ML20057A939

Forwards NRC Comments on CE Sys 80+ Tier 1 Submittals Dtd 930430,0503-08,0604,0618 & 0629

ML20057A939
Person / Time
Site:	05200002
Issue date:	09/02/1993
From:	Borchardt R Office of Nuclear Reactor Regulation
To:	Brinkman C ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 9309160235
Download: ML20057A939 (100)

Text

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September 2, .1993 Docket No.52-002 Mr. C. B. Brinkman, Acting Director Nuclear Systems Licensing Comoustion Engineering, Inc.

1000 Prospect Hill Road Windsor, Connecticut 06095-0500

SUBJECT:

COMMENTS ON COMBUSTION ENGINEERING (CE) SYSTEM 80+ TIER 1 DESIGN CERTIFICATION MATERIAL Enclosed are the staff comments on the CE System 80+ Tier 1 submittals dated April 30, May 3 and 8 and June 4,18, and 29,1993.

CE should revise the Tier 1 design certification material to resolve these comments, and provide a response to each comment by September 24, 1993.

Timely responses to these comments and limited iterations are essential to meeting the design certification review schedules.

In a letter of August 13, 1993, CE provided an assessment of the potential changes to Tier 1 information that could result from the resolution of open issues related to the standard safety analysis report. You may receive additional comments on Tier 1 information based on these resolutions.

Sincerely, (Original signed by)

R. W. Borchardt, Acting Director Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next pages DISTRIBUTION:

See next page OFC: LA:PDST:ADAR PM:PDSTADAR , (a)SC:PDST:ADAR (A)D- ST:ADAR NAME: PShea TBoyce:sg TEssig fk, RBo ardt DATE: 08 '93 /93 06/ 1._/93 h / 93 0FFICIAL RECORD COPY: CELTR.TB 9309160235 930902 I PDR ADOCK 05200002 A PDR I i

ABB-Combustion Engineering, Inc. Docket No.52-002 cc: Mr. C. B. Brinkman, Acting Director Nuclear Systems Licensing ABB-Combustion Engineering, Inc.

1000 Prospect Hill Road Windsor, Connecticut 06095-0500 Mr. C. B. Brinkman, Manager Washington Nuclear Operations ABB-Combustion Engineering, Inc.

12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. Stan Ritterbusch Nuclear Licensing ABB-Combustion Engineering 1000 Prospect Hill Road Post Office Box 500 Windsor, Connecticut 06095-0500 Mr. Sterling Franks U.S. Department of Energy NE-42 Washington, D.C. 20585 Mr. Steve Goldberg Budget Examiner 725 17th Street, N.W.

Washington, D.C. 20503 Mr. Raymond Ng 1776 Eye Street, N.W.

Suite 300 Washington, D.C. 20006 Joseph R. Egan, Esquire Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.

Washington, D.C. 20037-1128 Mr. Regis A. Matzie, Vice President Nuclear Systems Development ABB-Combustion Engineering, Inc.

1000 Prospect Hill Road Post Office Box 500 Windsor, Connecticut 06095-0500

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September 2, 1993

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DISTRIBUTION w/o enclosures:

.AThadani, 8E2 BBoger, 10H1 FCongel, 10E7 JWiggins, 7D25 ACRS (11)

DISTRIBUTION w/ enclosures:

Docket File PDST R/F TMurley/FMiraglia DCrutchfield PDR PShea JNWilson TEssig ,

SMagruder TWambach RBorchardt TBoyce MFranovich RJones, 8E23 AThadani, 8E2 MMiller 8E23 TBoyce JMoore, 15818 TGody, Jr., 17G21 BHardin, RES LShao, RES AVietti-Cook WRussell, 12G18 J0'Brien, RES CMcCracken, 8D1 JLyons, 8D1 RPerch, 8E2 GBagchi, 7H15 DTerao, 7H15 MChiramal, 8H7 DEckenrode, 10D24 REmch, 10D4 -

GGrant, 17G21 GMizuno, 15B18 MFinkelstein, 15B18 TPolich, 9Al DThatcher, 7E4 MRubin, 8E23 PCastleman, 12E4 MWaterman, 8H7 CBerlinger, 7E2 RLatta, 9Al S

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PROJECTS COMMENTS ON CE SYSTEM 80+ ITAAC

Contact:

Tom Boyce. PDST. (301) 504-1130

1. General comment - The design certification material should be revised to reflect the agreements reached in the review of the GE ABWR ITAAC (See meeting summary of the GE ITAAC review dated August 10, 1993, especially the general agreements and actions contained in Enclosure 1).

2. Section 1.0, Introduction. The power level of the standard design should be stated (See meeting summary of the GE ITAAC review dated August 10, 1993). l

3. Section 1.1, Definitions. The definition of " channel" is not acceptable, and should be the definition used in the technical specifications.

4. Section 1.2, General Provisions. The general provisions should be clarified to show that tests of the as-built condition are required (See meeting summary of the GE ITAAC review dated August 10, 1993).

5. Section 2.11, Initial Test Program. This section does not contain the comniitments to the test program required, and should reflect those agreed upon 1 with GE for the ABWR.  ;

6. Section 3.3, Reliability Assurance Program. This is still under i discussion within the staff. If required, this section does not contain the l commitments to the reliability assurance program required, and the design description should reflect those agreed upon with GE for the ABWR.

7. Roadmaps. The design certification material should reflect the agreements reached with GE for the ABWR (See meeting summary of DOE meeting dated August 17, 1993).

8. Interfaces. The design certification material should clearly indicate l what systems are both partially and fully out of scope of the certified design, and the interface requirements for these systems (See meeting summary of the GE ITAAC review dated August 10, 1993).

9. PRA/ Severe Accidents. Insights to the design should be incorporated into the Tier 1 and SSAR information as appropriate (See meeting summary of 00E meeting dated August 17, 1993 and meeting summary of the GE ITAAC review dated August 10, 1993).

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I RADIATION PROTECTION TASK GROUP COMMENTS j ON CE SYSTEM 80 + ITAAC i l

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[_ontact : Rich Emch. PRPB. (301) 504-1068 l 1.3 Site Parameters

1. Add the following to Table 1.3-1:

a. Bounding atmospheric dispersion factors for the EAB and the LPZ.

b. Maximum EAB distance of 800 meters (1/2 mile).

2.9.1 Liouid Waste Manaaement System

1. Add the following to Figure 2.9.1:

a. Shim bleed and reactor grade lab drains to high level waste subsystem.

b. Reactor building subsphere floor drain sumps, radwaste building sumps and resin dewatering pumps to low level waste subsystem (note that the above are shown in CESSAR-DC Figure 11.2-1, Sheet 3).

c. Dilution flow for liquid waste discharge (See Figure 11.2-2).

d. Alarm feature for the liquid waste discharge monitor (see Section 11.5.1.2.3.2, Item B).

2. Figure 11.2-1, Sheets 3 and 4 show steam generator (SG) drains input to low level waste and high level waste subsystems. Therefore, include SG drains input to low level waste subsystem in Figure 2.9.1-1. Al so ,

clarify how you will distinguish the SG drains that go to the high level waste subsystem from the SG drains that go to the low level waste subsystem.

3. Clarify whether inputs to high level waste subsystem from some of the sources shown in Figure 11.2-1, Sheet 4 (SG blowdown wastes, boric acid concentrator, boric acid ion exchanger and reactor make up water tank) are not included in Figure 2.9.1-1, because these are not routine inputs but are expected to be infrequent.

4. Revise Table 2.9.1-1 as appropriate to reflect your responses to the items listed above. Note that your revised Table 2.9.1-1 should address the alarm feature for the rad monitor.

5. Revise Figure 11.2-1, Sheet 3 to include fuel building floor drains as an input to the low level waste subsystem.

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2.9.2 Gaseous Waste Manaaement System

1. In the design description, add the following:

a. Number of hydrogen and oxygen analyzers,

b. Alarm features (e.g., hi and hi-hi) for the analyzers. l

c. Automatic action that will be triggered by Hi-Hi alarm

d. Alarm feature for the waste gas rad monitor.

e. The system including the analyzers are designed to withstand a hydrogc.n explosion.

f. The adsorption beds and their suppor. structures do not collapse under seismic loads corresponding to SSE ground accelerations.

g. The GWMS is located in the Nuclear Annex (See CESSAR-DC Section 11.3.1.2. Nuclear Annex is part of nuclear island structures).

Staff has suggested additions 1.a 1.b and 1.c for the reasons given below. Your response to Open Item 11.3-3 (12/10/92) and CESSAR-DC l Section 11.3.1.2 give contradictory information. 'Also, note that SRP Section 11.3 states that at hi-hi alarm setting, for systems designed to preclude explosions oy r.1r,taining either hydrogen or oxygen below 4 percent, the source of hydragen or oxygen (as appropriate) should be automatically isolated from the system (valve should fail in a closed positior,) and diluent should be automatically injected to reduce concentrations below the specified limit. In lieu of meeting the above guidelines, the staff will accept your 12/10/92 response (not Amendment Q) provided you revise the response to state explicitly that the remedial manual action at hi alarm will consist of isolating.the source of hydrogen or oxygen (as appropriate) from the system.

2. Include analyzers in Figure 2.9.2-1. Also, include annunciators for both the analyzers and the system rad monitor in the above figure.

3. Revise Table 2.9.2-1 to reflect the responses to the above. Your l

re uion should address alarm features, the system capability to wiu. stand an internal hydrogen explosion (hydrostatic test in accordance with code requirements);, and the design of the adsorption beds and-their support structures which prevents them from collapsing under SSE ground accelerations (structural analysis) among other things.

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2.9.3 Solid Waste Manaaement System ,

1. Add the following to dry solid wastes:

Air filters such as pre-filters, HEPA filters and charcoal adsorbers used in gaseous process and effluent streams.

2. Add the following to Figure 2.9.3-1:

Dry solid wastes (these can be represented symbolically by a block) and their disposition.

3. Revise Table 2.9.3-1 as appropriate to reflect response to Item 2 above. l l

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P 2.9.4 Process and Effluent Radioloaical Monitorina and Samplina System

1. Add the following to design description:

a. "The system provides radiological monitoring during. plant operation .

and following an accident. Two channels of high range containment >

area monitors that indicate the radiation levels in containment '

throughout the course of an design basis accident."

b. Add the following to the list of safety-related and Class 1E .;

radiation monitors:

1. Containment high and low purge exhaust monitors ,

2. Fuel building ventilation exhaust monitors Reasons for Item 1.b Section 11.5.1.2.4 of CESSAR-DC, Item A states that when containment is purged, the containment atmosphere. monitor is used in conjunction with the containment high purge.or low purge exhaust monitor to monitor releases. The Item further states that a high radiation alarm on any '

channel will produce an isolation signal to the purge valves. Since the automatic closure of. the containment purge valves has to be single '

failure proof and there is only one containment atmosphere monitor to trigger the automatic closure of the purge valves, the purge monitors. .

have to be safety-related and Class IE. Fuel building ventilation exhaust should have two safety-related monitors to divert the exhaust a through the safety-related filtration system as .necessary. Note that 1 the DSER for FHA' states that the offsite doses due to FHA'either in the ,

fuel building or containment will be within the acceptable limits only i if elemental and organic iodine forms along with particulates are ,

filtered prior to release by the fuel building filtration unit or high volume purge filtration unit as appropriate (this implies that both t these filtration systems have to be safety-grade). .

c. Add information on actuation, automatic or from control room, of  !

safety-related monitors. 4

2. Some of the systems identified in this ITAAC do not have separate ITAACs (e.g., containment atmosphere monitoring system, turbine building drain l' system), so the key features provided for these monitors should be identified in this ITAAC. These are listed below: ,

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a. Automatic isolation of high or low purge' system as appropriate on ,

detection of high. radiation.by containment atmosphere monitor (this '

should be added to Table 2.9.4-1).

b. Alarm and automatic termination features'provided for the turbine l building drains monitor, SG drain tank discharge monitor and.

containment cooler condensate tank monitor.

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c. Alarm features provided for the primary coolant loops monitors and high range containment area monitors.

3. Add the following information to Table 2.9.4-1:

a. In DC, " Operation of each safety-related PERMSS division can be manually activated from the control room or automatically." In .'TA,

" Tests of each division (including each channel of the area radiation monitoring system) will conducted using manual controls and simulated automatic initiation signals." In AC, " Each division is activated upon receipt of test signal."

b. In DC, "Each area radiation monitor channel monitors the radiation level in its assigned area, and initiates its respective MCR alarm and local audible and visual alarm (if provided) when the radiation level exceeds a preset level." In ITA, " Tests of each channel of the area radiation monitoring system will be conducted using simulated input signals." In AC, "MCR and local alarms are initiated when the simulated radiation level exceeds a preset limit."

c. In DC, " Independence is provided between Class IE divisions and between Class IE and non-Class 1E equipment." In ITA, "a. Tests will be performed by providing a test signal to only one Class 1E division at a time, and b. as-built Class 1E divisions will be inspected." In AC, "a. The test signal exists only in the division under test, and b. physical separation exists between Class IE divisions and between Class 1E and non-Class 1E equipment."

4. Add the following to Table 2.9.4-2:

a. Unit Vent - One high range monitor and one normal range monitor.

(It is essential to add this information since the monitoring system handles accident situations also. Instead of " nuclear island structures unit vent" use simply " unit vent" to be consistent with Section 11-5.)

b. Component cooling water system, statica service water system, nuclear annex building ventilation, aaaulus ventilation exhaust, and subsphere building ventilation exhar c -- two rad monitors, one per division for each of the above sys'. ems.

c. Fuel building ventilation exhaust, primary coolant loops and high range containment area -- two rad monitors for each of the above items.

d. Main control room intake -- two monitors for each intake.

e. Main steam lines -- two area rad monitors with one for each loop.

f. Purification filter -- one monitor per filter.

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4. CESSAR-DC sections listed below should be revised as follows to make them consistent with ITAACs:

a. ITAAC need not identify the upper limits for the high range noble gas monitors provided to meet TMI Item II.F.1, Attachment 2 requirements. However, these should be specified in ci/cc unit in Table 11.5-1 and deviations from the limits given in the attachment should be explained in Section 11.5.1.2.3.1. The applicant has l

already committed to provide the above information (see NRC's letter i dated June 7, 1993, to ABB-CE, Ch. 11, Items 20-22.

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b. The titles given in Section 11.5 for the systems for which rad monitors are provided should be consistent with the titles given for those systems in Sections 6.2.3 and 9.4.

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t 2.10 Technical Succort Center

1. Table 2.10-1 AC 1.d) should specify that the " voice communications are audible and intelligible at all locations".

2. Design Description (ECGB Secondary Review Comment) - The DD should state that it is protected against the effects of natural phenomena.

(Bagchi/ECGB) 4 1

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3.2 Radiation Protection

1. Revise the DD to replace the undefined adjective "specified":

a. Replace "specified limits" (1st parr.) with " regulatory limits."

b. Replace "within specified limits" (2nd parr.) with " commensurate with expected occupancy requirements."

c. Replace "specified areas" (2nd parr.) with " areas of the plant where radiological conditions can change rapidly or unexpectedly."

2. In DD (2nd parr.) specify which areas are accessible under accident conditions and delete "de. sign basis" by revising with following recommended wording:

"Under accident conditions, plant shielding design permits operators to perform required safety functions in vital areas of the plant. A vital area is an area which will or may require occupancy to permit an operator to aid in the mitigation of, or recovery from, an accident".

3. In Table 3.2-1 provide the analysis methods and the source term assumptions to be used for all analyses specified in ITA 1,2,3,4 and 5.

4. Provide drawings of the plant layout indicating component locations, shield walls, and the radiation zones for normal operating and shutdown conditions.

5. In Table 3.2-1, AC 1, add the following af ter the word " levels":

"(deep dose equivalent shall be measured at 30 cm from the source of the radiation, not contact dose rates)."

6. Provide the access requirement criteria for the dose rate zones.

7. In Table 3.2-1, add "and operational occurrences" at the end of the DC, ITA, and AC in item 2.

8. Table 3.2-1 AC 2 seems to say that the dose rate in any area where maintenance is performed will be 2.5 mrem /hr or less. While this would certainly be acceptable, it seems unrealistic. Maintenance will surely be required on equipment that by itself produces radiation dose rates in excess of the 2.5 mrem /hr. Revise AC 2 as necessary.

9. Revise Table 3.2-1, AC 3 to read:

"The designed total individual personnel dose shall be less than or equal to 5 rem whole body, or its equivalent over the entire time required to perform mitigative or recovery operations (based on the frequency and duration of access required)."

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10. Add DC, ITA, and AC to Table 3.2-1 to address the function of the plant design to provide shielding to protect the general public:

a. In DC, "The plant design shall provide radiation shielding to i protect the general public outside of the controlled area."

b. In ITA, "An analysis wil be performed to determine the radiation dose to the maximally exposed member of the general public outside of the controlled area from direct and scattered radiation." ,

c. In AC, "As a direct result of normal operations, the radiation dose from direct and scattered radiation to the maximally exposed member of the public outside of the controlled area is equal to or less than 2.5 mrem / year."

11. Add "and anticipated operational occurrences" to the end of Table 3.2-1, ITA 4.

12. Revise Table 3.2-1, AC 4, by adding:

"a. For normally occupied rooms and areas of the plant (i.e. those areas requiring routine access to operate and maintain the plant) equilibrium concentrations of airborne radionuclides will be a small fraction (10% or less) of the occupational concentration limits listed in 10 CFR 20, Appendix B.

b. For rooms that require infrequent access (such as non-routine equipment maintenance), the ventilation system shall be capable of reducing and maintaining concentrations of airborne radionuclides to the occupational concentration limits listed in 10 CFR 20, Appendix B during the periods that occupancy is required.

c. For rooms that seldom require access, plant design shall provide containment and ventilation to reduce airborne contamination spread to other areas of lower contamination."

13. Modify Table 3.2-1, DC 5 by adding the following after the word " plant":

"in which there exists a significant potential for airborne contamination. The. airborne. radioactivity monitoring system shall:

a. Have the capability of detecting the time integrated concentrations of the most limiting internal dose particulate and iodine radionuclides in each area equivalent to the occypational concentration limits in 10 CFR 20, Appendix B for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

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b. Provide a calibrated response, representative of the concentrations within the area (i.e. air sampling monitors in ventilation exhaust streams shall collect an isokinenetic sample).

c. Provide local audible alarms (visual alarms in high noise areas) with variable alarm setpoints and readout / annunciation capabilty."

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I&C TASK GROUP COMMENTS ON CE SYSTEM 80 + ITAAC

Contact:

Matt Chiramal. HICB. (301) 504-2845 ITAAC 2.3.4. NSSS INTERGRITY MONITORING SYSTEM l

{- Design Description Comments -

l The level of detail in the design description should be consistent with the i level of detail provided in the ITAAC table. For example, items 2.a and 3.a in the IT whereas, the#.A, ACdescription 4dysign table reference does Tables 2.3.4-2 not discuss and 2.3.4-3 sensor respectively; locations.

The Acoustic Leak Monitoring System (ALMS) and the Loose Parts Monitoring System (LPMS) provide alarms in the main control room. These alarms should be discussed in the design description.

In its design of the diverse safety system, (which addresses common mode failures of the plant protection system and the engineered safety features system), ABB/CE claims credit for the early detection of primary coolant system leakages which would arise prior to a large break loss of coolant accident. The ALMS allows ABB/CE to design a diverse safety system that l does not require a diverse automatic actuation of the safety injection i system (manual operator action in response to leak detection is credited in I

the safety analyses). Since the ALMS is an important consideration in the diverse safety system, there should be some design commitment regarding the quality of the system (e.g., an ABB/CE Quality 2 rating).

ITAAC Comments -

Item 2 - The Acoustic Leak Monitoring System (ALMS) provides an alarm in the main control room. This alarm should be a design commitment.

Item 2 - The quality of the ALMS should be a design commitment.

Item 3 - The Loose Parts Monitoring System (LPMS) provides an alarm in the main control room. This alarm should be a design commitment.

SSAR comment -

l In the CESSAR-DC there are no acoustic leak monitors (ALMS) in the RCP suction i legs. The cold leg ALMS are on the reactor vessel nozzles, the SG ALMS are on the SG hot leg plenum manways, and the RCP ALMS are-on the RCP seals. During the initial review of-Section 7.7 the issue regarding leak detection had not been raised. Now that CE wants credit for leak detection in their diverse actuation system (to avoid diverse automatic actuation for safety injection),

the absence of monitors in the cold leg suction piping requires further review.

