 75,145 HICB A-47, 67.3.3,142,151 HHFB B-17, HF 1.1, HF 4.4, HF 5.1, HF 5.2 PRPB 155.1 PSGB A-29 issues for which resolution or GE submittal of revised SSAR mark-up is on hold pending resolution of other related ABWR open items (issue mark-up will need to be consistent with open item resolution) -- 4 I

Branch Issues EELB A-44 SRXB A-9,105

)

OTSB B-61 i

Issues not yet discussed with GE -- 23 1

Branch issues SPLB A-7, A-8, A-17, A-24, A-36, A-39, A-48, B-10, B-36, B-66, C-1, C-10, C-17, 25, 51, 57, 82, 83,106,121,124,143, i

153 1

"GE submitted revised SsAR mark-ups for these nine issues on July 15,1993. The staff has not completed its review of this submittal

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- STAFF COMMENTS ON PROPOSED RESOLUTIONS OF GENERIC ISSUES.

FOR THE'ABWR PROVIDED DURING CONFERENCE CALLS WITH GE Conference Call on June 17,1993, on Generic issues Assigned to the Performance and Quality Evaluation Branch (RPEB)

Issue 75 (GE submittal dated 4/30/93, SSAR Section 19B.2.38):

1.

Based on the staff's knowledge of the Advanced Boiling Water Reactor.

(ABWR) design, the statement in the first sentence of the GE Nuclear 1

Energy (GE) resolution [that the reactor protection system design pro---

vides the capability for the ABWR to fully satisfy all Generic Letter (GL) 83-28 and NUREG-1000 requirements]is not entirely true. (The word

" fully" in the sentence makes it not entirely true.) Revise as appropriate i'

to be reflective of actual circumstances.

2.

The resolution statement regarding GL 83-28 is an assertion that does not provide sufficient information upon which the staff may base a conclusion. GE should explicitly address how the ABWR will satisfy the 1

four facets of this issue which are stated in the GE acceptance criteria, i

as follows.

The plant must have a program for a post-trip review of l

unscheduled reactor shutdowns.

The plant must have a program for safety-related equipment e

classification and vendor interface.

l The plant must have a program for post-maintenance operability testing.

]

The plant must have a program to control vendor-related modifi-e cations, preventative maintenance, and surveillance for reactor j

trip breakers.

j 3.

The statement in the GE resolution regarding the anticipated transient without scram rule (10 CFR 50.62) does indicate how satisfying the rule i

contributes to resolving this issue for the ABWR.

Issue 145 (GE submittal dated 5/18/93, SSAR Section 198.2.55):

1 The GE resolution of this issue should be addressed in the context of the ABWR Reliability Asse:ance Program.

i i

i

,V; j

l Conference Call on June 17,1993 on Generic issues Assigned to the Human l

Factors Assessrnent Branch (HHFB)

1 1ssue B-17 (GE submittal dated 4/30/93, SSAR Section 198.2.20):

l l

1.

The GE acceptance criteria statement does not tie issue resolution into l

the requirements of ANS Standard 58.8. Revise to do so or explain why this is not necessary.

_j 2.

The first sentence of the GE resolution stating that the ABWR design satisfies U.S. Nuclear Regulatory Commission (NRC) requirements 1

concerning automation of safety-related operator actions and operator

's response times is incorrect in view of the ABWR open item on instru-mentation and controls (l&C) diversity. GE needs to provide an appro-priate resolution of this issue that is consistent with the resolution of the j

l&C issue.

j issues HF 1.1. HF 4.4. HF 5.1. and HF 5.2 (GE submittal dated 4/30/93, SSAR.

Table 19B.1-1 and Section 198.3.1)-

j 1.

Issue HF 4.4 needs to be addressed in SSAR Section 18.8 (" COL

}

License information").

1 2.

SSAR Appendix 198 should include a section on each of these issues.

j The resolution section should explain the status of the issues as COL applicant actions and also reference the appropriate SSAR subsection in j

Section 18.8 where the issues are discussed.