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ITAAC 2.5.1. PLANT PROTECTION SYSTEM i

l Design Description Comments -

l The level of detail in the design description should be consistent with the level of detail provided in the ITAAC table. For example, Item 15 in the ITAAC describes the major components of the software development plan (SDP). The design description lists the major elements of the SDP, but provides no additional details. The design description should be as detailed as the ITAAC acceptance criteria.

-i The design description should include more details regarding the basic hardware, software, and data network architecture. This includes the use of multiplexers, programmable logic controllers (PLCs), microprocessors, and continuous testing capabilities. The paragraph should also discuss environmental qualification of the hardware components, to include:

temperature, pressure, humidity, chemical contamination from sources such-as smoke and fire suppression sprays, radiation, aging, and electromagnetic compatibility. There should also~be some discussion regarding the commercial dedication process to be used for procuring hardware and second and third party software.

Equipment qualification should be addressed in more detail in the design description, and should be added to the ITAAC table as a design commitment *

(ref. GE ITAAC 3.4, pages 12-13, and ITAAC Table 3.4, Item 12, page 38).

There should be some discussion of the testing of the hardware, software and data networks after the system has been installed at the site.

The description of the Master Transfer Switches on page 4 should include a discussion of the means by which the operators are informed that the control functions have been transferred to the Remote Shutdown Room.

The Interface and Test Processor continuously' tests the PPS logic. The  :

continuous testing capability should be more clearly described on page 4.

Figure 2.5.1-2 or 2.5.1-3 should denote the composition of the hardware  !

components. For example, include a label that defines the type of processor (PLC, micro, etc) that will perform the coincidence processing function.

In general, specific details regarding the hardware composition, data ,

network structure, environmental qualification, and procurement '

requirements should be added.

ITAAC Comments -

4 Item 4 - The word coniguration" in the middle column should be changed to configuration.

Item 6 - The tests specified are not exhaustive. There should be a statement that every disconnectable trip path component shall be 1 disconnected, one at a time, to verify that each such component, when .

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disconnected, will cause a trip initiating state to occur.

Item 7 - The testing scope should be expanded to' address: 1) the PPS response when input signal crosses the setpoint threshold, and 2) the effect on PPS response when the setpoint is shifted to a new value. The scope of the testing-should also assure that, each time a setpoint is changed, the setpoints of the other trips do not also change.

There should be some commitment regarding the procurement, use.and control of second party and third party software, and of hardware (commercial dedication and configuration management of procured software and hardware products).

The PPS ITAAC should address electromagnetic compatibility in the design description and in the acceptance criteria, (Table 2.5.1-1,. Plant Protection System Inspections, Tests, Analyses and Acceptance Criteria)

(ref. GE ITAAC 3.4, pages 8-9).

The PPS ITAAC should discuss the methodology for selecting protection system setpoints in the design description section (ref. GE ITAAC 3.4, pages 10-11). The acceptance criteria in Table 2.5.1-1 for the setpoint methodology is acceptable, but is not supported by the text in the design description.

The data network structure design commitments'should be added to the ITAAC ,

table.

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0 6 ITAAC 2.5.2. ENGINEERED SAFETY FEATURES-COMPONENT CONTROL SYSTEM Design Description Comments -

The level of detail in the design description portion should be consistent with the level of detail provided in the ITAAC tables. For example, Item 15 in the ITAAC describes the major components of the software development plan (SDP). The design description lists the major elements of the SDP, I but provides no additional details. The design description should be as l detailed as the ITAAC acceptance criteria. l l

The design description should include more details regarding the basic hardware, software, and data network architectures. This includes the use of multiplexers, programmable logic controllers (PLCs), microprocessors, and continuous testing capabilities. The paragraph should also discuss environmental qualification of the hardware components, to include:

temperature, pressure, humidity, chemical contamination from sources such as smoke and fire suppression sprays, radiation, aging, and electromagnetic compatibility. There should also be some discussion regarding the commercial dedication process to be u;ed for procuring hardware and second and third party software.

Equipment qualification should be addressed in more detail in the design description, and should be added to the ITAAC as a design commitment (ref.

GE ITAAC 3.4, pages 12-13, and ITAAC Table 3.4, Item 12, page 38).

The software portion of the design description should be expanded into a more detailed discussion of the software development plan (see the first comment).

There should be some discussion of the testing of the hardware, software

and data networks after the system has been installed at the site.

The description of the Master Transfer Switches on page 3 should include a discussion of the means by which the operators are informed that the control functions have been transferred to the Remote Shutdown Room.

The ability to continuously test the ESF-CCS was not discussed in the design description.

Figure 2.5.1-1 or 2.5.1-2 should denote the composition of the hardware components. For example, include a label that defines the type of processor (PLC, micro, etc)-that will perform the coincidence processing l function.

The Containment Spray Actuation System (CSAS) should be added tc figure 2.5.2-3, and deleted from Figure 2.5.2-4. The Safety Injection Actuation Signals (SIAS) should be added to Figure 2.5.2-4. Addit!onally, the manual actuation capabilities should be added to both of these t igures.

In general, more detailed information is required regarding the following 4 I&C

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topics: 1) hardware composition, 2) data network composition, 3) quality assurance processes for hardware and software, 4) environmental qualification, 5) electromagnetic compatibility, 6) commercial grade item dedication, 7) channel bypasses, 8) completion of trip actuations once they_

are initiated, 9) testing capabilities,10) the effect of loss of power .

within an ESF channel,11) annunciation of Master Transfer Switch and diverse actuation system actuations, and 12) fail-safe features of the ESF-CCS upon loss of. data communications.

ITAAC Comments -

Item 1 - Reference Figure 2.5.2-2 in the design commitment column.

Item 5.b - The acceptance criteria implies that any two initiation signals will result in an ESF function actuation. The acceptance criteria should-ensure that only selective signals result in actuations. For example, initiation signals from Channels A and C should not result in an actuation signal; Signals A and B should result in an actuation signal. The acceptance criteria for Item 6.b should be used. The ITA should require testing of all combinations to ensure that the selective logic is correctly implemented in the design.

Item 6 - Items 6.a and 6.b appear to address the same commitments as Items 5.a and 5.b. The acceptance criteria apparently address the manual controls provided by the control and display interface equipment. The response time test in Item 6.c should explicitly state that the response time for each actuation signal is within its specified interval.

Item 8 - The acceptance criteria should require that the control and display interface equipment-be exercised for each of the listed systems in such a manner that the control and display capability may be verified.

Item 9 - The acceptance criteria should state that the loads must be sequenced in the proper order for each of the accident sequencing scenarios.

Item 10 - This item discusses the response of the system to losses of load  ;

external to the ESF-CCS. A similar discussion should address the effect of losses of power within an ESF-CCS channel. Additionally, the ITA should address all the types of transients that will result in load transfers.

The proposed test addresses total losses of power. The test scope should include degradations in the power supply that do not result in a total loss of power, but will result in load transfers to the EDGs.

Item 12 - The comments for Items 6, 7 and 8 apply for Item 12.

Additionally, the ITA and acceptance criteria reference Item 8.a instead of Item 8. l Item 14 - This item should include consideration of alarms in the design commitment and acceptance criteria. Item 14.a.1 should address only main control room display interface devices. The tests specified in Item 13 should be repeated for each state of the Haster Transfer Switch (MTS) prior 5 I&C  !

to transferring control to the Remote Shutdown Room (RSR). There should be a series of tests to ensure that there is no control capability in the RSR unless the MTS has been actuated, and vice when the MTS has not been actuated.

Item 15.b - The system described in the acceptance criteria for item 15.a.2 is not consistent with the design presented in the CESSAR-DC, which the NRC staff has found to be acceptable. The CESSAR-DC design does not use digital equipment or software that is diverse from the microprocessors used in the PPS and ESF-CCS equipment. As writter., this acceptance criteria allows the applicant to change the design without further staff review, which is unacceptable. The purpose of the ITA should be moved into the Acceptance Criteria column. Additionally, the acceptance criteria should require verification that each ESF function correctly operates when the corresponding control is actuated.

Item 16 -'The ITA require inspections of the design documentation and the as-built equipment. Tests should also be performed on the equipment to ensure its operability.

Item 19 - The testing scope should be expanded to address: 1) the ESF-CCS response when an input signal crosses the setpoint threshold, and 2) the effect on ESF-CCS response when the setpoint is shifted to a new value.

The scope of the testing should also assure that, each time a setpoint is changed, the setpoints of the other trips do not also change. '

The ESF-CCS ITAAC should discuss the methodology for selecting protection system setpoints in the design description section (ref. GE ITAAC 3.4, pages 10-11). The acceptance criteria in Table 2.5.2-1 for the setpoint methodology is acceptable, but is not supported by the text in the design description.

General Comments -

There should be some commitment regarding the procurement, use and control of second party and third party software, and hardware (commercial dedication and configuration management of procured software and hardware products). t The ESF-CCS ITAAC should address electromagnetic compatibility in the design description and in the acceptance criteria.

The ITAAC should also address the effect on the digital systems of voltage surges, dips, frequency changes, and power supply degradations.

l l

6 I&C

l a

e ITAAC 2.5.3. DISCRETE INDICATION AND ALARM SYSTEM AND DATA PROCESSING SYSTEM Design Description Comments -

i The level of detail in the design description should be consistent with the level of detail provided in the ITAAC tables. For example, Item 10 in the ITAAC describes the major components of the software development plan a (SDP). The design description lists the major elements of the SDP, but provides no additional details. The design description should be as detailed as the ITAAC acceptance criteria.

i The first paragraph of the design description implies that the instrumentation used by the DIAS and DPS is not safety-related. The fourth paragraph contradicts this statement by stating that the DIAS and DPS display safety-related information.

l The DIAS instrument channels up to and including the channel isolation devices are to be Class lE, environmentally qualified, and seismically  ;

qualified, as stated in Section 7.7.1.4.4 (page 7.7-39) of the CESSAR-DC. '

The DIAS displays and CPUs are to seismically qualified for physical and functional integrity. The cabinets containing the DIAS computer equipment are to be provided with a temperature switch and associated alarm in the main control room to alert the operator regarding temperatures in the cabinets. These design criteria should be discussed in the design description and included in the ITAAC table.

A description of the DIAS communications architecture should be added to the design description.

There should be some discussion regarding the commercial dedication process to be used for procuring hardware, and second and third party software.

There should be some discussion of the testing of the hardware and software after the system has been installed at the site.

1 Figure 2.5.3-1 or 2.5.3-2 should denote the composition of the hardware {

components. For example, include a label that defines the type of processor, (PLC, micro, etc), that will perform the coincidence processing function. ,

Figure 2.5.3-2 should be corrected. lhe data link between the Channel B protection system and the DIAS Channel P displays is a hardwired data link with isolators at each end. See Figure 7.7-16 in the CESSAR-DC.

The last sentence on the first page of the design description states, "One channel of the information provided to the DIAS-P displays is communicated ,

via means which are diverse from the communication software used in the '

plant protection system (PPS) and the engineered safety features-component control system (ESF-CCS)." This sentence implies that the DIAS-P channels are diverse from each other, since only one channel is diverse from the PPS.

and ESF-CCS communication software. Additionally, this diversity is not indicated in Figure 2.5.3-2 or Figure 7.7-16 in the CESSAR-DC. Clarify the 7 I&C

s a reference to a single channel and the reference to diversity from the communication software. This should also be clarified in ITAAC Item 4.b.

The design description lists three indicators of core cooling (i.e..,

subcooling, reactor vessel liquid inventory, and steam temperature at the core exit). The instrumentation at the core exit measures coolant temperature, regardless of the coolant phase (liquid or vapor). Using the term " steam" instead of " coolant" implies the use of instruments that are specifically_ designed for two-phased water measurements. The use of this type of instrument was not discussed in the CESSAR-DC or the shutdown cooling report. '

The qualification of the DIAS and DPS power supplies should be included in the design description and the ITAAC.

In general, more detailed information is required regarding the following topics: 1) hardware composition, 2) quality assurance processes for hardware and software, 3) environmental qualification, 4) electromagnetic compatibility, 5) commercial grade item dedication, and 6) the effect of loss of power.

ITAAC Comments -

Item 4.b - See the comment in the design description comments.

Item 4.b.ii - The design described in the ITA or acceptance criteria is not consistent with the design presented in the CESSAR-DC, which the NRC staff has found to be acceptable. The CESSAR-DC design does not use digital equipment or software that is diverse from the microprocessors used in the PPS and ESF-CCS equipment. As written,-this acceptance criteria allows the applicant to change the design without further staff review, which is ,

unacceptable.

Items 5 and 6 - These design criteria appear to be within the scope of l Item 7. Additionally, there is no discussion of remote shutdown room displays (see Section 7.7.1.4.2 in the CESSAR-DC).

Item 7.g.iii - The design commitment and acceptance criteria list three indicators of core cooling (i.e., subcooling, reactor vessel liquid inventory, and steam temperature at the core exit). The instrumentation at the core exit measures coolant temperature, regardless of the coolant phase (liquid or vapor). Using the term " steam" instead of " coolant". implies the use of instruments that are specifically designed for two-phased water measurements. The use of this type of instrument was not discussed in the CESSAR-DC or the shutdown cooling report. <

Item 8 - The acceptance criteria should require that multiple failures of each parameter be simulated, and the display interface equipment be exercised in such a manner that the control and display capability may be verified.

8 I&C

o .

General Comments -

The design description and ITAAC table must include the DIAS alarm functions. As written, this ITAAC discusses only the display capabilities.

There should be some consideration of the alarm capabilities, i.e., alarm annunciations, alarm acknowledgements, alarm information, and alarm prioritization.

There should be some commitment regarding the procurement, use and control of second party and third party software, and of hardware (commercial dedication and configuration management of procured software and hardware products).

The ITAAC should address electromagnetic compatibility in the design description and in the acceptance criteria.

1 I

i I

i 9 I&C

• ^ ' -~ . , _ ,.. . , - . . . .- < - .-. .- - . , .,-.-,,---r.,-..g -er-

.v- w a . -er

. 4 ITAAC 2.5.4. POWER CONTROL SYSTEM / PROCESS-COMPONENT CONTROL SYSTEM Design Description Comments -

The level of detail in the design description should be consistent with the level of detail provided in the ITAAC table. For example, Item 10 in the ITAAC describes the major components of the software development plan (SDP). The design description lists the major elements of the SDP, but provides no additional details. The design description should be as detailed as the ITAAC acceptance criteria.

The megawatt demand setter should be added to the list-of PCS/P-CCS control interfaces on page 1. Additionally, it may be useful to indicate, for each item in the list, the system (PCS or P-CCS) that provides the control interface.

Since the APS portion of the PCS/P-CCS must be highly reliable, there should be some discussion regarding the commercial dedication process to be used for procuring hardware and second and third party software.

ITAAC Comments -

Item 3 - The megawatt demand setter should be added to the list of PCS/P-CCS control interfaces. Additionally, it may be useful to indicate, for each item in the list, the system (PCS or P-CCS) that provides the control interface.

Item 8 - The acceptance criteria should require that actuation of the master transfer switches is annunciated and results in an alarm indication for-each case in which control is transferred from the active controlling area.

General Comments -

There should be some commitment regarding the procurement, use and control of second party and third party software, and of hardware (commercial dedication and configuration management of procured software and hardware products).

10 I&C

, v HUMAN FACTORS TASK GROUP COMMENTS ON CE SYSTEM 80+ ITAAC l

Contact:

Dick Eckenrode. HHFB. (301) 504-3172 2.12.1. Main Control Room j l

1. Pages 2-4, Table 2.12.1, MCR Minimum Inventory:  !

a. Change title of table to read: "MCR MINIMUM INVENTORY OF FIXED POSITION ALARMS, DISPLAYS AND CONTROLS".

Table 2.12.1-2 l

2. Row 3, col. 1: Change as noted in brackets: The MCR provides suitable i workspace [and environment] for continuous occupancy and use by MCR l operators.

3. Row 3, col. 3: Change to read as follows: The MCR workspace and l environment are determined to be suitable for use by MCR operators. '

4. Row 4, col. 1: . Change to read as follows: The MCR permits execution of I those tasks performed by operating personnel to operate the plant and i maintain plant safety. )

5. Row 4, col. 2: Confirm that "a fullsize dynamic mockup of the MCR j consoles that simulates plant operational responses" equals a " full- i l

scale, full-fidelity, plant-specific simulator."

Comment: Provide a commitment to use (or acceptable justification for ,

not using) a full-scale, full-fidelity, plant-specific simulator. l Clarify in V&V Plan what the subject statement means with regard to ANSI j 3.5. Clarify ABB-CE's commitment regarding ANSI 3.5 (e.g., exceptions, l applicable sections, etc.).  !

6. Row 4, col. 3: Change to read as follows: "The tests and analyses results demonstrate that tasks performed by operating personnel to operate the plant and to maintain plant safety can be performed from the MCR."

l l

I 1

1 HFE

e

• 2.12.2. Remote Shutdown Room

7. Page 1: Change as noted in brackets: "The RSR makes available the annunciators, displays, and controls to shutdown (prompt hot shutdown] '

the plant and maintain plant safety. [The RSR has capability for subsequent cold shutdown of the reactor.]"

8. Page 1: "The RSR makes available the annunciators, displays, and controls to shutdown the plant and maintain plant safety."

Comment: Specify the inventory of RSR annunciators, displays, and . t controls in either (a) the RSR ITAAC or (b) the applicable system ITAAC required to achieve and maintain a safe shutdown of the reactor (specified in CESSAR section 7.4.1).

Table 2.12.2-1

9. Row 2, col. 3: "2.b) The as-built RSR has capability for subsequent cold shutdown of the reactor through the use of suitable procedures."

Comment: Define " suitable procedures" in CESSAR or propose some acceptable alternative.

10. Row 3, col. 1: Change as noted in brackets: "The RSR provides suitable workspace [and environment] for use by RSR operators."

Row 3, col. 3: Change to read as follows: "The RSR workspace and 11.

environment are determined to be suitable for use by RSR operators."

12. Row 4, col. 1: Change to read as follows: "The RSR permits execution of those tasks performed by operating personnel to shutdown the plant and maintain plant safety."

13. Row 4, col. 2: Confirm that "a fullsize dynamic mockup of the Remote Shutdown Panel that simulates plant operational responses" equals a

" full-scale, full-fidelity, plant-specific simulator".

Comment: Provide a commitment to use (or acceptable justification for not using) a full-scale, full-fidelity, plant-specific simulator.

Clarify in V&V Plan what the subject statament means with regard to ANSI 3.5. Clarify ABB-CE's commitment regarding ANSI 3.5 (e.g., exceptions, l applicable sections, etc.).

14. Row 4, col. 3: Change to read as follows: "The tests and analyses results demonstrate that tasks performed by operating personnel to shutdown the plant and maintain plant safety can be performed from the RSR."

2 HFE l

2.12.3. Control Panels

15. Add the following row (or propose acceptable alternative ensuring delta between Control Panels ITAAC and MCR/RSR ITAACS is addressed): .

a. design commitment: " Control Panels have readily available the annunciators, displays and controls to operate the plant and maintain plant safety."

b. inspections: " Human Factors Engineering (HFE) verification inspections of the availability of the annunciators, displays and controls of a Control Panel against verification criteria will be performed."

c. criteria: "The annunciators, displays and controls to operate the plant and maintain plant safety are readily available."

P P

k 3 HFE l

PRA-Related Item

16. Add to the Human factors V&V Plan at the Tier 2 level, "that the final control room design has not introduced any human engineering deficiencies which would either significantly increase the error rates for human actions modelled in the PRA/HRA, or the potential for additional, risk-significant errors not modelled in the PRA/HRA."

t 4 HFE

. , SYSTEM 80+"

2.12.1 MAIN CONTROL ROOM 1 Design Description ne Main Control Room (MCR) permits execution of MCR tasks to operate the plant and maintain plant safety. He MCR provides suitable workspace for continuous occupancy annunciators, displays, and controlsand use the to operate byplant MCR and operators, maintain plant safety, ne MCR mak including at least those annunciators, displays and controls identified in Table 2.12.1-1. j The Basic Configuration of the MCR is as shown on Figure 2.12.1-1. The MCR contains the Master Control Console, the Auxiliary Console, the Safety Console, the Control Room Supervisor (CRS) Console, administrative support facilities, and the Integrated Process Status Overview (IPSO).

He MCR is located in the Nuclear Annex within fire and ventilation isolation boundaries.