Conference Call on June 17,1993 on Generic Issues Assigned to the

'I instrumentation and Controls Branch (HICB).

Issue A-47 (GE submittal dated 5/4/93, SSAR Section 19B.2.17):

]

1 1.

GE resolution is overly general. To which Owners Group submittals is

-l GE referring? Not all were acceptable to staff.

l I

2.

Also in GE resolution, expand on which limiting conditions for operation l

and surveillance requirements are pertinent to the resolution of this issue

-l

~

for the ABWR.

l 3.

One of the facets of this issue is concerned with operating procedures, l

and is indicated in the GE acceptance criteria. However, there is no discussion in the GE resolution. Provide a discussion.

. i i

l

s issue A-47. continued

~

4.

The last sentence of the GE acceptance criteria states that the ABWR automatic overfill protection system design and set points are to be

{

selected to minimize inadvertent trips of the main feedwater system l

during various plant evolutions. However, there is no discussion in the i

GE resolution. Provide a discussion.

issue 45 (GE submittal dated 4/30/93, SSAR Section 19B.2.34):

{

No concerns.

Issue 67.3.3 (GE submittal dated 4/30/93, SSAR Section 198.2.37):

1.

The technical specifications (TS) and human factors aspects of this issue have not been addressed in the GE acceptance criteria and resolution.

2.

TS have not been finalized and are need for issue closure.

Issue 120 (GE submittals dated 5/4/93, SSAR Section 19B.2.49):

The GE resolution of this issue should be addressed in the context of the ABWR Reliability Assurance Program (RAP). (Note: This comment was not i

incorporated the 7/2/93 resubmittal of the SSAR mark-up for this issue. In preparing the mark-up, however, GE made revisions to the references that t

are incorrect. The references in the 5/4/93 submittal were acceptable and the next markup should correct the references, as well as address the staff's comment on RAP.)

Issue 142 (GE submittals dated 4/30/93 and 5/4/93, SSAR Section 198.2.53):

1.

The last paragraph of the GE resolution has a statement that BWRs do not directly use a commercial power source. Explain this statement.

2.

The GE acceptance criteria and resolution appear to be based primarily-on NUREG/CR-3453 (Reference 2). However, it would be more appro-priate to address resolution of this issue in terms of the licensing review bases (LRB) criteria on isolators (the LRB are contained in a letter from T. Murley of NRC to R. Artigas of GE dated 8/7/87). The resolution should probably also reference SSAR Appendix 7A (Section 7A.3).

r h

t f

issue 151 (GE submittals dated 4/30/93 and 5/4/93, SSAR Section 19B.2.56):

The staff indicated that it has already found the ABWR recirculation pump trip design to be acceptable, but that GE's resolution for this issue should clearly state that the ABWR design does not use the breakers which are the i

subject of this issue. (Note: GE resubmitted this SSAR section, without changes, on 7/2/93. The staff has reconsidered and withdraws the original j

comment. There are no additional concerns.)

Conference Call on June 17,1993 on Generic issues Assigned to the I

Radiation Protection Branch (PRPB)

Issue 155.1 (GE submittal dated 4/30/93, SSAR Section 198.2.58):

i 1.

The first sentence of GE's resolution does not make complete sense, since the ABWR is not currently licensed to anything. Correct this discrepancy.

2.

The GE resolution should state where in the SSAR the ABWR source term analysis is addressed and include a statement about meeting TID-14844.

Conference Call on June 17,1993 on Generic issues Assigned to the Electrical Engineering Branch (EELB)

Issue A-24 (GE submittal dated 4/30/93, SSAR Section 19B.2.8):

Although EELB is a secondary review branch for this issue (Plant Systems Branch is the lead reviewer), the staff questions why GE added dynamic qualification to issue which is concerned with environmental qualification.

f i

Issue A-25 (GE submittal dated 4/30/93, SSAR Section 198.2.9):

1.

In GE's issue statement, the intent of the second sentence in the second paragraph ("The first approach is to restrict the connection of primarily safety loads to Class 1E power supplies.") is not clear. Revise as appropriate or explain the intent.

2.