MCR consoles are organized functionally according to the following:

Master Control Console Auxiliary and Safety Consoles Reactor Coolant System Heating, Ventilation & Air Chemical & Volume Control System Conditioning Plant Monitoring & Control Cooling Water Systems Feedwater & Condensate Systems Engineered Safety Features Turbine Control Safety Monitoring Secondary Auxiliaries Switchyard Electrical Distribution ne CRS console provides a workstation from which the CRS coordinates MCR operations. Administrative support facilities provide ofIIce workspace. He IPSO provides safety parameter display information at a fixed location that can be viewed from the MCR consoles and administrative s'6pport facilities.

\

Inspection, Test, Analyses, and Acceptance Criteria Table 2.12.12 specifies the inspections, tests, analyses, and associated acceptance criteria for the MCR. ,,.

4

' (Nuclear Island Structures, 'ventifatiois, fire protection, communications, lighting, -

)

I radiation protection and control panels ire addressed in Sectiods 2.1.1,2.7.17,2.7.24, 2.7.25,2.7.26,3.2 and 2.12.3, respectively.) (

i 2.12.1 04-30-93

e a SYSTEM 80+= TABLE 2.12.1-1 MCR MINIMUM INVENTORY OF nx2O Possreor) At.n& MS, ptSR.AYS AND CoADCbl5 PAAAht.TIR DCSCRrTIQIl Displaye AnnundsamuP Cenerets e

_OMahe Rue voNage stamas X 120 VAC Vitat load centw voitage statas X X 125 VDC Vitallead centu voitage statas X X 24 KV Mah Turthe Generator output breakw poeMon X X X 4.18 KV Cfwe 1E bus breakw poettlone (supply & crosaeverl X X 4.18 KV Cisse 1E voltape status X X 4.18 KV D;esef Cenerator output breakw posMen X X 4.18 KV D;esef Generator start conwel X X 4.18 KV D;eest Cenerator synchroeoope X - X

'I

i. 4.18 KV Reserve Aum Xfmr outpd voitoge etetus X 480 VAC CIsse 1E vehese etetus X X Arcufwe wentDation control setpoint X X Annulus vent #atim damper posMon X X Aamdu went% tion ten veteM X X Atmospheric dump vafve poeMon X X CEA posMen X CET tempersture X CIAS actuation X X CtAS success monitor X X -

CCW HX biet vatve posP6an X X CCW HX outlet vatve postdon X X CCW MX outlet flow X i

CCW pumps ordeff X X CCW surge tank level X

! Containmsnt hydrogen icvel (when analyser is in opwe6en) X X Containment preseure T X Contahment redet$en X CSAS setua6cn X X i Contahment Spray flow X Containment Spray pump ordoff X X 2.12.1 04 30-93

e .

- system 80+= TABLE 2.111-1 (Continued)

MCR MINIMUM INVENTORY OF FIXED POSITr69 ALA RMS , DISPt. A YS AtJD cODTROLS PARAhsE'TIR DESCRrTMIII "

Dispanye JL:: _ " - Omssereds Containment Sprey pump decharge vain poeMan X X Contahment temperature X X DV! valve poemon X X ETAS ectuation X X E7W flew control vefve poemen X X UW he oder Sow X 17W motor <friven pump onleM X X (7W pump suction preneure X E7W steam-drfven pump on/off X ,i X UW-to40 isoletion valve pceMan X X 3

ETW Storege TarA level X Hot Lag W vain pos4en X X 1RWSTlowl X Me:n Control Room WAC leoletion dampere X X Main Steem Ene tres redeb monher X Main Steam eefety vefve position X Msts actuation X X X

• Nwc&eer Annea bull (ng yen 12etion re&ation morser X Par Fockup Hesters on/off X X Par Level X X Par Pressure X X Rapid DepreeeuriseCon vafve poeMan X X l

Rp WW X X RCS Celd Les temperature X RCS Hot Lag temperature X .l RCS subesoAng marpin X X Reacto, seg .us.rer. v.nseson ..secon m.m., X Reactor Coofant gas v+nt vs!w poofilen X X Rosetor power (N1) X Ree:1or Trip (RPS) X X 2.12.1 3- 04 30 93 m ,

9 l SYSEM 80+=

TABLE 2.12.1-1 (Continued)

MCR MINIMUM INVENTORY OF" FtXED_

Postned AL AllM5, DISPL AW AAD COYYOLS PARAMETIR D(50up'TICII Diepisye W Caseek Re ector Vessellevel X X SCS flow (whk SCs le b operatient X X SCS leoladon vafve poe%n (& LTOP3 X X X SCS RX Bypsee Vaive poeMan X X SCs HX CCW steplyAeoledon valve poeMan X X SCS HX Irdet & Oudet temperature (when SCS le b operatent X SCS MX outet vafve posMon X X SCs pump on/ett X X SC$/ CSS pump sucCon croes<onnect velve po* Men X - X 8C8/ CSS pump dechorgo cross-conneet vaPve peeMon X X 8tAS actuation X X Si new .X St pump on/off X X

= dvedr,6 edeJon i wat<e position X X Spent Fust Poollevel X .

Startup Rete INfl X

$$W HX intot leoledon vafve posMen X X SSW HX outtet isareCon wahre posMon X X 5SW HX outset flew - X SSW pamp onloff X X SC Stewdown sample refi 6an meadter X sa level X X 80 preneure X l

! Vacuum Pump Aedv9ty X Turbine Tety X . X i

I

'* Arnancistors are ofertne and other storting depfere designed to direct operator ettensen.

2.12.1 04-30 93 c ~

SYSTEM 80+= TAllLE 2.12.1-2 - '

MAIN CONTROL ROOM Inspections. Tests. AnaJyses, and Acceptance Criteria Design Commitment Inspections,_ Tests. Analyses Acceptance Criteria

1. The Basic Configuration of the Main 1. Invections of the as-built MCR con- I. For the components and equipment Control Room is as shown on Figure figuration will be conducted. shown on Figure 2.12.1-1, the as-built 2.12.1-1. 4mg,gg o . a n t' w w w Main Control Room conforms with the ma fMudet' 4x6 ga MM p 2. ' Basic Configuration.

4 .arcC cp w w w- ,

2. The MCR makes available the 2. liuman Factor Engmeeting (life) avail-  ! 2. The MCR makes available the annunciatori, displays and controls ability verification inspection of the as- I annuncistors, displays and controls identified in Table 2.12.1-1. ~ _. _ built MCR will be performed, identified in Table 2.12.1-1.

a.,4 u ext m C

3. M MCR provida suitable workspace - 3. HFE suitability inspection against 3. /@'ons demonstrate HFE suitabiSty )(_

, for continuous wrj and use by verification criteria will be performed. %f the_MCR workspace.

j MCR operators.

_ ,.A. -

4. b MCR pennits execution o,fkCR) 4. Tests and analyses against the validation 4. test and analysis results a-L teK tto operate the plant and mainisiH] criteria using a fullsize dynamic mockup validation of MCR tank execution plant safdy. of the MCR consoles that simulates -

-[ plant operational responses will be son h/n ga x G L Aelb m V,a d m Q E! R , +--LL s L&yx j.

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2.12.1 04-30-93

SYSTEM 80+" -

1 l

ADMINISTRATIVE SUPPORT FACILITIES AUXILIARY AND SAFETf CONSOLES CRS CONSOLE i

MASTER CONTROL CONSOLE r L 1

IPSO FIGURE 2.12.1-1 MAIN CONTROL ROOM

l

, i e SYSTEM 80+"

2.12.2 REMOTE SHU30WN ROOMW ^

Design Description J a. sfsgg O u cc4dN. y &

og g The Remote Shutdown Room (RSR) pertnits execution of RSR tasks to plaDd maintain the plant in a safe shutdown condition. He RSR provides suitable workspace separate from the Main Control Room (MCR) for use by MCR operators in the event that the MCR becomes uninhabitable. De RSR makes available the annunciators, displays, and controls to shutdown theylant and maintain lant safety.

(PhM De Basic Configuration of the RSR is as shown on Figure 2.12.21. He RSR '

d w) contains the Remde Shutdown Panel. He Remote Shutdown Panel provides a workstation from which MCR operators perform RSR operations.

He RSR is located in the Nuclear Annex within fire and ventilation isolation boundaries.

Inspection, Test, Analyses, and Acceptance Criteria Table 2.12.21 speci5es the inspections, tests, analyses and acceptance criteria for the RSR.

' (Nuclear Island Structurcs, ventilation, fire protection, communications, lighting, radiation protection, and control panels are addressed in Sections 2.1.1,2.7.17,2.7.24, 2.7.25,2.7.26,3.2, and 2.123, respectively.)

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- 04 30 93

-s,-w- ws w

SYSTEM 80+ .

REMOTE SHUTDOWN PANEL FIGURE 2.12.2-1 REMOTE SHUTDOWN ROOM

o SYSTEM 80+" TAHLE 2.12.2-1 - '

REMOTE SIIUTDOWN ROOM i

Jnspections. Tests. Analysess and Acceptance Criteria l

l . Design Commitment Jnggtions. Tests. Analyses Acceptance Criteria

1. De Basic Configuration of the RSR is 1. Inspection s of the as. built RSR I. For the components and equipment as shown on Figure 2.12.2-1. configurat on will be conducted. shown on Figure 2.12.2-1, the as-built RSR conforms with 6 Basic Configuntion.

2. He RSR makes available the 2. liuman Factor Engineering (HFE) avail- 2.a) He as-built RSR makes available the annunciaton, displays and controls to ability verification inspection of the as- annunciators, displays, and controls shutdown the plant and maintain plant *ouilt RSR will be performed. i necessary to achieve and maintain safety. w N, prompt bot shutdown of the reactor.

/j-lu_b.3b e. @ ,11 ,, f 5 * $~ [.

/>~.e yi/ h # 2. ) De as-built RSR has capability for h b < nd DL, subsequent cold shutdown of the reactor g( ,e tj L C " * ^ [ g 4 q. t A through the use of suitable procedures.

/

3. De RSR provides suitable workspacet' 3. IIFE suitability inyection against }3. (Es~pections demonstate HFE suitabifilyY for use by RSR opentors. verification criteria will be performed. Qf the RSR workspace. _.

4. The RSR permits execution of @S 4. Tests and analyses egninst the validation 4. -%e~tesTaslianalysiTrddemonstr:5 A[kk to shutdown the plant and maintain criteria using a fullsize dynamic mockup hidation of RSR tadt execution plant safety. I _. of the Remote Shutdown Panel that (

) simulates plant opentional resporues h7 will be performed. \ _I u. ,[.ph, g/g /, ,

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y ..

SYSTEM 80+=

2.12 3 CONTROL PANELS 2 i Design Description Control Panels use standard features to provide suitable operator workstations for annunciators, displays and controls. Each Control Panel permits execution of the 3

Control Panel's tasks to operate the plant and maintain plant safety. '

'ne Basic Configuration of a Control Panelis as shown on Figure 2.1231.

Control panels are provided in the Main Control Room (Section 2.12.1) and the Remote Shutdown Room (Section 2.12.2).

Control Panels with Class 1E instrumentation are qualified Seismic Category L Inspection, Test, Analyses, and Acceptance Criteria Table 2.123-1 specifies the inspections, tests, analyses, and associated acceptance criteria that will be applied to each Control Panet 8 (Instrumentation and Control Systems are addressell in Section 2.5.)

2.12.3 04 30 93 1

C ma - . . < __---__,______m.=a-

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o- - - * ~ ~ ~ ~ ~ ~ - ' -~

SYSTEM 80 +* '

RM A RM SE ON PROCESSING AND AND SYSTEM INDICATION DISPLAY INDICATION AREA AREA AREA U

IL CCS CONTROLLER, CCS SWITCH, AND OPERATOR WORK SURFACE AREA CONTROLS SECTION U

FIGURE 2.12.3 - 1 CONTROL PANEL LAYOUT CONFIGURATION

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a: . w ELECTRICAL SYSTEMS TASK GROUP .

COMMENTS ON CE SYSTEM 80+ ITAAC i 6

Contact:

Dale Thatcher, EELB, (301) 504-3260 Seneral:

e In the following comments, any comment to add something should be-  :

interpreted as identifying a need for inclusion in the DD as well as inclusion  !

in the corresponding ITAAC unless specifically stated otherwise.

2.6.1 Electrical Power Distribution System (EPDS) 3

1. The CE EPDS is basically intended to cover all the electrical  :

distribution systems in the plant. There is sianificant Design  ;

Description (DD) and corresponding ITAAC information that needs to be supplied. Particularly for the de portion of.the system, the vital ac .

portion of the system, the containment electrical penetrations.  ;

Supplement the information (both DD and ITAAC entries) including describing the important features of the Class lE portion of these systems and briefly describe the non-1E portions.

2. The DD should acknowledge that the EPDS includes the electrical protection devices for the distribution system equipment.

3. The dc power for the GCB should be specified as Non Class IE.

4. The UATs and RATS should be specified as having oil pits,' drains, and fire deluge systems.

5. The design commitment that the UATs are separated from each other is.

probably not Tier 1. Similarly their separation from the UMT. is l probably not Tier 1. Consider removing this.

6. The separation distances for the UATs, RATS, etc. and other provisions (e.g. separate raceways, barriers) could be part of the ITAAC acceptance criteria alone and could be deleted from the DD.

7. The Divisional designations (Division I and II) should be on the figures as appropriate - see figure 2.6.1-1.

8. Although the EPDS DD is organized into two subsections - the Non-Class 1E subsystem and the Class IE subsystem, the subsections then appear to be mixing the descriptions of the two together. See for. example the paragraph on medium voltage switchgear and their load requirements.

Correct this and verify that all Tier 1 electrical aspects have been adequately treated in both subsections or prepare a common subsection to 1 deal with ' electrical aspects (such as capacity, faults currents, breaker t coordination) that' apply to both. '

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9. The statement " Medium voltage switching devices may be closed by manual action without their control power" does not appear to be a Tier 1 type commitment. This is typically a basic feature of all such equipment.

Therefore unless there is some overriding reason (e.g. PRA key feature) for including this, it could be removed.

10. The paragraph on protection for containment electrical penetrations is inadequate. All penetrations must be protected and qualified. Address this.

11. The Figures need to show the full scope of the Class IE system. For example Figure 2.6.1-1 should show distribution circuitry down to the lower voltage levels to match up with the next figure (2.6.1-2). It should possibly also extend down to the loads.

On the other hand, Figure 2.6.1-1 may show too much detail in the Non-Class 1E area of the plant. For example the spare equipment should not be needed in Tier 1. Reconsider your level of treatment of this Non-lE equipment.

12. Verify that the DD for harmonic distortions was included because of 1 unique design features of the CE 80+ design (such as control for motor driven feedwater pumps).

13. Include DD/ITAAC for degraded voltage protection (refer to SRP BTP PSB-1).

14. Address Main Control Room and Remote Shutdown displays / controls.

15. Include a commitment addressing connections between divisions / channels

- there should be no auto connections. Manual connections (if any) are interlocked.

16. Address seismic classification in the DD.

17. Address harsh environment qualification in the DD.

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18. The DD for independence only addresses the two " divisions". The independence of the four " channels" (for the de and vital ac subsystems) need to be addressed because these four channel power supplies are also l to be independent per the SSAR. '

19. Verify that the following are clearly covered for all aspects of the EPDS (including at, dc and vital ac power subsystems):

-capacity

-short circuit withstand

-circuit protection (breaker) coordination analyses

-voltage drop analyses

-independence and identification inspections 2 ELECTRICAL an d

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20. The Interfaces should address the need for independent switching stations.

21. Clarify if the term load centers is intended to cover MCCs and power centers.

22. Include a commitment that the Class lE divisional at is supported by the corresponding divisional dc.

23. Expand the identification commitment to include Class 1E equipment other than just the cables and raceways.

24. In some case the DC of the ITAAC contains information that only needs to-be in the AC. Revise as necessary.

25. The isolated bus duct appears to be covered but not the segregated bus duct. Justi fy.

26 The ITAAC should cover the cables and bus ducts for load carrying capacity and for short circuit withstand.

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s a 2.6.2 (Onsite) Standby AC Power Sources

1. To avoid potential confusion over the terms "onsite" and "offsite" power, remove the term "onsite" in the title and the text.

2. Clarify the scope of this DD vs the EPDS DD. They should match up.

Also provide a scope type statement that the combustion air intake, ,

starting air, fuel oil, lubricating oil, engine cooling water engine exhaust / silencer, generator excitation and regulating systems are included here.

3. For the EDG and its Auxiliaries, address seismic category and ASME code class.

4. Include a statement that the EDG and its auxiliaries are separated from the other EDG and auxiliaries.

5. In general equipment protective features are not treated in Tier 1.

Consider deleting the DD discussion of EDG equipment protection functions. Similarly, consider deleting the alarms for the EDG protection function bypass and inoperability status. It is our understanding the these latter items are covered in the PPS.

6. For the ITAAC, include a test of the EDG loading sequence to demonstrate the adequacy of the analysis for the EDG ability to accept loads in a time sequence which is compatible with the accident analyses (e.g. the LOCA loads are loaded on within x seconds). Include voltage and frequency tolerances as part of the acceptance criteria during the loading test.

7. Include a DD statement regarding the EDG response to the existence of both an SIAS and LOP signal. In addition, for the ITAAC test for EDG start on the various signals (LOP, SIAS,CSAS, EFAS) include acceptance criteria for the voltage and frequency tolerances within 20 seconds.

8. The commitment regarding the EDG test mode should state that it resets to its standby mode.

9. The EDG MCR displays should include watts and VARs.

10. The commitment for the EDG to start and run its largest load at the end of auto loading is probably not Tier 1. Consider removing it.

11. Address remote shutdown or local panels displays / controls for the EDG.

12. State that the CT is an Alternate AC source and that it is a self-contained unit equipped with its own supporting / auxiliary systems (i.e.,

independent of the EDGs).

13. Include the CT capacity to supply the SB0/ safe shutdown loads.

14. Address the CT displays and controls as appropriate.

4 ELECTRICAL

c. 6 2.7.26 Liahtina System l

1. There are parts of the lighting system that are classified as Class lE as described in the SSAR. Therefore the statement that lighting is non i safety related does not appear to be totally accurate. The statement could identify the normal lighting as non safety related.

2. The descriptive information should include a discussion of the dc self contained battery operated emergency lighting units. This should i include function, Class 1E classifications, and capacity and operation.

3. The lighting circuits include " associated circuits." This needs to be '

included in the SSAR and the Tier 1 DD. The independence of the  ;

circuits need to also be included in the DD. l

4. The identification of the Class lE and " associated" circuits (cables, raceways) and divisional routing need to be addressed.

5. Seismic Category should be addressed for the Class lE portion.

6. Consider addressing the illumination levels (10 ft candles) in the main control room and remote shutdown DD/ITAAC instead of here.

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ADDITIONAL ELFCTRICAL COMMENTS ON OTHER DD/ITAAC

1. A number of fluid / mechanical systems include design commitments regarding Class lE power requirements. Typically there are commitments that equipment is powered from its " respective division". In some cases the division is specified either on a figure or described in the design description. This is acceptable. However in other cases the division l is not clearly specified. Two examples are the pressurizer heaters and '

the MCR HVAC. Correct this for all cases were the " respective division" is not clearly specified.

In addition, it is noted that the related independence requirements for the electrical divisions is not addressed in the fluid / mechanical l systems. Justify why this is not needed.

f 2. In some systems (e.g. shutdown cooling-2.3.2, containment spray-2.4.6) within division assignments to separate buses is specified for pumps.

It is our understanding that this is important from the PRA and l therefore included in Tier 1. Justify why other electrical equipment such as corresponding valves, etc are not similarly specified.

3. The PPS (2.5.1) and ESFAS (2.5.2) DD state that the "... channel is powered from its respective Class IE bus". This does not adequately l reflect the important design consideration. There should be a tie to the respective divisional / channel power source.

4. In some limited cases, there are non-Class lE equipment supplied by Class IE divisions that should be identified in the DD/ITAAC where the equipment / components are addressed. One example is the pressurizer .

heaters. Lighting is another. There may be severe accident loads also.

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REACTOR SYSTEMS TASK GROUP COMMENTS l ON CE SYSTEM 80+ ITAAC l

Contact:

Mark Rubin. SRXB. (301) 504-3234 General

1. Generic guidance provided to the staff specifies that key numerical values, required to support a reasonable assurance determination, shall be included in ITAAC Design Descriptions. Please include these values as specified in the individual system comments. ,

2. Please modify the appropriate figures to indicate which instruments are included on the Remote Shutdown Panel (RSP). It is not necessary to include these features in the Design Description, as the RSP ITAAC will include the description.

3. It is, at times, unclear which CESSAR Chapter 14 tests are satisfied by a given ITAAC. Please modify the CESSAR such that individual preoperational tests reference the ITAAC which satisfies them.

4. Numerous Inspections, Tests and Analysis entries make reference to analyses to be performed in support of verifying Design Commitments.

When such references are made, the analysis method must be described in the ITA column or in the CESSAR. Please review the following ITAAC ITA entries and provide the appropriate analysis methods in the CESSAR.

a. Shutdown Cooling System 2, 3, 5, 10

b. Safety Depressurization System 2, 3

c. Safety Injection System 2, 8 1 REACTOR SYSTEMS

. 1 2.2.1 NUCLEAR FUEL SYSTEM

1. Your submittal of ITAAC for the nuclear fuel system indicates that it is a Tier 1 item. However, the only Tier 1 Fuel and Control Rod items '

should be limited to General Design Criteria (GDC) type requirements and the broad design commitments which will remain applicable to the initial core and to all reload core designs. These can be captured by applicable GDC and major Standard Review Plan requirements.

2. Fuel and control rods are consummable components and are not Tier 1 items. The fuel design has been specified and the analyses results have been presented in CESSAR. Startup tests to confirm specified nuclear and thermal-hydraulic design parameters should be described in Chapter 14 of CESSAR, and are subsequent to fuel loading. Therefore, ITAAC are not appropriate. Any changes to the initial core design from that presented and evaluated in CESSAR will require prior NRC review and approval .

3. Please specify the completa design commitments and acceptance criteria -

for all fuel and control rod replacement designs and the NRC approved analysis methods that will be used to show conformance to these criteria. These should include the Design Commitment and Acceptance Criteria (but not the ITA) columns of the ITAAC Table which you submitted as well as Figures 2.2.1-1 thru 2.2.1-3.

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2.3.1 REACTOR COOLANT SYSTEM

1. Please enhance the Design Description to include the following:

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a. A specification that System 80+ is a Pressurized Light Water Reactor and that the RCS acts a boundary to fission product release

b. A description of Reactor Pressure Vessel (RPV) penetrations

c. A description of the control rod drive mechanisms (CRDMs) (or l generate a separate ITAAC section on the CRDMs)

d. A more detailed description of the Steam Generators (SGs) (e.g.

vertical U-tube, number of main steam lines)

e. A more detailed description of the Reactor Coolant Pumps (RCPs)

(e.g. vertical, shaft sealed)

f. A description of the RCP anti-rotational devices and the pump speed transducers 9 A description of RCP seal injection

h. A description of Pressurizer (Pzr) Spray, including manual and automatic actuation, spray valve type and power supniy, and block valve purpose, type and power supply

i. Bases for the Main Steam (MS) and Direct Vessel liijectior. (DVI) nozzle sizes J. Descriptions of the design and purposes of the Refueling Heated Junction Thermocouples (RHJTCs) and the Core Exit Thermocouples (CETs), and the electrical classifications for the RHJTCs and the CETs

2. Please add the following information to the Design

Description:

a. System design pressure,and temperatures

b. System fluid flow rate (per the assumptions in the accident analysis)

c. System volume, with a description of pressurizer volume sufficient to ensure system pressure response consistent with the accident analysis

d. Pressurizer safety valve relief capacity (either a quantitative specification or a design basis qualitative specification)

e. Reactor Coolant Pump (RCP) coastdown characteristics

• Add appropriate ITAAC verification for these items

3. Page 2, paragraph 5 In the last sentence, for those instrument loads not powered from Class lE sources, please describe their sources.

4. Figure 2.3.1-1

a. PRA insights indicate that the Pzr spray block valve is an important design feature. Please add this valve to the figure and incorporate it into the Design Description.

b. The wide range level transmitter representations on this figure are misleading. The graphic representations of the low pressure taps i are confounded by a series of breaks in the lines at the connections to the Shutdown Cooling System (SDS) loop connections. Please clarify this figure for ease of readability.

3 REACTOR SYSTEMS

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5. Figure 2.3.1-2

a. Please add representations of Pzr level transmitters.

b. Within the Safety Depressurization System (SDS) interfaces on this figure, please differentiate which lines lead to the Reactor Coolant Gas Vent Subsystem (RCGVS) from those which lead to the Rapid Depressurization Subsystem (RDS).

6. Figure 2.3.1-3

a. Please include this figure in the CESSAR or indicate its basis.

b. Please provide a representation of the Shutdown Heated Junction Thermocouple (SDHJTC) on this figure.

7. Figure 2.3.1-4 Please indicate the point of Emergency Feed Water System interface.

8. Table 2.3.1-1, item 2 Please specify that the type test to be performed to determine Pzr safety valve capacity must be performed at rated temperature and pressure or, in the alternative, describe analysis methods that will convert test results to design conditions in the CESSAR.

9. Table 2.3.1-1 Generic staff guidance requires the existence of ITAAC which verifies independence for electrical and I&C systems as follows:

Design Commitment Independence is provided between Class IE Divisions, and between Class 1E Divisions and non-Class 1E equipment, in the System.

Inspections, Tests, Analysis

1. Tests will be performed in the System by providing a test signal in only one Class 1E Division at a time.

2. Inspection of the as-installed Class 1E Divisions in the System will be performed.

Acceptance Criteria

1. The test signal exists only in the Class 1E Division under test in the System.

2. Physical separation exists between Class 1E Divisions in the System. Physical separation exists between Class 1E Divisions and non-Class 1E equipment in the System.

I Please include ITAAC for the RCS which satisfy these verification requirements.

10. Table 2.3.1-1 Generic staff guidance requires the existence of ITAAC which verifies physical separation as follows:

Design Description Each mechanical division of the System is physically separated.

4 REACTOR SYSTEMS

s o Inspection, Test, Analysis Inspections of the as-built System will be performed.

Acceptance Criteria Each mechanical division of the System is physically separated from the other mechanical divisions oT the System by structural and/or fire barriers (with the exception of ).

Please include ITAAC for the RCS which satisfy these verification requirements.

11. Reference Information, Relationship of Safety Analysis to the RCS It is the opinion of the staff that key parameters, identified in comment 2, above, should be included in this section. Please add these parameters to the reference information.

12. In " System 80+ PRA Assumptions and Insights," provided to the staff by ABB-CE, item C.2 states that the spray control valves will not open if ,

instrument air to the valve actuators is lost. While the staff feels that this fact is adsequately captured in the " fail closed" distinction made in Figure 2.3.1-1, it is our opinion that this fact should be considered a " Major Design and Performance Assumption" in the PRA insights document.

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a s 2.3.1 Reactor Coolant System (Structural Task Group Comments)

Desian Description (DD)

1. The DD should be modified to state that the RPV pressure boundary welds l are ultrasonically examined in addition to the radiographic examination l performed during fabrication in accordance with the requirements of ASME Code Section XI. (Georgiev/ECGB)

2. The DD should be modified to state that 6 capsules for accommodating the ,

material surveillance program will be placed in the RPV. (Georgiev/ECGB)

3. The DD should be modified to state that the RCS pressure boundary  :

components are designed and constructed in accordance with the ASME  :

Boiler and Pressure Vessel Code,Section III, Class 1 requirements. l (Georgiev/ECGB) l Fiaure 2.3.1-3

4. Dimension G, which shows distance from the reactor pressure vessel top  ;

flange surf ace to the lower end of the in-core instrumentation nozzles, is misleading. In addition, it is unclear why the word " REFERENCE" is shown instead of providing dimensional tolerance as indicated for other dimensions. Revise Dimension G to indicate the length of the reactor pressure vessel from its top flange surface to the lowest point of the vessel bottom head and replace the " REFERENCE" by specifying the tolerance of Dimension G. (Hou/ECGB)

5. Provide a new figure showing the location of the 6 specimen capsule holders as shown on Figure 5.3-4 of the CESSAR 80+ SSAR. (Georgiev/ECGB)

ITAAC Table 2.3.1-1

6. Add the following RCS ITAAC item:

Design Commitment - The RCS pressure boundary components are designed and constructed in accordance with the ASME Boiler and Pressure Vessel Code,Section III, Class I requirements. (Georgiev/ECGB)

Inspections, Tests, Analyses - Inspection of the ASME design reports will be conducted. (Georgiev/ECGB)

Acceptance Criteria - The ASME Code,Section III design reports exist for the RCS pressure boundary components. (Georgiev/ECGB)

7. The SSAR, Section 3.9.3.2 specifies that the pressurizer safety valves were tested in the EPRI Test Program under full flow and full pressure conditions. Add the following sentence at the end of Item 2 under Inspections, Tests, and Analyses: "lhe pressurizer safety valves are tested under full flow and full pressure conditions." (Huang /ECGB) 6 REACTOR SYSTEMS P

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a o 2.3.2 SHUTDOWN COOLING SYSTEM

1. Please enhance the Design Description by discussing the following system features: *

a. IRWST cooling capability

b. System actuation and flow paths

c. Pump minimum flowpath and miniflow heat exchanger,

d. CCW cooling to the SCS pumps

e. The basis for the system heat removal capacity

f. Provisions for powering the system from off-site Diesel Generators (EDGs), or combustion turbines, sources, Emergency

• Add appropriate ITAAC verification for these items

2. Please add the following information to the Design

Description:

a. System heat removal capacity

b. Setpoint and capacity of LTOP relief valves

c. SCS/ CSS pump design flowrates and discharge head

• Add appropriate ITAAC verification for these items

3. Page 1, paragraph 10 Please enhance this paragraph by specifying that the pumps can be " full flow tested" as opposed to " flow tested." Please modify ITAAC 7 to indicate this.

4. Page 1, paragraph 13 Please include a thorough discussion of ISLOCA upgrades within the SCS.

Include a discussion of system design pressure inboard of the outboard Containment Isolation Valves (CIVs).

5. Page 2, paragraph 3 Please enhance this paragraph to identify the limiting system case for NPSH (e.g. IRWST cooling following steam discharge to the IRWST, if appropriate).

6. Page 2, paragraph 4 f Please indicate that divisional containment isolation valves are powered l from different buses within the division. i

7. Page 2, paragraph 6 This paragraph indicates that SCS suction valves are interlocked such that they will not open if RCS pressure is above the LTOP relief valve setpoint, implying that the interlock setpoint is based upon the LTOP relief valve setpoint. The CESSAR, page 5.4-28 item 5.4.7.2.3.A.2, implies that the interlock is based upon not exceeding SCS design pressure. Please reconcile these statements.

8. Figure 2.3.2-1 Please indicate the existence of the flow limiting device referred to on page 1, paragraph 8. Additionally, the 6500 gpm flow limit associated with this device could not be found in the CESSAR. Please include this l value in the CESSAR.

7 REACTOR SYSTEMS

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9. Figure 2.3.2-1 Please include the SCS pump minimum flow line and heat exchanger to the figure.

10. Table 2.3.2-1, item 2

a. The staff strongly recommends changing the portion of the acceptance criteria which refers to cooldown criteria, as the conditions necessary to demonstrate this will be difficult to achieve prior to 1 fuel load.

b. In sentence 3 of the acceptance criteria, please replace " heat exchanger" with " division."  !

11. Table 2.3.2-1, item 3 l Please specify that shop tests will be performed at prototypical i conditions or describe the analysis which will be performed to convert ,

test data to design conditions in the CESSAR.

12. Table 2.3.2-1, items 4 and 5

a. Please include associated discharge heads in the acceptance criteria for these items.

b. Please provide a basis in the CESSAR for the 6500 gpm value in the acceptance c.riteria for item 5.

c. Please modify item 4 to verify that flow can proceed in either direction at the SCS/ CSS pump suction cross connect, consistent with paragraph 7 of page 1.

13. Table 2.3.2-1, item 7 Please provide an associated discharge head for the flow verified in the acceptance criteria.

14. Table 2.3.2-1, item 10 Please modify the ITA portion of this item to indicate that determination of adequate NPSH will include such factors as:

• pressure losses for pump inlet piping and components

• design basis fluid temperatures l

• IRWST level and containment pressure (if IRWST cooling represents l the limiting case for NPSH) l

• required NPSH based upon vendor test reports for the specific, as-built, pump involved i 15. Please modify the CESSAR Chapter 14 SCS preoperational tests to include the ITAAC tests of items 5, 6, and 15 of Table 2.3.2-1.

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l 16. Table 2.3.1-1 i Generic staff guidance requires the existence of ITAAC which verifies i independence for electrical and I&C systems as follows:

i Design Commitment Independence is provided between Class IE Divisions, and between Class IE Divisions and non-Class IE equipment, in the System.

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l Inspections, Tests, Analysis  !

1. Tests will be performed in the System by providing a test signal l in only one Class 1E Division at a time.

2. Inspection of the as-installed Class IE Divisions in the System will be performed.

Acceptance Criteria

1. The test signal exists only in the Class lE Division under test in the System.  ;

2. Physical separation exists between Class IE Divisions in the  !

System. Physical separation exists between Class 1E Divisions and non- l J

Class 1E equipment in the System.

Please include ITAAC for the SCS which satisfies these verification requirements for Class IE/non-1E separation.

17. Reference Information, Relationship of SCS to Safety Analysis  ;

It is the opinion of the staff that key parameters, identified in comment 2, above, should be included in this section. Please add these parameters to the reference information.

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18. In " System 80+ PRA Assumptions and Insights," provided to the staff by ABB-CE, item A.5 states that the SCS pumps will have a shutoff head of at least 600 psi. As this is considered, in the PRA insight document, to be a major design and performance assumption, it is the opinion of the staff that this value should be verified by ITAAC. Please include an item in Table 2.3.2-1 to verify this value. Additionally, this value could not be verified in the CESSAR. Please update the CESSAR accordingly.

9 REACTOR SYSTEMS

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• 2.4.1 SAFETY DEPRESSURIZATION SYSTEM

1. Please enhance the Design Description by discussing the following system features:

a. The conditions under which the system would be employed

b. The method of system actuation

c. The location, number and purpose of spargers

d. The ability to prevent containment heating through depressurization

e. Provisions for powering the system from off-site Diesel Generators (EDGs), or combustion turbines, sources, Emergenc

• Add appropriate ITAAC verification for these items

2. Please add the following information to the Design

Description:

a. Quantitative depressurization rates or system / subsystem flow capacities, as appropriate

3. Figure 2.4.1-1 Please identify those instruments which provide indications to the Remote Shutdown Panel.

4. Figure 2.4.1-1 Please include the RDS line pressure alarms in this figure and in the MCR minimum inventory table.

5. Figure 2.4.1-1 Please indicate the divisional power source for each valve on this figure.

6. Figure 2.4.1-1 The CESSAR indicates that the RDS pressure and temperature instruments are qualified for harsh environments. Please indicate this on this figure.

7. Table 2.4.1-1, item 2 The staff finds this item ambiguous. Please provide the following amplifying information:

a. In the Design Commitment - Please specify the conditions and constraints associated with this con.mitment (e.g. the initially assumed RCS pressure, the basis for the time within which the depressurization will be accomplished).

b. In the Acceptance Criteria - Please provide a basis in the CESSAR for the specified depressurization rate.

, c. Please include a verification of RCGVS valve capacity.

8. Table 2.4.1-1, item 3 i

a. Please include a verification of RDS valve capacity, and include the l

required flow capacity in the CESSAR and a description of the analysis method for converting test conditions to design conditions in the CESSAR.

b. Please include the design basis information, described in the Acceptance criteria for this item, in the Design Description.

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9. Reference Information, Relationship of SDS to Safety Analysis Please include the information presented in this section, and bases for  ;

their values, in the CESSAR.

10. In " System 80+ PRA Assumptions and Insights," provided to the staff by ABB-CE, item C.8 for the SDS states that if the bleed valves in both trains of RDS are opened at the time of onset of core damage, then the RCS can be depressurized to 250 psi before vessel failure occurs.

Please include this feature of the system in the Design Description and provide verification in ITAAC.

Additionally, it is the opinion of the staff that items C.2, C.3, and C.5 should be considered " Major Design and Performance Assumptions" in the PRA insights document. Please consider including these items in Section A of the insights document.

11 REACTOR SYSTEMS

, r 2.4.4 SAFETY INJECTION SYSTEM

1. Please enhance the Design Description by discussing the following system features:

a. SIT isolation valve pressure interlock *

b. SIS pump cooling by CCW

c. Conditions which generate a SIAS

d. SIS pump minimum flow lines

e. Design features provided for ISLOCA concerns

f. Provisions for powering the system from off-site Diesel Generators (EDGs), or combustion turbines, sources, Emergency

g. The source of SIS pump control power

• Add appropriate ITAAC verification for these items

2. Please add the following information to the Design

Description:

a. SIS pump rated flow and discharge head

b. SIS pump runout flow

c. SIT liquid volume and normal operating pressure

d. Minimum SIT and IRWST boron concentrations

e. System response time to a SIAS - specify whether this is with or without an assumed EDG start time

3. Page 1, paragraph 4 Please define the existing sentence as the limiting design basis accident and point out that a DVI line break can be adequately treated with one SIS pump.

4. Page 1, paragraph 7 Please replace " flow" with " full flow."

5. Page 1, paragraph 12 Sentence 2 appears redundant to paragraph 6.

6. Page 2, paragraph 6 Please clarify this paragraph to indicate that, during normal plant operations, the SIT isolation valves receive a confirmatory open signal.

7. Page 2, paragraph 7 Please specify that hot leg injection (HLI) is employed in long term / post-LOCA cooling. Additionally, please explain that only one SIS pump per division can provide HLI.

8. Figure 2.4.4-1 Please precede the text of ncte 2 by a "*."

9. Figure 2.4.4-1 Please add a note indicatino that safety related components on the figure are powered from an a;sociated Class IE electrical division.

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10. Figure 2.4.4-1 Please identify those instruments which provide indications to the Remote Shutdown Panel.

11. Table 2.4.4-1, item 2

a. Please provide a basis in the CESSAR for the 2040 psid value presented in the Acceptance Criteria.

b. Please clarify whether the 40 second system response time, presented in the Acceptance Criteria for item 2b, includes EDG start and load time.

c. Please include a verification of SIT volume in this, or another, ITAAC.

d. Please provide a verification of the line volume from the SIS pump discharges to the DVI nozzles. This volume is assumed to be unborated in the accident analysis and the verification should assure that the as-built volume does not exceed that assumed.

12. Table 2.4.4-1, item 4 To conform to the resolution of open item 6.3.3.1, please include a '

durability test in this item.

13. Table 2.4.4-1, item 5

a. Please modify the Design Commitment to indicate that the SIS pumps can be " full flow" tested during plant operations.

b. Please provide an associated discharge head for the 815 gpm flow value provided in the Acceptance Criteria.

c. Please provide a basis in the CESSAR for the 815 gpm flow value provided.

14. Table 2.4.4-1, item 8 Please modify the ITA portion of this item to indicate that determination of adequate NPSH will include such factors as:

a pressure losses for pump inlet piping cnd components

= design basis fluid temperatures

- IRWST level and containment pressure e required NPSH based upon vendor test reports for the specific, as-built, pump involved

15. The tests described in items 4, 5, 7, and 13 do not appear to be described in CESSAR Chapter 14. Please update the CESSAR as necessary to include all testing specified in ITAAC.

16. Reference Infornation, Relationship of SDS to Safety Analysis The staff me unable to verify the 2040 psid value of item 2 and the K factors of item 5 in the CESSAR. Please include these values in the CESSAR.

17. In " System 80+ PRA Assumptions and Insights," provided to the staff by ABB-CE, item C.4 for the SIS states that SIS pump mini-flow valves are assumed to be open. Figure 2.4.4-1 indicates that minimum flow is controlled by orifices. Please clarify this item.

13 REACTOR SYSTEMS ,

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STRUCTURAL TASK GROUP COMMENTS ON CE SYSTEM 80 + ITAAC

Contact:

Dave Terao. ESGB. (301) 504-3317 A.

GENERAL COMMENT

S Motor-Operated Valve (MOV) and Check Valve (CV) Testina '

1. ABB/CE has not included the description of the function of the active safety-related MOV and CV in all the applicable system design descriptions. Attachment 1 is the staff's proposed design description text entries for MOV and CV. ABB/CE should revise the applicable system-design description to include this information.

2. ABB/CE has not included the table entries in all the applicable system ITAAC tables for testing of the active safety-related MOV and CV designated in the system configurations. Also, the language used by CE for these table entries is not completely acceptable. Attachment 2 is the staff's proposed table entries for MOV and CV. ABB/CE should revise the applicable system ITAAC tables accordingly.