The resolution contains many statements that do not have SSAR refer-ences. Provide references where ones are available.

Issue A-35 (GE submittal dated 4/30/93, SSAR Section 198.2.11):

i i

No concerns.

1 )

3,

  • i

-issue A-44 (GE submittal dated 4/30/93, SSAR Section 198.2.16):

Issue remains open pending completion of the staff's review of station blackout (SBO). GE should assure that SSAR Section 198.2.16 is consis-tent with the final resolution of SBO for the ABWR.

issue B-56 (GE submittal dated 4/30/93, SSArt Section 198.2.23):

(

The Federal Reoister will notice the issuance and availability of Regulatory Guide 1.160 this week (actual date was 6/18/93). The staff would like GE to address this issue in context of the guide. The staff will provide GE a copy of the issuance in the near future (copy provided on 6/21/93).

{

issue 128 (GE submittal dated 4/30/93, SSAR Section 198.2.52):

f 1.

This issue is actually a combination of 3 issues--A-30,48, and 49. To resolve issue 128, GE should address the elements of resolution for each of these three issues, as discussed under issue 128 in NUREG-0933.

2.

Correct the apparent misprint in the first line of the acceptance criteria, "me" should read "the."

Conference Callon June 25,1993 on the Generic issue Assigned to the Safeguards Branch (PSGB)

Issue A-29 (GE submittal dated 4/30/93, SSAR Section 198.2.60):

i 1.

The resolution should state that GE has performed an analysis of the ABWR design for vulnerability to sabotage, as discussed in the draft final safety evaluation report (DFSER), and what changes were made to accommodate staff's concerns.

2.

The GE resolution should also capture the combined operating license (COL) applicant action items which are addressed in the DFSER.

l,

o Conference Call on June 25,1993 on Generic issues Not Currently Assigned to Specific Office of Nuclear Reactor Regulation (NRR) Review Branches 1.

The SSAR needs to provide a discussion which supports the status of TMl Action Plan items presently identified in the GE Safety issues Index (SSAR Table 198.1-1) for " COL Applicant," as follows:

1 1.A.1.1 1.A.1.2 1.A.1.3 1.A.2.1(1)

1. A.2.1 (2)
1. A.2.1 (3) 1.A.2.3 1.A.2.6(1) 1.A.3.1 1.A.4.1(2) 1.C.2 1.C.3 l.C.4 1.C.6 l.C.7 l.C.8 11.B.4 ll.J.4.1 Ill. A.1.1 (1 )

lli. A.2.1 (1 )

lil. A.2.1 (2) lil. A.2.1 (3) lli. A.2.1 (4) lli. A.2.2 Ill. A.3.3(1) lli. A.3.3(2) 2.

Severalissues appeer to be missing from the GE Safety issues Index (SSAR Table 198.1-1). For each of the following TMI Action Plan items, GE should provide a SSAR reference in SSAR Table 198.1-1 and a SSAR discussion for issues that are not already addressed:

1.A.1.4 1.C.1(1) 1.C.1(2) 1.C.1(3) 1.D.1 II.E.1.3 3.

GE should use SSAR section references in the Safety iss res Index (SSAR Table 19B.1-1) that are consistent with the " hierarchy" of issue discussions among SSAR Appendices 1 A,19A, and 198.

4.

TMI Action Plan items 1.A.4.2(1) through (4); i.F.2(2), (3), (6), and (9);

lli.D.1.1(1); lil.D.3.3(3); and Ill.D.3.3(4) are 10 CFR 50.34(f) items.

The Safety issues Index (SSAR Table 19B.1-1) should probably refer-ence the appropriate Appendix 19A section under the heading "SSAR Section," rather than " COL Applicant."

5.

GE should capture all COL applicant actions related to the generic issues that were addressed in Chapter 20 of the staff's DFSER in the pertinent SSAR discussions of the issues.