3. In many systems, a phase similar to the following has been used: "The safety-related equipment shown in Figure - is' qualified Seismic Category I." This phrase is insufficient liecause it does not depict. 4 what portion of the system is Seismic Category I and what portion is not. It was agreed previously that a note would appear in the figure stating that all ASME Code Class components in the figure are safety-related. Otherwise, the Design Description must clearly specify the boundaries of the Seismic Category I portion of the system.

Alternatively, state in the Design

Description:

"The ASME Code Class components shown in Figure _ is qualified Seismic Category I."

B. JETRODUCTION 12 General Provisions

1. In Section 1.2 (2), " Tests, or tests and analyses" should be revised to state " Type tests, analyses, or a combination of type tests and analyses."

2. In Section 1.2 (2), the word "as-built" should be reinstated and the phrase, " including associated anchorage," should be movad to state "...

to demonstrate that the as-built equipment, including associated anchorage, is qualified..."

1 STRUCTURAL

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, i 1.3 Site Parameters l

1. Table 1.3-1 (T. Cheng) l I

a. Precipitation (for Roof Design): The maximum rainfall rate should read 19.4 inches per sq. mile per hour and 6.2 inches per sq. mile per 5 minutes.

b. Extreme Wind: The basic wind speed should be provided for both 50-year and 100-year recurrence intervals (i.e.,110 miles per hour and 130 miles per hour).

c. Tornado:

1) The maximum tornado wind of 330 miles per hour should be added to this table.

2) The wind speeds corresponding to each of these missiles should be added to this table.

d. Soil Properties: The minimum shear wave velocity should be at least 1000 feet per second. 500 feet per second appears too low. (This is an open issue in the SSAR that has not yet been resolved). In addition, under liquefaction, add " buried safety-related piping and equipment" after the words " safety-related structures." (Bagchi)

e. Seismology: The shape of the ground response spectra should also be included in the site parameters.

1.4 Fiaure Leaend and Abbreviation list (T. Cheng)

a. The figure legend for building structures is not included in the submittal.

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C. DESIGN OF STRUCTURES. COMP 0NENTS. E0VIPMENT. AND SYSTEMS 2.1.1 Nuclear Island Structures

1. Desian Descriotion

a. The Design Description should include the following:

Containment design pressure Deterministic Service Level C pressure Design ra essure for the IRWST and its components (Bagchi)

b. In the 5th paragraph, the containment is described as free-standing.

As per ABB-CE commitment in July 28, 1993 meeting with the staff, the steel containment vessel will have positive connection with the internal structure and the foundation slab. Add a description of steel containment connection to the internal structure and the building foundation concrete . (Ali)

c. In the 7th paragraph, revise the following phrase to read, " ... are designed and fabricated to ASME Code,Section III, Class MC."

(Georgiev)

d. In the 6th paragraph, line 4, add "(Polar Crane Wall)" after " wall".

(Ali)

e. In the 6th paragraph, add a statement that the polar crane wall aligns with the wall underneath the steel containment. (Ali) I

f. In the description of design basis loads, delete " fire".(Ali)

2. Fiaures 2.1.1-1 throuah 2.1.1-12

a. Provide the following details on the Figures : (Ali)

Elevations for the various levels. (Ali)

Distances between the major walls. (Ali) I 1

Thicknesses of major walls. (Ali) j 1

b. Discrepancies between the Tier 1/ITAAC material and the CESSAR  ;

figures are noted as follows : (Ali) j In the fourth paragraph of the ITAAC design description, the RB description refers to Shield Building (SB). CESSAR Figure 1.2-2 refers to the same structure as Shield Wall.

ITAAC figures refer to the vent at the top as " Unit Vent".

CESSAR refers to this vent as the " Vent Stack".

l Reconcile the overall width of 434 ft in Figure 2.1.1-1 of ITAAC with the corresponding dimension in Figure 1.2-3 of i

3 STRUCTURAL

CESSAR. Similarly reconcile the overall width of 326 ft in Figure 2.1.1-2 of ITAAC with the corresponding dimension in Figure 1.2-2 of CESSAR.

c. Revise Figure 2.1.1-1 to indicate the finished grade level. (Ali)

d. The use of

• 2 ft tolerance for building embedment and

• 3 ft and i 4 ft for building dimensions appear to be too large. Discuss the appropriateness of a smaller tolerance (This comment applies to all building system ITAAC). (Ali)

e. From the description of non-seismic category I structures in Figure 2.1.1-12, it appears that Unit Vent is a seismic category I structure. If so, clarify if the Unit Vent is designed to resist tornado generated missiles. (Ali) _

3. ITAAC

a. Provide the design commitment, ITAAC and acceptance criteria for the depth of the basemat below the finished grade level. (Ali)

b. There should be entries to verify the containment shell material, fracture toughness requirement. (Bagchi)

c. The acceptance criteria in 2.b) should state that the results of the pressure are in conformance with the Code required acceptance criteria. (The words used here are also repeated in all the ITAACs that require pressure testing and they are incorrect in all the ITAACs. They should be changed throughout). It should be noted that the testing requirement in Subsection NE 6000 only specifies that a minimum of 1.1 times the design pressure should be used in the test; the staff requirement is 1.15 time the design pressure.

Also, the code does not say that a pneumatic test has to be performed. Therefore, under ITA it should be clearly stated that a pneumatic test at 1.15 times the design pressure should be conducted. (Bagchi) 4 STRUCTURAL l

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• 2.1.2 Turbine Buildina

1. Desian Description  !

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a. The design basis loads such as earthquake should be defined in the  !

Design Description if they are different from those for the NI and NA. (Ali)

b. The last line in the Acceptance Criteria for Item 2 should be  !

revised to read, " function of the NI structure or other adjoining components." (Bagchi)

2. Fiaure 2.1.2-1 l

a. The figure should more clearly specify the low trajectory turbine  !

missile path zone. Provide a figure which shows the turbine missile '

path such as Figure 1.2-1 of the CESSAR.

]

b. An elevation view (cross-section) through the long dimension of the building should be provided to show the relationship with the other buildings, especially the gap between this building and the NI i structure.  !

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3. ITAAC

a. The SSAR should discuss the scope of the structural analysis report l for the Turbine Building if the as-built reconciliation for the {

Turbine Building is to address a scope different than that for '

seismic Category I buildings. (Ali) i i

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a o 2.1.3 Component Coolina Water Heat Exchanaer Structure

1. Desian Descriotion

a. CESSAR Figure 1.2-1 indicates that there are two CCW Heat Exchanger Structures. The design description seems to indicate that there is only one CCW Heat Exchanger Structure. (Ali)

b. In the description of design basis loads, delete " fire". (Ali)

2. Fioures 2.1.3-1

a. Provide overall construction details such as embedment depth, overall building dimensions, wall thicknesses, and elevations. (Ali

& Bagchi)

b. Correct the typographical error in Figure No, i.e., 2.1.3-1 instead of 2.3.1-1. (Ali)

3. ITAAC

a. In order to verify that the CCW Heat Exchanger Structure is located outside the projected low trajectory turbine missile path (ITAAC

1. 2), a figure should be provided which shows the location of CCW Heat Exchanger Structure relative to the turbine building. (Ali) 6 STRUCTURAL

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2.1.4 Diesel Fuel Storace Structure

1. Desian Description

a. There should be a statement in this section that the fuel lines are protected from tornado missiles.

b. In the description of design basis loads, delete " fire". (Ali)

2. Fiaures 2.1.4-1

a. Provide overall construction details such as embedment depth, overall building dimensions and wall thicknesses. (Ali)

b. If applicable, include the fuel lines that are safety-related.

3. ITAAC

a. In order to verify that the DFSS Structures are located outside the projected low trajectory turbine missile path (ITAAC #2), a figure should be provided which shows the location of DFSS Structures relative to the turbine building. (Ali) 7 STRUCTURAL

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2.1.5 Radwaste Buildina

1. Desian Description

a. The design basis loads such as earthquake should be defined in the Design Description if they are different from those for the NI and NA. (Ali)

2. Fiaures 2.1.5-1 throuah 2.1.5-2

a. An elevation view (cross-section) through the building should be provided to show the relationship with the other buildings, especially the gap between this building and the NI structure. (Ali)

b. Section view in Figure 2.1.5-2 cannot be identified from the floor plan in Figure 2.1.5-1. (Ali)

3. ITAAC

a. The SSAR should discuss the scope of the structural analysis report for the Radwaste Building if the as-built reconciliation for the-Radwaste Building is to address a scope different than that for seismic Category I buildings. (Ali) 1 l

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2.1.6 Reactor Vessel Internals

1. Desian Description

a. The description of major RV internal components appears _ inadequate.

Components such as lower core support structures, instrumentation nozzles and guide tubes, flow skirt, core plate and other core flow distribution structures, CEA and fuel assemblies guide structures, in-reactor surveillance specimen holders, etc. are not described.

Extend the scope of the Design Description of RV internals to cover all major components. (Hou)

b. As indicated in the last paragraph of the Design Description, it appears that the RV internals are designed only to withstand the effects of flow induced vibration caused by operation of the reactor coolant pumps. This is not complete, since the design is also intended to ensure structural adequacy and safety functions of the RV internals under other loads, including events of thermal transients, SSE, and postulated pipe rupture loads. Revise the last paragraph to include design considerations of RV internals other than operational flow induced vibrations. (Hou)

c. The severity of flow-induced vibrations are closely related to '

thermal hydraulic parameters, which are not specified in the design description. Provide a tabulation of hydraulic parameters, including (1) number of loops, (2) design core flow rate, (3) inlet temperature, (4) inlet ID, (5) outlet ID, (6) flow velocity at inlet i pipe, (7) flow velocity at downcomer, (8) flow velocity at core inlet, (9) flow velocity at outlet pipe, (10) coolant pump ,

rotational speed, and (11) number of coolant pump blades. j 1

In addition, because the design of System 80+ RV internals is  !

essentially identical to the prototypical design of the RV internals l in the Palo Verde plant, this similarity should be discussed in the Design Description. (Hou)

d. Add the following design commitments:

The effect of irradiation on the properties of the materials is considered in the design of the reactor internal structures. ,

Cobalt-base material is used only for hard surfacing of wear j points.

Cold-worked austenitic stainless steel is not used in the reactor internals.

Stainless steel materials are supplied in solution heat-treated condition. (GBG) 9 STRUCTURAL

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2. Fiaures 2.1.6-1 and 2.1.6-2

a. Figures 2.1.6.-1 and 2.1.6-2, as indicated in Item 1 of the ITAAC, are intended to be used for inspection of the as-built RV internals i to verify their in conformance with the basic configurations of the l certified design. Configurations of some major components, such as lower core support structures, instrumentation nozzles and guide -

tubes, flow skirt, core plate and other core flow distribution structures, CEA and fuel assemblies guide structures, in-reactor surveillance specimen holders, etc. are either not clearly identified or not included. In addition, no dimensions of key components are given.

Provide figures with clear views of major components and with key dimensions. You may tabulate key dimensions and design parameters to include the following: (1) For core support barrel, show length, diameter, outlet nozzle number and diameter, and number of lateral constraints. (2) For lower support structure, show cylinder height and diameter, and main beam number, thickness and height. (3) For upper guide support barrel assembly, show barrel length, diameter and thickness, flange OD, CEA guide tube number, and fuel alignment plate diameter arid thickness.

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2.1.7 In-core Instrument (ICI) Guide Tube System

1. Desian Description

a. The DD should discuss the design basis loads (e.g., normal operation, seismic, pipe break) considered in the structural design of the ICI guide tube system. (Terao/ECGB)

2. Fiaure 2.1.7-1

a. Figure 2.1.7-1 appears inadequate as an inspection guide to verify basic configurations of a certified design. The drawing does not provide any elevations, dimensions, seal and isolation measures, size and thickness of the guide tubes, and configuration of guide tube supports.

Figure 2.1.7-1 should also show elevation of the seal table in relation to the elevation of the reactor pressure vessel, a cross section of the guide tube and its internal instrument tube with dimensions, a sketch to express locations of seal and isolation devices, and a typical configuration of guide tube supports with basic dimensions. (Hou)

3. ITAAC:

a. Since ICI guide tubes, supports, seal housings and seal table are ASME Code Class 1 components, an inspection of the Code required design report document is needed but is not included in Table 2.1.7-1.

Add an item to the ITAAC shown in Table 2.1.7-1 to indicated that an inspection will be performed to the ASME Design Report Document for verifying Code compliance. (Hou)

b. Item 2 in the third column of Table 2.1.7-1 indicates that the pressure test results should conform with testing criteria in ASME Code Section III, which may be misleading. Insert " acceptance" in front of the word " criteria" and specify particular part of the Code that requires the pressure test.

c. An ITAAC entry is needed to verify that the as-built configuration is reconciled with the as-designed configuration for the ICI guide tube system. (Terao/ECGB) 11 STRUCTURAL

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.l 2.2.4 Control Element Drive Mechanism NOTE: The Table of Contents shows this section to be 2.2.2. Is 2.2.4 an incorrect number?

1. Desian Description ,

a. Control element drive mechanism is neither described nor illustrated. Provide a description of major components and drive mechanism with illustrative figures as necessary. (Hou)

b. The DD should clearly state the number of CEDMs required.

2. ITAAC

a. No ITAAC entries are specified. As a minimum, an ITAAC entry is '

needed to verify the basic configuration of the CEDM system.

b. An ITAAC entry (e.g., a test) is also needed to ensure the functional operability of the control element drive mechanism. (Hou)

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. l 2.3.3 Reactor Coolant System Component Succorts

1. Desian Description

a. The descriptions of component supports are too general and it difficult to visualize what the design of supports are. Based on descriptions so provided, it would also be difficult for a COL licensee to verify the as-built supports are in conformance with the certified design. A figure of the RCS support system would be useful.

b. State that the RCS supports are designed for loads due to normal operation, testing, and accident conditions (i.e., seismic and pipe rupture). (Hou)

c. In the 7th paragraph, " Class 1" should be " Subsection NF."

2. ITAAC

a. An inspection should be performed to ensure that the basic configuration of the as-built component supports are in conformance with the certified design. (Hou)

b. An ITAAC entry is needed to verify that the as-built configuration of the RCS component supports is reconciled with the as-designed configuration.

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1 2.7.7 Demineralized Water Makeuo System l

, 1. Desian Description J

a. Design Description should include the Demineralizer Waste Tank for regenerative waste which is described in Section 9.2.3 of the CESSAR-DC. (Parczewski/EMCB)

b. There is no description as to where this system is physically located. (Bagchi)

2. Fiaure 2.7.7-1

a. Figure 2.7.7-1 should include the Demineralizer Waste Tanks.

(Parczewski/EMCB) 14 STRUCTURAL f

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4 2.7.9 Process Samplina System I NOTE: System 80+ is required to have a Post Accident Sampling System (PASS) which should have the capability to sample and analyze the reactor i coolant and containment atmosphere for dissolved gases, chloride, boron '

and activity in the post-accident conditions. The PASS should meet the requirements of 10 CFR 50.34(f)(2)(viii), Item II.B.3 of NUREG-0737, and Item II.I of SECY-93-087.

In addition,10 CFR 50.34(f)(2)(xvii) requires that hydrogen analysis in the containment atmosphere could be accomplished by the safety-grade containment hydrogen monitor. Since the criteria in Item II.I of SECY-93-087 do not require for PASS to have this function, the applicant should verify that this requirement is met by other systems and reference the system where this is performed.

These are open items in the DSER that have not yet been resolved nor addressed in the SSAR. (Parczewski/EMCB)

1. Desian Description i

a. Design Description should include a description of the specific  !

design features of the PASS which would be needed for taking and analyzing reactor coolant and containment atmosphere samples in the post-accident conditions (i.e. shielding, remote sampling devices, specific analytical tools and procedures). (Parczewski/EMCB)

2. Fiaure

a. Figure 2.7.9-1 should include sampling line for PASS sampling of the containment atmosphere. (Parczewski/EMCB)

3. ITAAC

a. ITAAC should state that the PASS would have to be tested to verify its capability to obtain and analyze the required samples taken in the post-accident conditions and should verify that the shielding requirements have been met. (Parczewski/EMCB)

b. The acceptance criteria should meet the requirements of 10 CFR 50.34(f)(2)(viii), Item II.B.3 of NUREG-0737 and Item II.I of SECY 93-087. (Parczewski/EMCB) l 15 STRUCTURAL i

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2.7.16 Chemical and Volume Control System

1. Desian Descriotion

a. The following functions of the CVCS should be included in the Design

Description:

• Maintaining required volume of water in the RCS by compensating for reactor coolant contraction or expansion resulting from temperature changes or losses or additions of coolant inventory.

• Continuous removal of noble gases from the RCS.

• Control of the primary coolant chemistry in the RCS by addition of chemicals (lithium hydroxide and hydrazine).

(Parczewski/EMCB)

2. Fiaure 2.7.16-1

a. The Dedicated Seal Injection Pump, shown on Figure 2.7.16-1, does not exist in the description of the CVCS in the CESSAR-DC.

(Parczewski/EMCB)

b. Figure 2.7.16-1 should show a flowpath between the Baron Recovery and Recycle System and the letdown line. (Parczewski/EMCB)

c. The direct flow path between the Baron Recovery and Recycle System and the Volume Control Tanks, shown on Figure 2.7.16-1, does not correspond to the CVCS description in the CESSAR-DC. In the described system, the distillate from the boron recovery is collected in the Holdup Tank. (Parczewski/EMCB)

d. Figure 2.7.16-1 does not show that the fluid received by the Boron Recovery System comes not only from the Reactor Drain Tank, but also from the Equipment Drain Tank. (Parczewski/EMCB)

e. Figure 2.7.16-1 does not show the temperature monitor which protects the Purification Ion Exchangers by alarming the operator and reducing the letdown flow on high temperature conditions.

(Parczewski/EMCB) i 16 STRUCTURAL

6 4 2.8.7 Steam Generator Blowdown System

1. ITAAC

a. Item 3 of ITAAC should be expanded to include a requirement that the controls in the MCR will be able to open and close the power operated valves, shown on Figure 2.8.7-1, under different pressures and temperatures encountered during the normal operating and accident conditions. (Parczewski/EMCB) i 17 STRUCTURAL

i 4 3.1 Pioina DAC

1. Desian Description

a. Analysis methods and load combinations are not mentioned.

Add a statement that analysis methods and load combinations used for analysis of piping systems shall be referenced or specified in the ASME Code certified stress report. (Hou)

b. Computer benchmark program is not mentioned. -

Add a statement that computer programs and modeling techniques used for piping system dynamic analysis shall be evaluated using the NRC piping benchmark program. (Hou)

c. Considerations for material design are not mentioned.

Add statements to include the following: For those piping systems using ferritic materials as permitted by the design specification, the materials shall not be susceptible to brittle fracture under the expected service conditions and only intrinsically tough grades of ferritic materials will be used with verification by toughness tests. For those piping systems using austenitic stainless steel materials as permitted by the design specification, the material and fabrication process shall be selected to reduce the possibility of cracking during 60-year service life. Special chemical, fabrication, handling, welding, and examination requirements that minimize.

cracking shall be met. (Hou)

d. For the LBB for the main steam line, the Design Description should state that the LBB portion extends up to the first anchor on the main steam lines outside the containment. (Bagchi)

e. The following editorial comments are provided:

(1) In third paragraph, clarify "ASME Code" as the "ASME Boiler and Pressure Vessel Code." (Hou)

(2) Modify the first sentence in the sixth paragraph to " Piping systems are designed to minimize the effects of erosion, corrosion and to reduce the potential for waterhammer and steam hammer." (Hou)

3. ITAAC

a. In ITAAC #1 listed in Table 3.1-1, an analysis should be added to reconcile the as-built with the as-designed configuration when discrepancies are found during the inspection. The acceptance criteria should state that an as-built piping report exists. The reconciliation analysis results should be documented as required by the ASME Code. (Hou) 18 STRUCTURAL

i D. COMMENTS ON OVALITY GROUP AND SEISMIC CLASSIFICATION 2.1 Desian of Structures. Components. Eouioment. and Systems 2.1.1 Nuclear Island Structures - No comments 2.1.2 Turbine Building - No comments 2.1.3 Component Cooling Water Heat Exchanger Structure - No comments 2.1.4 Diesel Fuel Storage Structure - No comments 2.1.5 Radwaste Building - No comments j I

2.1.6 Reactor Vessel Internals - No comments l 2.1.7 In-Core Instrument Guide Tube System - No comments 2.2 Reactor 2.2.1 Nuclear Fuel System In the Design Description and Table 2.2.1-1, the control element and  ;

fuel assemblies should be identified as Seismic Category I.