1

.., : d t

Conference Ca/l on July 2,1993 on the Generic issues Assigned to the l

Reactor Systems Branch (SRXB) l l

Issue A-9 (GE submittal dated 4/30/93, SSAR Section 198.2.5):

'l

+

The staff has found anticipated transient without scram (ATWS) to be adequately addressed in the ABWR design, except for DFSER Open item l

4.4-1 about thermal hydraulic stability. Tha issue remains open pending l

resolution of this DFSER open item. GE should assure that SSAR Section -

l' 198.2.5 is still consistent with the final resolution of ATWS for the ABWR.

Issue A-31_ (GE submittal dated 4/30/93, SSAR Section 19B.2.10):

J 1.

The first sentence of the GE resolution indicates that the residual heat removal system is composed of three electrically independent divisions.

Based on the staff's knowledge of the ABWR design, this is not entirely l

true. GE should revise this statement to be more reflective of the actual plant design.

2.

GE resolution does not provide pertinent SSAR references for the i

majority of the statements made. Provide references where ones are q

available.

3.

The GE acceptance criteria and the resolution should address cornpli-l ance with General Design Criterion 34.

Issue 23 (GE submittal dated 5/4/93, SSAR Section 198.2.31):

No concerns.

issue 40 (GE submittal dated 4/30/93, SSAR Section 198.2.33):

Correct typographical error in the last line of GE resolution, "me" should read "the."

1 issue 105 (GE submittal dated 4/30/93, SSAR Section 19B.2.45):

The issue of intersystem loss-of-coolant accidents (ISLOCAs) has not been resolved by the staff. GE owes a submittal for review and issue 105 will remain open pending resolution of the ISLOCA topic for the ABWR, GE -

should assure that SSAR Section 198.2.45 is still consistent with the final resolution of ISLOCA for the ABWR.,

y

(+ w l

Conference Call on July 9,1993 on the Generic issues Assigned to the Civil l

Engineering and Geosciences Branch (ECGB) 1 Issue A-1 (GE submittals dated 4/30/93 and 5/18/93, SSAR Section 198.2.2):

I No concerns.

l Issue A-10 (GE submittals dated 4/30/93 and 5/18/93, SSAR Section 19B.2.6):

1 i

1.

GE should advise the staff as to whether any operating plants'use the

'[

welded double sleeve.

i 2.

GE needs to propose inservice inspection (ISI) requirements for the i

welded double sleeve design that are consistent with Table 2 (p.15) of

{

NUREG-0619 for staff review, if any operating plants are using this same design, their ISI requirements would provide a good reference l

point.

-l

~1 issue A-13 (GE submittal dated 4/30/93, SSAR Section 19B.2.7):

No concerns.

l

. Issue A-40 (GE submittai dated 4/30/93, SSAR Section 198.2.14):

j Need to correct the reference to SSAR Section 2.5.2 (which does not exist)-

in the GE acceptance critaria and resolution.

i i

Issue A-42 (GE submittal dated 4/30/93, SSAR Section 198.2.15):

f No concerns.

Issue B-5 (GE submittal dated 4/30/93, SSAR Section 198.2.61):

I 1.

Need to correct the erroneous statement in the GE resolution that the l

ABWR containment was designed to American Concrete Institute Code 1

349. Based on the staff's knowledge, the ABWR containment designed in accordance with ASME Boiler and Pressure Vessel Code, Section lil, Division 2.

j 2.

Since the ABWR containment structure is reinforced concrete, the issue of buckling of steel containment shells is not applicable to the ABWR' l

design and should be discussed as such.

.l 1

i

! l t

~

Issue B-55 (GE submittal dated 4/30/93, SSAR Section 198.2.22):

GE resolution should reference the SSAR section or figure that indicates that the ABWR design uses direct-acting safety / relief valves.

Issue B-63 (GE submittal dated 5/4/93, SSAR Section 198.2.25):

j i

No concerns. [ Note: This issue will likely also be addressed as part of the staff's evaluation of ISLOCA (and issue 105)].

Issue C-8 (No GE submittal):

This issue was not included in the NRC's minimum list of issues expected to be addressed that the staff discussed with GE on January 13,1993 (the issue is not included Appendix B of NUREG-0933 as it was resolved without the issuance of new requirements). However, the lack of a main steam line isolation valve (MSLIV) leakage control system in the ABWR design was a major review issue and the staff has reviewed extensively how the ABWR design contains MSLIV leakage. Staff intends to include a write-up on this issue with its USI-GSI evaluations in the FSER. GE should include a discus-sion of this issue in SSAR Appendix 198, in the grouping of issues that were resolved with no new requirements.

Issue 15 (GE submittal dated 4/30/93, SSAR Section 198.2.30):

No concerns, issue 29 (GE submittal dated 4/30/93, SSAR Section 198.2.62):

GE should reference NUREG-1339, " Resolution of Generic Safety issue 29:

Bolting Degradation or Failure in Nuclear Power Plants" (already included in SSAR Table 1.8-22), and EPRI Report NP-5766, " Degradation and Failure of Bolting in Nuclear Power Plants, Volumes 1 & 2," and indicate compliance with the recommendations contained in these documents.

Issue 78 (GE submittal dated 4/30/93, SSAR Section 19B.2.39):

1.

Do the ABWR TS require that records be kept on the number of actual transient occurrences (to ensure that transient limits, based on design assumptions, are not exceeded)? This should be addressed in the GE resolution.

_g.

y[*

1311>e 70, continued 2.

Where in the SSAR is there a more detailed discussion on the envi-ronmental effects on the fatigue life of reactor coolant pressure boundary components?

Issue 83 (GE submittal dated 5/4/93, SSAR Section 198.2.41):

No concerns.

Issue 87 (GE submittal dated 4/30/93, SSAR Section 19B.2.42):

No concerns.

Issue 89 (GE submittal dated 4/30/93, SSAR Section 19B.2.43):

1.

GE resolution needs to make clear statements that the effects of clamps on piping systems was considered in the design process and reference where in the SSAR this discussed.

2.

Provide more details on the analyses done resulting in the conclusion that pipe-clamp induced stresses are negligible. It is not clear that the sample calculations (discussed in the GE acceptarme criteria) covered an appropriate number of clamps and range of applic<tions which supports l

the generic conclusions drawn.

3.

Reference the SSAR section that addresses the criteria, stated in the GE resolution, regarding the installation of pipe clamps, 4.

Were the second and third paragraphs of the GE acceptance criteria intended to be a part of the resolution statement?

Issue 103 (GE submittal dated 5/4/93, SSAR Section 198.2.44):

No concerns.

Issue 113 (GE submittals dated 5/4/93, SSAR Section 19B.2.47 and 7/2/93, J

SSAR Section 19B.2.64):

1.

Provide information regarding number and location (application) of large bore hydraulic snebbers (LBHSs).

i i i

i y%

E lssue 113. continued l

i 2.

SSAR 3.9.3.4.1(3), referenced in the GE resolution, provides appropriate elements for resolution of issue 113, but this SSAR section addresses snubbers as piping restraints. Revise this SSAR section as appropriate j

to incorporate LBHSs that are used as other than piping restraints.

Issue 118 (GE submittal dated 4/30/93, SSAR Section 19B.2.48):

]

No concerns.

Conference Call on July 9,1993 on Generic issues Not Currently Assigned to Specific NRR Review Branches issue 73 (GE submittat dated 7/2/93, SSAR Section 19B.2.37.1):

t Appendix B of NUREG-0933 shows this issue is not applicable to BWRs.

Explain why it is important to be addressed for the ABWR.

j issue 79 (GE fax dated 7/8/93, Table 19B.1-1):

1.

The draft revision of Safety issues Index (Table 19B.1-1) shows that this issue is discussed in SSAR Section 198.2.39.1. NRC has not yet received a submittal which includes this material.

2.

Appendix B of NUREG-0933 shows this issue is not applicable to BWRs.

Explain why it is important to be addressed for the ABWR.

Miscellaneous issues (GE fax dated 7/8/93, Table 19B.1-1):

Errors noted during review of the Safety issues index under the headings

" Title," "NRC Priority," and "SSAR Submittal" are annotated ir "actosure 1.