2.2.2 Control Element Drive Mechanism - No comments ,

2.3 Reactor Coolant System and Connectina Systems 2.3.1 Reactor Coolant System - No comments 2.3.2 Shutdown Cooling System - No comments 2.3.3 Reactor Coolant System Component Supports The Design Description states that "the reactor vessel columns, the SG sliding base, bearings, and snubber assembly, and the RCP vertical columns and snubbers are ASME Code Section III, Class 1 and are qualified Seismic Category I." Table 2.3.3-1 contains a similar description. This limited description implies that some parts of these .

supports may not have the same classifications. To avoid this implication, revise the Design Description to state that all of the reactor coolant system component supports are ASME Code Section III, l Class I and are qualified Seismic Class I. In addition, revise Table '

2.3.3-1 to agree with the Design Description.

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. 4 2.3.4 NSSS Integrity Monitoring System (NIMS)

The Design Description correctly states that this system is non-safety- ,

rel ated. However, the Design Description should also state that the systems comprising the NIMS are designed to be capable of performing their function following seismic events that do not require plant shutdown.

2.4 Enaineered Safety Features ,

2.4.1 Safety Depressurization System There is an apparent discrepancy between Figure 2.4.1-1 and SSAR Figure 5.1.2-3 relative to the safety classification of that portion of the reactor coolant gas vent lines downstream of the classification interface between ASME Class 1 and Class 2 at the four solenoid operator valves.

2.4.2 Annulus Ventilation System - No comment 2.4.3 Combustible Gas Control System If applicable, this Design Description should include a Basic Configuration figure of the Containment Hydrogen Recombiner System which identifies the safety classification interfaces. In addition, it should include a statement that all safety-related components in this system are Seismic Category I.

2.4.4 Safety Injection System - No comments ,

2.4.5 Containment Isolation System - No comments 2.4.6 Containment Spray System -No comments 2.4.7 In-Containment Water Storage System - No comments 2.5 Instrument and Control 2.5.1 Plant Protection System - No comments 2.5.2 Engineered Safety Features - Component Control System - No comments 2.5.3 Discrete Indication and Alarm System and Data Processing System - No comments 2.5.4 Power Control System / Process-Component Control System - No comments 20 STRUCTURAL l

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2.6 Electric Power 2.6.1 Electrical Power Distribution System - No comments 2.6.2 Onsite Standby AC Power Sources The Design Description should state that the safety-related portions of the emergency diesel generators are Seismic Category I.

2.7 Auxiliary Systems c

2.7.1 New Fuel Storage Racks - No comments 2.7.2 Spent Fuel Storage Racks - No comments 2.7.3 Pool Cooling and Purification System - No comments 2.7.4 Fuel Handling System In the SSAR Table 3.2-1, the Spent Fuel Pool and the Fuel Transfer Tube Quick Closure are listed as safety-related portions of the Fuel Handling System. If applicable, these items should be identified as safety-related and Seismic Category I in the Design Description and Table  ;

2.7.4-1 of this section.

2.7.5 Station Service Water System - No comments 2.7.6 Component Cooling Water System - No comments 2.7.7 Demineralized Water Makeup System (DWMS)

The Design Description and Figure 2.7.7-1 state that this system is non-safety related. However, in Sheet 6 of SSAR Table 3.2-1, under the DWMS, Note (27) implies that this system contains containment isolation valves and containment penetration piping that is Safety Class 2. The SSAR Figure 9.2.3-1, which is the P&ID for the DWMS, does not show such piping or valves. Please resolve this apparent discrepancy.

2.7.8 Condensate Storage System - No comments 2.7.9 Process Sampling System - No comments 2.7.10 Instrument Air System The Design Description should contain a statement that the containment isolation valves and containment penetration piping ~in this system are qualified as Seismic Category I.

2.7.11 Turbine Building Cooling Water System - No comments 21 STRUCTURAL

s o 2.7.12 Essential Chilled Water System (ECWS)

The Basic Configuration of the ECWS in Figure 2.7.12-1 shows the ECWS to be classified as ASME Class 2 (Safety Class 2). However, the SSAR Table 3.2-1 and SSAR Figure 9.2.9-1, Sheets 1 through 8 classifies the majority of the ECWS as Safety Class 3. Please resolve this apparent discrepancy.

2.7.13 Normal Chilled Water System The Design Description should contain a statement that the containment isolation valves and containment penetration piping in this system are safety-related and are qualified as Seismic Category I. In addition, the Safety Class 2 designation at the top of the expansion tank in Figure 2.7.13-1 should be deleted.

2.7.14 Turbine Building Service Water System - No comments 2.7.15 Equipment and Floor Drainage System - No comments 2.7.16 Chemical and Volume Control System - No comments 2.7.17 Control Complex Ventilation System - No comments 2.7.18 Fuel Building Ventilation System The Basic Configuration in Figure 2.7.18-1 should identify the safety-related portions of this system.

2.7.19 Diesel Building Ventilation System - No comments 2.7.20 Subsphere Building Ventilation System The Basic Configuration in Figure 2.7.20-1 should identify the safety-related portions of this system.

2.7.21 Containment Purge Ventilation System - No comments 2.7.22 Containment Cooling and Ventilation System - No comments 2.7.23 Nuclear Annex Ventilation System The Design Description, Basic Configuration, and SSAR Figure 9.4-8 all indicate that this system is non-safety-related. However, SSAR Table 3.2-1, Sheet 16, shows recirculating units and room recirculating coils as Safety Class 3 and Seismic Category I, and SSAR Section 9.4.9 discusses safety-related functions of essential mechanical equipment room cooling systems. Please resolve this discrepancy.

22 STRUCTURAL

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2.7.24 Fire Protection System The Design Description, Basic Configuration, and SSAR Figure 9.5.1-1 all imply that there are-no safety-related items in the Fire Protection System. However, SSAR Table 3.2-1, Sheet 13 classifies portions of the water spray systems, hose systems and the surge tank as safety-related l and Seismic Category I. In addition, SSAR Section 9.5.1.7.3.C states that sprinkler system piping is seismically restrained to avoid interaction with safety-related items. If the information in SSAR Table 3.2-1 is correct, revise the Design Description, Basic Configuration and l SSAR Figure 9.5.1-1 to agree.

2.7.25 Communications Systems - No comments 2.7.26 Lighting System - No comments l

2.7.27 Compressed Gas Systems The Design Description and SSAR Section 9.5.10 state that there are no safety-related items in this system. However, SSAR Table 3.2-1, Sheet 13 implies that portions of these systems include containment isolation valves and containment penetration piping which is safety-related.

Please resolve this apparent discrepancy.

2.7.28 Potable and Sanitary Water Systems - No comments 2.7.29 Radwaste Building Ventilation System  !

2.7.30 Turbine Building Ventilation System - No comments 2.7.31 CCW Heat Exchanger Structure Ventilation System - No comments l

2.8 Steam and Power Conversion System 2.8.1 Turbine Generator - No comments )

i 2.8.2 Main Steam Supply System - No comments  !

2.8.3 Main Condenser - No comments 2.8.4 Main Condenser Evacuation System - No comments ,

l 2.8.5 Turbine Bypass System - No comments l 2.8.6 Condensate and Feedwater Systems - No comments 2.8.7 Steam Generator Blowdown System - No comments 2.8.8 Emergency Feedwater System - No comments 2.8.9 Condenser Circulating Water System - No comments 23 STRUCTURAL l

~~ . . , . . . . . . . _ . -

2.9 Radioactive waste Manaaement 2.9.1 Liquid Waste Management System The Design Description should contain a statement that the containment isolation valves and containment penetration piping in this system are classified as safety-related and Seismic Category I. In addition, the Basic Configuration, Figure 2.9.1-1 should show this portion of the ,

system as Safety Class 2.

2.9.2 Gaseous Waste Management System The Design Description and SSAR Figure 11.3-1 state that this system is ,

non-safety-related. However, SSAR Table 3.2-1, Sheet 8 implies that this system contains containment Isolation valves and containment penetration piping. If SSAR Table 3.2-1 is correct, the comment in paragraph 2.9.1 above is also applicable to this system. In addition, SSAR Figure 11.3-1 should be revised accordingly.

2.9.3 Solid Waste Management System - No comments 2.9.4 Process and Effluent Radiological Monitoring and Sampling System The Design Description should state that the safety-related items in this system are qualified Seismic Category I.

2.10 Technical Succort Center - No comments 2.11 Initial Test Proaram - No comments 2.12 Human Factors 2.12.1 Main Control Room Although the Main Control Room is located in the Nuclear Annex, which is a Seismic Category I structure, and included in Section 2.1.1, " Nuclear Island Structures", the Design Description should state that the Main Control Room is safety-related and qualified Seismic Category I. ,

2.12.2 Remote Shutdown Room Same comment as that for Section 2.12.1 above.

2.12.3 Control Panels - No comments 3.0 Non-System Based Desian Descriptions & ITAAC 3.1 Pioina Desian - No comments ,

3.2 Radiation Protection - No comments  ;

3.3 Desian-Reliability Assurance Proaram - No comments 24 STRUCTURAL l

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,. t ATTACHMENT 1  ;

DESIGN DESCRIPTION TEXT ENTRIES MOV: TE MITOR-OPERATED VALVES (M(Ns) SHOW ON FI(IRE __ HAVE ACTIVE SAFETY-RELATED RNCTIONS TO OPEN, CLOSE, OR BOTH OPEN #0 CLOSE, MO PERFORM TIESE RNCTIONS (20ER DIFFERENTIAL PRESSLRE, FLUID R0W, AND TEMPERATURE CONDITIONS.

CV: llE GEX VALVES (CVs) SDN W FICIRE _ IMVE SAFETY-RELATED FUCTIWS TD OPEN, CLDSE, OR IKTTH OPEN AND CLOSE, UNDER SYSTEM PRESSURE, FLUID FLOW, AND TEMPERATURE CONDITIONS,

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ATTACHMENT 2 ITAAC TABLE ENTRIES MOV:

Design Comitment Inspection, Test, Analyses Acceptance Criteria MOVs designated in Section Tests of installed valves for Upon receipt of the actuating as having an active safety- opening, closing or both opening signal, each MOV opens, closes, related function open, close, or and closing will be conducted or both opens and closes,

! both open and close under under preoperational depending upon the valve's differential pressure, fluid differential pressure, fluid safety functions. The following

( flow, and temperature flow, and temperature valves open, close, or both open conditions. conditions, and close, in the following time limits:

ValveTime (sec) open close open close NOTE: Table entries in the AC column are required only for valves with stroke times that are important in l

meeting their safety functions. It is not intended that all valves in a system be included in this table independent of safety-significance.

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! ITAAC TABLE ENTRIES CV:

Design Commitment Inspc.;tions, Tests, Analyses Acceptance Criteria CVs designated.in Section Tests of installed valves for Based on the direction of the as having an active safety- opening, closing, or both differential pressure across the related function open, close, or opening and closing, will be valve, each CV opens, closes, or both open and close, under conducted under system both opens and closes, depending system pressure, fluid flow, and preoperational pressure, fluid upon the valve's safety temperature conditions. flow, and temperature function.

conditions.

27 STRUCTURAL

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• SPLB SECONDARY REVIEW COMMENTS FOR STRUCTURAL TASK GROUP 2.1.1 Nuclear Island Structures

1. Desian Description

g. Page 2 of ITAAC 2.1.1 lists the areas of Nuclear Annex. Since Nuclear Annex houses the GWMS (See CESSAR-DC, Section 11.3.1.2, Item B.1), include the area which houses the GWMS among the listed areas of Nuclear Annex. Show this area in the Figure 2.1.1. (SPLB)

h. Clarify whether the portion of the Nuclear Annex that houses the GWMS is part of the basic configuration. Note that this portion has to meet Position C.5 of RG 1.143 with respect to seismic design.

(SPLB)

3. ITAAC j

d. ITAAC Table 2.1.1-1 at Item 2.b, " Inspection, Tests, Analyses", it' states that a pressure test will be conducted on the containment and f its penetrations required to be pressure tested by ASME Code Section III. This statement should be changed to:

"A structural integrity test will be conducted on the containment pressure boundary and its penetrations per ASME Code requirements.

In the table's " Acceptance Criteria", cl.ange "the results of the pressure test" to "the results of the structural integrity test".

(SPLB)

e. ITAAC Table 2.1.1-1 at Item 2.c, " Acceptance Criteria," change "at the leakage rate test pressure" to "at the peak containment pressure for the design basis accident." (SPLB)

f. ITAAC Table 2.1.1-1 at Item 4, " Design Commitment", it states that flood doors have sensors with open and close status displays provided at a monitored location. Change "at a monitored location" to "at a central fire alarm station." CE has previously committed to make this change in a conference call. (SPLB) -l 28 STRUCTURAL

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• 2.7.16 Chemical Volume Control System (CVCS)

1. Desian Description

b. Add boric acid Concentrator and what it does and the disposition of the concentrates to the design description of the CVCS. (SPLB)

2. Fiaure 2.7.16-1

f. Show the boric acid concentrator in Figure 2.7.16-1. (SPLB)

3. ITAAC

a. Revise Table 2.7.16-1 to reflect the responses for Items 1 and 2 i above. (SPLB)  :

b. At a public meeting held on April 29, and April 30, 1993, ABB/CE l agreed to include an orifice in the design of the letdown line of l the Chemical and Volume Control System (CVCS). This orifice is necessary to limit the flow out of the line in the event of a CVCS letdown line failure outside containment. The acceptabilty of the postulated accident dose consequences relies on this orifice. The ITAAC does not address this orifice. It should be included in the l design description and functional drawing. An ITAAC entry is also needed with an acceptance criteria requiring this maximum orifice diameter. (PRPB - Emch/Eccleston) 29 STRUCTURAL

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P_LANT SYSTEMS TASK GROUP COMMENTS ON CESSAR SYSTEM 80+ ITAAC

Contact:

Jim Lyons. SPLB. (301) 504-2803 2.4.2 ANNULUS VENTILATION SYSTEM

1. Add a sentence: "all major components of AVS are located in the Nuclear Annex" in design description.

2. Table 2.4.2-1, Item 3: Add acceptance criteria of draw-down time to be consistent with dose calculation. Section 6.2.6.5 of the SSAR states that the Annulus Ventilation System pressure test can achieve a negative pressure of -0.5 in, water gauge within 110 seconds. The above SSAR statement can be used as acceptance criteria.

3. Figure 2.4.2-1: Note 1 states that the damper is for tornado protection and isolation with fans are off. Clarify if the above damper is tornado damper.

4. Note: The staff has not completed its evaluation of all potential accidents (e.g., LOCA). If staff concludes that credit for removal of elemental and organic forms of iodine and particulates is warranted to meet offsite accident dose limits and control room accident dose limits, )

the tables for the CPVS, FBVS, AVS, and SBVS ITAACs will require revision. Furthermore, the rad monitors, which will indicate when the i exhausts from the areas serviced by the subject systems have to be diverted through filter systems, should be included among the safety-related monitors in ITAAC 2.9.4. Note that the annulus ventilation system handles the design basis containment leakage and the subsphere building ventilation system handles the ESF leakages from the safeguards rooms.

1

l 2.4.3 COMBUSTIBLE GAS CONTROL SYSTEM

1. This ITAAC item does not have a figurc to represent basic configuration.

Therefore, the verification for " basic configuration" (such as pressure boundary welds, seismic qualification, electrical equipment-qualificaticn, and testing of MOVs), and ASME code class for the system does not exist. Provide a figure to represent the basic configuration.  ;

2. Section 2.4.3 Design

Description:

It is stated that hydrogen recombiner units, if. provided, are safety-related. This is not consistent with SSAR, which has not justified that hydrogen recombiner units can be optional. Delete the phrase "if provided" and add design description for hydrogen recombiners.

3. Table 2.4.3-1: Add ITAAC items for hydrogen recombiners.

t 4 Table 2.4.3-1, Item 4.a: Identify the specific instrumentation in the MCR that will be subject to the inspection. It is not clear which MCR instrumentation related to hydrogen recombiners will be subject to .

ITAAC. '

S 2 SPLB

e n 2.4.5 CONTAINMENT ISOLATION SYSTEM

1. Table 2.4.5-2, Items 19 and 20: The valve arrangement designation (No.

4) is not consistent with the description in the service column. The outboard isolation valves are remotely operated in the service column, whereas they are locked closed in valve arrangement No. 4. ,

2. Table 2.4.5-2, Items 52: The valve arrangement designation (No.1) is not consistent with the description in the service column. There are three remotely operated isolation valves identified in the service column, whereas there are only two in valve arrangement No.1.

3. Table 2.4.5-2, Items 59, 60, 61, and 62: The valve arrangement designation (No. 1) is not correct. These valves are locked closed valves according to the Technical Specifications. Arrangement No. 3 is a better designation.

4. Design Description

a. The DD should state that all butterfly valves in the isolation path are capable of closing against the design basis pressure as well as the service level C pressure. (Bagchi/ECGB)

b. The DD should state that at the seismic margin level earthquake, the containment isolation valves are not susceptible to fail open due to a postulated simultaneous off-site power-loss. (Bagchi/ECGB)

c. The DD should state that low pressure lines are sized for appropriate pressure rating. (Bagchi/ECGB) l l

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4 2.4.6 CONTAINMENT SPRAY SYSTEM

1. Table 2.4.6-1, Item 2.a of Acceptance Criteria: There is a typographic error. The 400 " feed" of head should be read as 400 feet of head.

2. The DD should state that all CSS safety related heat exchangers, pumps and valves are capable of performing their safety functions under the '

design basis and service level C pressure. (Bagchi/ECGB)

Include a thorough discussion of ISLOCA upgrades within the SCS.

3.

Include a discussion of system design pressure inboard of the outboard Containment Isolation Valves (CIVs). (Miller /SRXB) 4 i

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2.4.7 IN-CONTAINMENT WATER STORAGE SYSTEM

1. Table 2.4.7-1, Item 2.a of Acceptance Criteria: It is stated that the IRWST has a useable volume of at least 495,000 gallons above SIS / CSS pump suction line penetrations. Provide basis for this number and list it in the SSAR.

2. Figure 2.4.7-1: Add pressure indicator to the figure.

3. Design Description

a. The DD should state that the IRWST is capable of withstanding the design basis and the service level C pressure. (Bagchi/ECGB)

b. Figure 2.4.6-I: Relative levels of HVT and IRWST should be shown here. (Bagchi/ECGB)

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2.7.1 - NEW FUEL STORAGE RACKS DESIGN DESCRIPTION (DD)

1. The DD should state the capacity of the new fuel racks.

2. The last sentence of the 3rd paragraph should state "... normal operation and postulated accident conditions".

3. Add the following sentence to the design description: "The New Fuel Pool Racks are bolted to embedments at the bottom of the rack storage cavity to preclude tipping." (Ali/ECGB)

4. The DD should state that the racks and fuel are designed to accommodate -

design basis loads and load combinations including the effects of impact of fuel assemblies on the racks and the impact due to postulated fuel handling accidents without losing structural integrity of the racks or the fuel assemblies. (Bagchi/ECGB)

ITAAC

1. Add basic configuration ITAAC entry.

1 I

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2.7.2 - SPENT FUEL STORAGE RACKS DESIGN DESCRIPTION (DD)

1. The DD should state the capacity of the new fuel racks.

2. The last sentence of the 3rd paragraph should state "... normal operation and postulated accident conditions".  ;

3. '

The DD should state that the racks and fuel are designed to accommodate design basis loads and load combinations including the effects of impact i of the fuel assemblies on the racks and the impact due to postulated fuel handling accidents without losing structural integrity of the racks or the fuel assemblies. (Bagchi/ECGB)

ITAAC i

1. Add basic configuration ITAAC entry. I I

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2.7.3 - POOL COOLING AND PURIFICATION DESIGN DESCRIPTION (DD)

1. Identify where the equipment is located (what building)

2. Include a discussion of the high-temperature isolation of the filter demineralizers. ,

3, Are there any other automatic functions? i FIGURE

1. Why are the spent fuel pool, refueling pool, and fuel transfer canal identified as not being part of the PCPS. If they are not part of this system, what system (s) are they in?

ITAAC

1. Add a test to verify the automatic isolation of the filter demineralizers on high temperature. Also, if there are any other automatic functions, they will need to be verified also.

SSAR  !

1. The SSAR does not specifically talk about the cross-connect valves. It 4 only states that the divisions can be-cross-connected. These cross-  !

connect valves MUST be physically and electrically separated to meet single-failure criteria. If the SSAR must be modified to clarify this, then it should be done.

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2.7.4 - FUEL HANDLING SYSTEM DESIGN DESCRIPTION (DD)

1. All key handling equipment should be discussed. Specifically, the following equipment and their key interlocks should be discussed:

NOTE: Some of the interlocks below are already discussed in the ITAAC. This list is given to provide a comprehensive identification for all the interlocks and load handling devices that should be considered in the ITAAC. ,

a. Refueling and Spent Fuel Machines: Both the electrical and mechanical hoist up-stop interlocks

b. Lask Handling Hoist: Electrical and mechanical hoist up-stop incerlocks which prevent lifting a cask > 30' above the floor.

Ele:trical and mechanical interlocks to prevent moving a cask over botl the new and spent fuel rack.s.

c. New Fuel Handling Hoist: Electrical and mechanical interlocks to pravent moving new fuel over spent fuel.

d. Containment Polar Crane: Electrical and mechanical hoist up-stop interlocks.

2. Discuss the location of all key load handling equipment, including the containment polar crane (what building are they in)?

3. Discuss the seismic qualifications of the equipment. Specifically, state that they are designed to hold their loads during an earthquake in addition to holding them on a loss of power.

4. Indicate that the load handling devices are designed to prevent damage to fuel and to move fuel and components such that safe shutdown ,

canability is maintained.

ITAAC

1. Add basic configuration ITAAC.

2. Add ITAAC to ensure that the electrical and mechanical interlocks identified above are verified. '

SSAR

1. Check to be sure that all the key electrical and mechanical interlocks discussed above are discussed in sufficient detail in the SSAR.

2. The SSAR should state that the load handling devices are designed not only to protect fuel, but also to ensure that no more than 1 division of safety-related equipment can be damaged due to a dropped load.

9 SPLB

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-2.7.5 STATION SERVICE WATER - NO COMMENTS l 1

2.7.6 COMPONENT COOLING WATER SYSTEM - NO COMMENTS 1

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i 2.7.8 CONDENSATE STORAGE SYSTEM l

1. Provide location of the system.

2. Provide the standard statements regarding controls and instrumentation in the Design Description.

3. Provide the standard entries regarding controls and instrumentation in the ITAAC.

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6 4 2.7.10 INSTRUMENT AIR SYSTEM

1. The Design Description should state that the safety related equipment (the containment isolation valves and associated penetration piping) shown on Figure 2.7.10-1 are qualified Seismic Category I.

2. The Instrument Air System is one of three subsystems of the Compressed Air System. The Tier 1 information should include a Design Description and at a minimum basic configuration ITAAC entries for the other two ,

systems (Station Air System and Breathing-Air System). )

3.. The DD should state that those parts inside containment should be operable under design basis and the service level C pressures and control valves should not be susceptible to effects of high ambient pressure. (Bagchi/ECGB) >

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2.7.11 TURBINE BUILDING COOLING WATER SYSTEM l 1

1. Provide location of the system.

2. Provide the standard statements regarding controls and instrumentation in the Design Description.

3. Provide the standard entries regarding controls and instrumentation in the ITAAC.

13 SPLB

4. O.

2.7.12 ESSENTIAL CHILLED WATER SYSTEM

1. Provide the specific location of the system with in the Nuclear Island Structures (e.g., Nuclear Annex).

2. The code class shown on the figure is different'than that shown on CESSAR Figure 9.2.9.1.

34 SPLB I

t < s 2.7.13 NORMAL CHILLED WATER SYSTEM

1. Provide the specific location of the system with in the Nuclear Island Structures (e.g., Nuclear Annex).

2. The code class shown on the figure is different than that shown on CESSAR Figure 9.2.9.1.

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2.7.14 TURBINE BUILDING SERVICE WATER SYSTEM

1. Provide location of the system.

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2.7.15 EQUIPMENT AND FLOOR DRAINAGE SYSTEM

1. The Design Description should state that a loss of air to the turbine building floor drain sump A0V's causes the valves to fail in the safe position with the sump discharge isolated and the cross connection to the LWMS open.

2. No instrumentation shown in Figure 2.7.15-1 (Both the Design Description and Note 2 on Figure refer to instrumentation)

3. Indication of the number of divisions or the number of pumps should be clarified in Figure 2.7.15-1.

4. There are discrepancies between CESSAR, CESSAR figures, Design Description, and Design Description figure. For example, CESSAR Section 9.3.3 and Design Description 2.7.15 discuss the Turbine Building Equipment and Floor Drain system, but there are no P&ID's showing this system in either CESSAR Section 9.3.3 or Design Description 2.7.15.

5. CESSAR Section 9.3.3 is missing Figure 9.3.3-5 Sheet 1 "CVCS Equipment Drain Sump System."

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2.7.17 CONTROL COMPLEX VENTILATION SYSTEM (CCVS)

1. Desian Description (DD)

a. The designation of "NI" structures, as described in 1st paragraph of DD, is too general to determine the specific locations of CCVS.

b. 2nd paragraph notation " Air Condition System" differs from the SSAR notation " Air Handling System." Reconcile the difference.

c. The fourth paragraph should read as follows:

"The MCSRACS consists of .... air intake, louver, redundant tornado dampers, system dampers, ... controls."

d. Add a sentence at the end of 7th paragraph on Page 1 as follows:

"In the event of a fire, supply fan may be deactivated manually if required and smoke removal is then manually initiated from the control room or the remote shutdown panel room by a smoke exhaust fan, outside makeup air and associated ductwork and control dampers.

The fire dampers with fusible links in HVAC ductwork close under air flow conditions.

e. Replace the phrase "outside atmosphere" with " surrounding spaces" in first two paragraphs on Page 2.

f. The 6th paragraph on page 2 of DD should read as follows:

"The CCVS serves...the operation support center, non-essential electrical rooms, computer rooms, non-safety battery rooms and other non-essential areas."

g. Add phase "and remote shutdown panel room" at the end of sentences in 7th and 8th paragraph on page 1 and after word "MCR" in last two paragraphs on page 2.

2. Fiaures 2.7.17-1. 2.7.17-2. and 2.7.17-3 Fiqure 2.7.17-1

a. Show redundant tornado dampers, TGs, Rs, and SDs for each outside air intake.

b. Show tornado protection for exhaust points.

Fiqure 2.7.17-2 and 2.7.17-3

a. Show a louver to outside air intake.

b. Show redundant tornado dampers.

c. Areas served by Divisions I and 11 CCVS as shown in these figures do not agree with SSAR Section 9.4.1.

d. Show tornado protection for exhaust points.

18 SPLB

3. ITAAC Table 2.7.17-1 t

a. Replace the phrase "outside atmosphere" with " surrounding spaces" in-  ;

ITAAC " Items 7 and 8.

b. Revise "ITAAC Item 4" accordingly~to incorporate " Item 1.d" above ,

for smoke removal mode. - i.

c. Revise "ITAAC Item 4.c" and "ITAAC Items 13.a and 13.b" to incorporate " Item 1.g" above for remote shutdown panel reference.

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d. Provide ITAAC Item for the fire dampers, with fusible-links in HVAC  !

ductwork, which close under air flow conditions. The " Inspections,  ;

Tests, Analysis" should state that " tests'of fire dampers will be' ,

performed at Vendor's or other certified laboratory for fan closure ,.

under system air flow conditions." This item applies to all HVAC systems under ABB-CE design certification.

e. Provide ITAAC for the concerns identified in Items 4.f and 4.g below '

to preclude unfiltered inleakage inside MCREZ and maintaining the MCRACS integrity.

f. Add an ITAAC item for the emergency filtration unit testing having at least 95% removal efficiency for all forms of iodine (elemental, organic, particulate, and HI) for carbon- adsorber and 99% removal efficiency for particulate iodine for HEPA filters.

4. SSAR Sections 9.4.1 and 6.4

a. Subsection 9.4.1.1 on page 9.4-2 states that "the control building is a seismic category I structure." SSAR Table 3.2-1 on page 23 of 27 does not list " control building." Reconcile the difference. 1 i

b. l Provide your rationale for not providing smoke dampers for the i following and amend SSAR text and table, DD, ITAAC Figures 2,7,17-1, l 2.7.17-2, and 2.7.17-3 and ITAAC ' Table 2.7.17-1 accordingly: 1 SSAR Section 9.4 on page 9.4-1 (last paragraph) indicates that there are more than one smoke control dampers for the control complex.

However,the Figure 9.4-2 (sheets 1 and 2) shows the following:

1) Technical support center air handling system shows no smoke damper. l

2) Nonsafety-related Division II areas including personnel decontamination rooms, break room, and shift assembly offices have a common separate exhaust, but smoke removal function is not provided. Also, Division II area containing Operations-Support Center and OSC equipment room and Divisions I and II duct shaft areas are not provided with a smoke removal function.

19 SPLB

Also, provide smoke and fire dampers classification in SSAR Table 3.2-1 and provide applicable data for smoke and fire of dampers in SSAR Table 9.4-1.

c. Revise SSAR 9.4.1 text and SSAR Figure 9.4-2 (two sheets)-

accordingly to incorporate the information sought'in Item 2 for ITAAC Figures 2.17.1-1, 2.17.1-2, and 2.17.1-3 above.

d. Revise Table 9.4-1 as follows:

1. Sheet 4 of 18 .t a) " Battery Rm. I" and " Battery Rm. II" should be listed as Essential Battery Rooms I" and Essential Battery Room II." Also, Type System should be " exhaust" not

" ventilate." Additionally, provide fan horse power (HP).

b) "Elec. RM. Div I Cha. A" and "Elec. RM. Div I Cha. C" should be " Essential Elec. RM. Div I Cha. A" and

" Essential Elec. RM. Div I Cha. C."

2. Sheet 10 of 18 a) Similar comment as in Item 4.1.d.l.b above for Division II.

b) " Control Building Electric Rooms" should be " Divisions I and II Essential and Non-Essential Electrical Rooms '

and vital instrument and equipment rooms." Also, under heading of " Type System" it should be " smoke purge fan." ,

3. Sheet 11 of 18 a) "Elec. Rm. CEDM Contrel" should be "Non-Essential Elec. Rm. CEDM Control."

b) Provide location of the "Elec. Rm. N1 and N2" and also provide their corresponding data for air and cooling water flows, c) " Battery Rm. I and II" should be "Non-Essential Battery Rm. I and II."

4. Provide remote shutdown panel room heat loads, air and water flows and AHU fan horse power.

e. SSAR Figure 9.4-2 (sheet 1) shows two " Personnel Decon A/C Units."

However SSAR Section 9.4.1.2 on page 9.4-7 and Table 9.4-1 sheet 2 of 18 describes above as " Men's Change" and " Women's Change."

Reconcile the difference.

20 SPLB i

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f. SSAR Section 9.4.1.3 on page 9.4-8 (last paragraph) states that

" ducts that pass through walls, floors, and ceilings of the MCR are bullet resistant. In addition, security barriers (i.e., rebar or segmented ducts) are provided within ducts that pass through vital boundaries." Confirm that no other HVAC system ducts other than MCR air-handling system ducts are passing through the MCR emergency zone (MCREZ). If it is not the case, provide justifications to prevent unfiltered air inleakage inside the MCREZ. Also, provide periodic testing provisions to achieve and maintain MCRACS system integrity in order to maintain the required positive pressure inside MCREZ and prevent unwanted unfiltered inleakage inside MCREZ.

g. SSAR Section 9.4.1.4 on page 9.4-9, Item D states that "ductwork is fabricated, installed, leak tested, and balanced in accordance with SMACNA. Where applicable, duct and housing leak tests are performed in accordance with the provision of ASME N510."

Verify that all MCRACS ductwork outside MCREZ is of welded construction (not bolted flanged type construction). If non-welded ducting is employed, the MCRAC5 will be susceptible to unfiltered inleakage inside MCREZ by those duct portions and other components which will be exposed to the surrounding spaces with higher pressure than the inside ducting pressure (i.e., suction side ductwork to each filtration train, bypass ductwork around each filtration train, l fresh air duct inside and outside MCREZ). Also, the above is true for the MCRACS filtration train housings and A/C unit housings.

Therefore, periodic testing provisions should be made for the above mentioned ductwork and housing to assure there is no unfiltered inleakage, and to ensure that the integrity the MCREZ and MCRACS is maintained.

I

h. SSAR Subsection 9.4.1.1.1.k indicates that the MCRACS filtration trains serving MCREZ conform to the guidance of Regulatory Guide (RG) 1.52. Demonstrate the conformance of R.G.1.52 categorically for the MCRACS filter units. -

j

i. Add the following in SAR Section 6.4.2.1 on page 6.4-2:

"The emergency zone volume is 67,300 ft3, as shown in SSAR Table 15A-10. The maximum unfiltered rate into the control room emergency zone under accident conditions is 10 cfm, as identified in SSAR Tables 9.4.3 and 15A-10."

j. Delete the word " chlorine" in last two paragraphs on Page 6.4-3 and 2nd paragraph on page 6.4-4 of Section 6.4.2.2 and replace it with the word " toxic gas."

k. Add the following in 5th paragraph of Section 6.4.5 on page 6.4-5:

"G. Minimum instrumentation as identified in SSAR Table 9.4-3A."

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1. Revise SSAR Sections 9.4.1 and Table 9.4-1 appropriately to reflect

" safety-related" and "nonsafety-related" designations in lieu of

" essential and non-essential" identified in ITAAC 2.7.17. Al s o ,

state clearly identifying the status of habitability systems and CCVS as " safety-related and/or nonsafety-related" as applicable. l l

The SSAR Section 9.4, including system tables and drawings, generally use " essential"' and "non-essential" designations while HVAC systems ITAACs use " safety related" and "non-safety related" l designations for the systems, structures,and components. Reconcile '

the difference and revise SSAR section 9.4 including associated Tables, System Drawings and SSAR Table 3.1-2 accordingly.

I k

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2.7.18 FUEL BUILDING VENTILATION SYSTEM (FBVS)

1. Desian Description (DD)

a. The designation " nuclear island structures" as described in 1st l

-t paragraph is too general to determine the specific locations of '

FBVS. i

b. Replace the phrase " relative to the atmosphere" with "with respect to the surrounding spaces" in 4th paragraph.

c. Add the following before ITAAC description paragraph:  ;

"In the event of a fire, the exhaust and supply fans can be used for smoke removal. The fire dampers with fusible links in HVAC ductwork i close under air flow conditions."

i Note: The staff has not completed its evaluation of all potential accidents )

(e.g., LOCA). If staff concludes that credit for removal of elemental '

and organic forms of iodine and particulates is warranted to meet offsite accident dose limits and control room accident dose limits, the tables for the CP'IS, FBVS, AVS, and SBVS ITAACs will require revision.

Furthermore, the rad monitors, which will indicate when the exhausts from the areas serviced by the subject systems have to be diverted through filter systems, should be included among the safety-related i monitors in ITAAC 2.9.4. Note that the annulus ventilation system i handles the design basis containment leakage and the subsphere building j ventilation system handles the ESF leakages from the safeguards rooms.

2. Fioure 2.7.18-1

a. Show tornado missile shield for air intake and exhaust points.

b. Show redundant safety-related radiation detectors.

c. Explain what is meant by " damper provided for tornado protection." ,

3. ITAAC Table 2.7.18-1

a. Revise Item 3 by replacing the phrase " relative to the atmosphere" with "with respect to the surrounding spaces."

b. Provide ITAAC item for fire damper (ITAAC Item 2.7.17.3.d).

4. SSAR Section 9.4.2

a. Section 9.4.2.3 calls fore more than one radiation detector.

Clarify the number of radiation detectors provided. Since the exhaust system is safety-related, these radiation detectors should also be safety-related.

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b. Revise Figure 9.4.3 as follows:

1. Show two safety-related radiation detectors.

2. Show tornado damper for the exhaust points of the system.

3. What is the purpose of divisional boundary on the supply side of the system ? ,

c. Verify whether the bypass damper will be administratively locked closed whenever irradiated fuel handling operations which was based on providing a single bypass damper around each exhaust filtration ,

train. However, ABB-CE has provided redundant bypass dampers in response to staff's RAI. If there is no administrative criteria to locked closed bypass damper, the 5th paragraph on page 9.4-11 should be revised accordingly.

d. The 5th paragraph on page 9.4-13 of SSAR Section 9.4 2_? should read as follows: ,

"Each of the filter trains secuentially consists... electric heater, pre HEPA filter, carbon adsorber and post HEPA filter. It is...to monitor radioactivity. Upon indication... exhaust duct system, the redundant bypass damper...to the atmosphere."

e. Add the following as a separate paragraph after 2nd paragraph of SSAR Section 9.4.2.3 on page 9.4-13: ,

"The in-service testing program will be implemented in accordance with 10 CFR 50, Appendix B, Section Xi to allow in-service testing as required by applicable standards and codes."

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2.7.19 DIESEL BUILDING VENTILATION SYSTEM

1. Desian Description (DD)

a. The 1st paragraph should read as follows: 1 "The diesel...to each of the two diesel generator areas inside  ;

Nuclear Annex. The Diesel generator Areas are classified as seismic

• Category I. " i

b. Add the following to the 5th paragraph:

"The fresh air intake is located at least 20 feet above grade. Each safety-related air intake and exhaust penetrations are provided with protection from the external missiles."  ;

c. Add the following as a separate paragraph before ITAAC DD on page 1:

"In the event of a fire, the supply and exhaust fans can be used for smoke removal ."

2. Fiqure 2.7.19-1 l

a. Show protection from external missiles, i.e., tornado missile barrier for all safety-related intake and exhaust points.

b. Explain symbol in the plenum that has "P" and show it on the Figure I Legend.

3. ITAAC Table 2.7.19-1 Provide ITAAC for " Item 1.b" above.

4. SSAR Section 9.4.4

a. SSAR Section 9.6.4.1.1.c should delete "-1988."

b. SSAR Table 3.2-1 refers to " diesel generator areas" under Nuclear Annex. SSAR Section 9.4.4.1 refers to " diesel generator buildings" at various places. Reconcile the difference and revise accordingly.

l

c. SSAR Section 9.4.4.3, paragraph 4 on page 9.4.2.1 should read as follows:

" Essential components of the diesel building ventilation system and diesel aenerator areas housina the system are designed... earthquake."

d. Add a new separate SSAR section "8.3.1.1.4.13" on page 8.3-15 to incorporate RAI Q410.123.3 response. ABB-CE proposed to add above separate subsection.

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e. The DBVS, as described in Section 9.4.4.2Tshould use the. phrase ,

" safety-related" as its used in ITAAC 2,7.19 and state that DBVS is ,

a safety-related system.

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2.7.20 SUBSPHERE BUILDING VENTILATION SYSTEM (SBVS)

1. Desian Description (DD)

a. Add the following in .lst paragraph after 1st sentence:

"The SBVS is located in Nuclear Annex (NA) and Reactor Building (RB)."

b. Add the following in 4th paragraph:

"The fresh air intakes for the SBVS are located at least 30 feet above grade elevation and are provided with tornado dampers "

c. Replace the word " atmosphere" with " surrounding spaces" in 4th paragraph.

d. DD should state the following:

The safety-related mechanical equipment room cooling systems consists of two completely redundant, independent full-capacity systems which provide cooling function during normal and accident conditions. Divisions I and II cooling systems serve the safety injection pump rooms, shutdown cooling pump rooms, containment spray pump and heat exchanger rooms, fuel pool heat exchanger rooms, steam and motor driven EFW pump rooms, shutdown cooling heat exchanger rooms, and penetration rooms.

Note: The staff has not completed its evaluation of all potential accidents (e.g., LOCA). If staff concludes that credit for removal of elemental and organic forms of iodine and particulates is warranted to meet offsite accident dose limits and control room accident dose limits, the tables for the CPVS, FBVS, AVS, and SBVS ITAACs will require revision.

Furthermore, the rad monitors, which will indicate when the exhausts from the areas serviced by the subject systems have to be diverted through filter systems, should be included among the safety-related monitors in ITAAC 2.9.4. Note that the annulus ventilatien system handles the design basis containment leakage and the subsphere building ventilation system handles the ESF leakages from the safeguards rooms.

2. ITAAC Fiqure 2.7.20-1 The figure shows a " remotely operated" damper upstream of the unit vent.

Is this damper a " tornado damper"? Explain " Note 1."

3. ITAAC Table 2.7.20-1

a. Replace the work " atmosphere" with " surrounding spaces" in ITAAC Item 3.

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--____m._______-_._

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b. Add ITAAC item for the location of the air intakes located at least l 30 feet above grade elevation. l 1

4. SSAR Section 9.4.5

a. The 3rd paragraph on page 9.4-23 of SSAR Section 9.4.5.1 should read as follows:

the subsphere building ventilation systems are...containing a filter train complete with seauentially arranaed components consistino of a moisture eliminator, orefilter, electric heater, are HEPA filter, carbon adsorber, post HEPA filter. ducts and valves, related instrumentation and two 100%... Figure 9.4-5.

b. Delete "-1988" in Subsection 9.4.5.1.1.c.

c. Verify that all the safety-related equipment rooms served by the SBVS are listed in SSAR Table 9.4-1 with the completed data.

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2.7.21 CONTAINMENT PURGE VENTILATION SYSTEM (CPVS) I

1. Desian Description (DD) l l

a. Provide location of CPVS. I i

b. Add the following before ITAAC description paragraph:

"In the event of a fire, the exhaust and supply fans can be used for smoke removal."

c. Provide fresh air intake locations with respect to the ground elevation.

d. Are the tornado missile barriers provided for air intakes ? If provided, then state in the DD.

Note: The staff has not completed its evaluation of all potential accidents (e.g., LOCA). If staff concludes that credit for removal of elemental and organic forms of iodine and particulates is warranted to meet offsite accident dose limits and control room accident dose limits, the tables for the CPVS, FBVS, AVS, and SBVS ITAACs will require revision.

Furthermore, the rad monitors, which will indicate when the exhausts from the areas serviced by the subject systems have to be diverted through filter systems, should be included among the safety-related monitors in ITAAC 2.9.4. Note that the annulus ventilation system handles the design basis containment leakage and the subsphere building ventilation system handles the ESF leakages from the safeguards rooms.

2. ITAAC Fiaures 2.7.21-1 and 2.7.21-2

a. Figure 2.7.21-1 CPVS DD should include bypass damper for low purge exhaust filtration unit.

b. The Figure 2.7.21-2 should include redundant bypass dampers for the high purge filtration unit and redundant safety-related radiation i

detectors since HEPA filtration is credited during a postulated fuel handling and control element ejection accidents,

c. SSAR Figure 9.4-6 shows code class boundaries as Class "4" and Class "2" whole Figures 2.7.21-1 and 2.7.21-2 show if as Class "H" and Class "2". Reconcile the difference.

d. Show the tornado missile barriers for the air intakes in both ITAAC figures, if required.

e. Alarm features should be added to the radiation monitors in the figures.

3. ITAAC Table 2.7.21-l i

a. ITAAC Table "2.7.21" should be "2. 7.21-1."

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b. Include ITAAC for fresh air intake location with respect ta ground elevation.

c. Include ITAAC entry to verify valves fail closed on loss of motive ,

power.

4. SSAR Section 9.4.6

a. Show humidity and fan status instrumentation for Figure 9.4-6 as shown in ITAAC Figures 2.7.21-1 and 2.7.21-2.

b. The 1st sentence in SSAR Section 9.4.6.3, paragraph 3 should reflect CIVs arrangement shown in SSAR Figure 9.4-6 and ITAAC Figures 2.7.21-1 and 2.7.21-2. The Figure 9.4-6 shows that each high purge '

supply and exhaust has 2 CIVs in " annulus" and 2 CIVs in

" containment" while each low purge supply and exhaust has 1 CIVs in

" Annulus" and 1 CIVs in " containment."

c. The 1st sentence in last paragraph in SSAR Section 9.4.6.2 on page 9.4-31 should read as follows:

The containment air cleanup system...each with seauentially arranaed components consists of orimary filter ore HEPA filter. carbon adsorber. Dost HEPA filter. ducts and valves. related instrumentation. and centrifugal fan.

d. SSAR Section 9.4.6 and Figure 9.4-6 should provide redundant bypass dampers for the high purge exhaust and safety-related redundant radiation monitors and low purge exhaust should include a bypass damper.

e. SSAR Figure 9.4-6 shows 100,000 cfm for each CEDM cooling unit while SSAR Table 9.4-1 on sheet 7 of 18 states 80,800 cfm for each CEDM cooling units. Reconcile the difference.

f. Describe air intake protection against the tornado-generated external missiles,

g. Provide the air intake locations with respect to the ground elevation.

h. Verify all safety-related and nonsafety-related components are included in Table 0.4-1 and are provided with the required data thereof.

i. SSAR 9.4.6 should provide system description for the high purge and low purge exhaust filtration trains including the associated components (i.e., each filtration exhaust train each, with sequentially arranged components, consists of a moisture eliminator primary filter, electric heater, pre HEPA filter, carbon adsorber, post HEPA, ducts and valves, fan and related instrumentation).

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e a 2.7.22 CONTAINMENT COOLING AND VENTILATION SYSTEM (CCVS)

1. D_esian Descriotion (DD)

a. Containment pressurizer cooling subsystem is shown in SSAR Figure 9.4-6 and included in SSAR Table 9.4-1, sheet 8 of 18 but is not stated in DD. This subsystem should be described in DD.

2. Fiqure 2.7.22-1

a. Figure 2.7.22-1 does not show any of the cooling subsystems.

(Bagchi/ECGB)

3. SSAR Section 9.4.6

a. Show those instrumentation shown in ITAAC Figure 2.7.22-1 in SSAR Figure 9.4-6.

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a 2.7.23 NUCLEAR ANNEX VENTILATION SYSTEM (NAVS)

1. Desian Description (DD)

a. Provide location of NAVS.

b. DD does not state if the system is safety-related or provide ASME ,

code classification.

b. Add the following in the 3rd paragraph of DD:

"The fresh air intakes are located at least 30 feet above grade elevation. The air intakes are provided with tornado missile barriers."

c. Add the following before ITAAC description paragraph:

"In the event of a fire, the exhaust and supply fans can be used for smoke removal."

d. Replace the phrase "outside atmosphere" with " surrounding spaces" in 4th paragraph of DD.

e. List safety-related rooms served by NAVS in DD as described in SSAR Section 9.4.9.2

2. ITAAC Fiaure 2.7.23-1 Show tornado missile barriers for the air intakes to protect against tornado-generated missiles.

3. ITAAC Table 2.7.23-1

a. Provide ITAAC for " Item 1.b" above to verify the air intake location.

b. Replace the phrase "outside atmosphere" with " surrounding spaces" in ITAAC Item 2.

4. SSAR Section 9.4.9

a. Replace the designations " essential" and " nonessential" with the

" safety-related" and "nonsafety-related" in SSAR Section 9.4.9 and Table 9.4-1.

b. Add the follo*ang in the Ist paragraph of SSAR Section 9.4.9.1 on page 9.4-39:

"The Nuclear Annex structure is designed to seismic Category I standards as noted in Table 3.2-1." P 32 SPLB

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c. Add the following in the 1st paragraph of SSAR Section 9.4.9.2 on page 9.4-41: ,

i "Each filter train sequentially consists of a moisture eliminator, electric heater, pre HEPA filter, carbon adsorber, post HEPA, ducts and valves and related instrumentation."

d. Add "CCWS pump rooms" at the end of 2nd paragraph of SSAR Section 9.4.9.2 on page 9.4.4-1.

e. Provide redundant bypass dampers in Figure 9.4.7-1 and rev',se 2nd paragraph of SSAR Section 9.4.9.2.1 to include "the redundant bypass dampers are provided to each filtration train."

f. Delete last paragraph on page 9.4-43 in SSAR Section 9.4.9.3 since it is duplicated.

g. Verify all safety-related and nonsafety-related components are included in Table 9.4-1 and are provided with the required data i thereof.

h. Show tornado missile barriers for the air intakes.

i. Show controls and instrumentation, as shown in ITAAC Figures 2.7.23-1 and 2.7.23-2, for the Figure 9.4.7-1.

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• . l 2.7.27 COMPRESSED GAS SYSTEMS tione i

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%s -o 2.7.24 FIRE PROTECTION SYSTEMS

1. Modifications to Design Description

a. Add... "The FPS consists of a water distribution, automatic and manual suppression systems, fire detection and alarm systems, and portable fire extinguishers.

b. State where the main components (i.e., pumps and tanks) are located and the buildings that the FPS protects,

c. Add that the diesel and motor driven pumps are designed to meet the most hydraulically demanding fire suppression system and hose station.

d. State "The FPS has the following displays and alarms in the Main Control Room (MCR):

(1) Detection system fire alarms and trouble signals (2) Status of fire pumps (3) Sprinkler /Preaction system

e. The DD does not state if it is protected from the effects of natural phenomena. (Bagchi/ECGB)

2. Modification to Figures Check List 1

a. Show the portions of the Fire Protection System that are  !

designed to remain functional following a design basis l earthquake.

l

b. Show buildings served (list)

c. Indicate on " Figure" key control valves

3. Modifications to ITAAC i

a. Include ITAAC to test and analyze that each pump will i provide at least the minimum flow and pressure to supply '

the largest design demand of any sprinkler, preaction or deluge system plus 500 gpm for manual hose.

b. Add hydrostatic test for all fire protection water systems. If NFPA requirements are different from ASME requirements, they should be delineated in the ITAAC or in the SSAR.

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c. Add ITAAC that the standpipe provided.in the nuclear annex and in the reactor building are designed to remain operational following a design basis earthquake.

d. Add ITAAC to inspect and test as-installed detectors.

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$t 'd 2.7.28 POTABLE AND SANITARY WATER SYSTEMS Currently the SSAR assumes the system is out-of-scope. However, those portions of the system which are in certified buildings are in-scope. This must be resolved at the SSAR level. These comments assume that these SSAR modifications will be made.

1. Modifications to DD:

a. Identify description, location, and operation of major in-scope system components.

2. Modifications to figure:

a. Provide figure for in-scope portion.

3. Modifications to ITAAC:

a. Provide basic configuration for in-scope portion,

b. Provide hydro

c. Provide verification of operation for in-scope portion

4. Modifications to SSAR:

a. System is not totally out-of-scope. Those portions within certified buildings are in-scope. SSAR must be rewritten to reflect this.

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The following is General . Electric's submittal for the ABWR's Potable .and Sanitary Water System which the staff found acceptable:

2.11.23 Potable and Sanitary Water System The Potable and Sanitary Water (PSW) System provides potable water to the '

reactor, control, turbine, radwaste and service buildings and collects liquid sanitary wastes and entrained solids and conveys them to a sewage facility and #

then to a site discharge structure. Nonradioactive drain subsystems  ;

throughout the plant collect nonradioactive waste water and' convey them to the site discharge structure.

Those parts of the PSW system that are within the reactor, control, turbine, 4 radwaste and service buildings are within the Certified Design. Those parts '

of the PSW system that are outside these buildings-are not within-the scope of.

the Certified Design.

The 'PSW system is classified as non-safety-rel ated.  ;

The PSW system has no interconnections with radioactive systems having the.

potential for transferring radioactive materials into the PSW system.

Inspections, Test, Analyses and Acceptance Criteria +

l Table 2.11.23 provides a definition of the inspections, test, and/or analyses, together with associated acceptance criteria, with will be undertaken for the '

PSW system.

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4e Table 2.11.23 Potable and Sanitary Water System Inspection, Test, Analyses and Acceptance Criteria Design commituent

1. The basic configuration for the Potable and Sanitary Water system is as t

discussed in section 2.11.23.

l

2. Independence is provided between the nonradioactive drain systems and the radioactive drain systems.

Inspections, Test, Analyses

1. Inspection of the as-built system will be conducted.

2. Test will be conducted on the as-built nonradioactive drain system by pressurizing all radioactive floor drains with water and observing the nonradioactive drains for evidence of inleakage from the radioactive floor drains.

Acceptance Criteria

1. The as-built Potable and Sanitary Water system conforms with the basic configuration discussed in Section 2.11.23.

2. No interconnections exist (i.e. no water inleakage from the radioactive drains is observed).

4.3 Potable and Sanitary Water System Interface Requirements There are no interface requirements for this system.

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s. 1 2.7.29 RADWASTE BUILDING VENTILATION SYSTEM (RBVS)

1. Desion Description (DD1

a. Show location of the system and ASME code classification of structures, components and systems.

b. Describe smoke removal mode for RWBVS.

c. Add the following before the ITAAC description:

1. The fire dampers with fusible lines in HVAC ductwork close under air flow conditions.

2. " Displays of the SBVS instrumentation is shown on Figure 2.7.29-1 exist in the MCR or can be retrieved from there."

3. Controls exist in the MCR to start and stop the RWBVS fans shown in Figure 2.7.10-1.

2. Fiaure 2.7.29-1

a. Show redundant radiation detectors for the RBVS.

b. Show fire damper as depicted under SSAR Figure 9.4-9.

3. ITAAC Table 2.7.29-1

a. Add ITAAC items for the following:

1) Controls for the system fans from the MCR.

2) Displays of the system instrumentation.

3) Smoke removal mode.

4) See "ITAAC Item 2.17.1.3.d" for ITAAC description for fire damper.

4. SSAR Section 9.4.3

a. Add the following for the SSAR Section 9.4.3.1.1 on page 9.4-16:

"I. Carbon filter medic, Nuclear Grade as defined by the Institute for Environmental Science."

b. SSAR Section 9.4.3.2.1, 1st paragraph on page 9.4-17 should state

" pre-HEPA" filter instead of " absolute" filter and " post-HEPA" filter instead of " post" filter.

c. SSAR Section 9.4.3.4, 2nd paragraph on page 9.4.17a should state l

" redundant" radiation detectors.

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d. Figure 9.4-9 should show for status instrumentation as shown in ITAAC Figure 2.7.29-1.

e. Figure 9.4-9 should show redundant air intakes as shown in ITAAC Figure 2.7.29-1.

f. Provide data for RWBVS exhaust and supply fans horse power and air and cooling water flows in Table 9.4-1.

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2.7.30 TURBINE BUILDING VENTILATION SYSTEM

1. Desian Description Provide system location and ASME code classification of system.

2. ITAAC Table 2.7.30-1 Provide an ITAAC for the Basic Configuration of the system.

3. SSAR Section 9.4.7 Revise SSAR Section 9.4.7 to include the requirement information in

" Item 1.a" above. Also, provide the system figure showing basic configuration.

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2.7.31 CCW HEAT EXCHANGER STRUCTURE VENTILATION SYSTEM (CCWHXSVS)

1. Desian Description

a. Provide system location and classification of the structures, components and system,

b. Add the following before the ITAAC description:

1) "The air intakes are located 20 feet above grade and away from plant discharges."

2) "In the event of a fire, the exhaust and supply fans can be used for smoke removal."

3) Displays of the CCWHXSVS-instrumentation shown on Figure 2.7.31 exist in the MCR or can be retrieved there."

4) Controls exist in the MCR to start and stop the CCWHXSVS fans shown on Figure 2.7.15-1.

2. Fioure 2.7.31-1

a. Show missile shield barriers for the intake and exhaust points.

b. Show " fan status" instrumentation on the exhaust fan.

c. Show temperature indication "T" in the structure of CCWHXSVS.

3. ITAAC 2.7.31-1

a. Provide ITAAC items for the following:

1) Air intake location l l

2) Controls for the system fans from the MCR

3) Displays of the system instrumentation

4. SSAR Section 9.4.10 Show missile shield barriers for intake and exhaust points, " fan status" instrumentation and temperature indication for the structure housing the

-CCWHXSVS.

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1 n) 2.7.X STATION SERVICE WATER PUMP STRUCTURE VENTILATION SYSTEM (SSWPSVS)

Provide Interface Requirements for SSWPSVS.

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2.8.1 TURBINE GENERATOR (T\G)

1. Desion Description (DD)

Provide the ASME code classification of the structures, systems, and components

2. Fiqure 2.8.1-1 Show the ASME code classification of the structures, systems, and components or provide the classification in DD.

3. ITAAC Table 2.8.1-1

a. Provide corresponding ITAAC for the closure times for T/G valves,

b. Provide closure times in case of full load rejection or turbine trip such as provided in response to DSER Confirmatory Item 10.2-1 in AB8-CE letter dated January 20, 1993. This was previously resolved confirmatory item in accordance with April 26-30, 1993 meeting with NRC staff. However, the proposed resolution in the January 20, 1993 letter has been revisited.'uy the staff and found acceptable.

4. Revise SSAR Section 10.2 appropriately to include the corresponding information identified in above items 1 and 3 Delete 4th paragraph in Section 10.2.1 of SSAR.

m,,

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n ev 2.8.2 MAIN STEAM SUPPLY SYSTEM

1. Desian Description

a. Provide location of nonsafety-related portions of main steam supply system in 2nd paragraph.

b. Add N16 detectors and alarms.

c. The DD should say that safety related valves are to be qualified to operate under loads and load combinations that include the simultaneous effects of earthquake and transients associated with rapid closure. (Bagchi/ECGB)

2. FIGURE 2.8.2-1  !

a. Revise Figure 2.8.2-1 in accordance with Item 1.b above.  !

3. ITAAC Table 2.8.2-1

a. Provide ITAAC for Item 1.b above.

4 SSAR Section 10.3

a. Show the applicability of asterisk (*) notation on page 10.3-6.

b. The word " licensee" in 1st paragraph on page 10.3.8 should be " COL applicant."

c. Revise SSAR in accordance with Item 1.b above.

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2.8.3 MAIN CONDENSER (MC)

1. Desian Description (00)  !

Provide location of the main condenser and its safety classification of the structures, systems, and components. i

2. FIGURE 2.8.3-1 Show the ASME code classification of the system.

3. SSAR Fiqure 10.4.4-1 Show instrumentation as identified on ITAAC Figure 2.8.3-1 47 SPLB

7 4 r-2.8.4 MAIN CONDENSER EVACUATION SYSTEM (MCES)

1. Desian Description (DD)

Provide the ASME code classification of the system.

2. Eigure 2.8.4-1 Show the safety classification of the structures, systems, and components in Figure 2.8.4-1.

3. SSAR Section 10.4.2 Provide location of the main condenser evacuation system, i

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f-2.8.5 TURBINE BYPASS SYSTEM (TBS)

1. Desian Descrintion (DD)

a. Provide the ASME code classification the structures, systems, and components and location of the TBS.

i

b. Provide location of the system.

c. Add the following after 3rd paragraph:

"The TBVs are normally controlled by steam bypass control system (SBCS) and also are capable of remote or local manual operation.

2. Fioure 2.8.5-1

a. Show the safety classification of the structures, systems, and components.

3. ITAAC Table 2.8.1-1 Provide corresponding ITAAC for the following:

a. TBS structural integrity under SSE conditions (See Item 1.b).

b. Item 3 should state "The turbine bypass valves open in less than 1 second and close in 5 seconds on receipt of a turbine bypass signal from the TBCS."

4. SSAR Section 10.4.4

a. Revise Section 10.4.4.2.4.1.F to read as follows:

"The COL applicant shall provide as-built pressure drop.... bypass valve to ABB-CE to evaluate.... capacity."

b. provide location of the TBS.

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fn T 2.8.x TURBINE GLAND SEALING SYSTEM (TGSS)

Provide a separate Design Description, Configuration Figure and ITAAC table for the TGSS for staff's review.

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2.8.6 CONDENSATE AND FEEDWATER SYSTEMS (CFS)

1. Desian Description (DD)

a. Provide system location.

b. " Figure 2.8.6-1" should be referenced as " Figure 2.8.6-1A" and Figure 2.8.6-18."

c. The " condensate demineralizer" in the DD and Figure 2.8.6-1A are captioned as " condensate polishers" in SSAR Figure 10.4.7-1.

Clarify the discrepancy and amend accordingly.

2. Fiqures 2.8.6-1A and 2.8.6-1B

a. The " condensate demineralizer" in Figure 2.8.6-1 A should be upstream of " gland steam condenser" as shown in SSAR Figure 10.4.7-1.

b. SSAR Figure 10.4.7-1 shows code class boundaries as class "4" and Class "2" while Figure 2.8.6-1B shows it as Class "N" and Class "2" Reconcile the difference.

3. ITAAC Table 2.8.6-1 i

a. " Figure 2.8.6-1 should be referred to as " Figure 2.8.6-1A" and l

" Figure 2.8.6-1B," accordingly.

4. SSAR Page 10.4-37, 1st Paragraph should refer to caption "10.4.7.2.7" rather than "10.4.7.3.2."

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t 2.8.8 EMERGENCY FEEDWATER SYSTEM (EFWS)

1. Desian Description (DD)

a. The 2nd paragraph should read as follows:

"The EFWS is located within the several structures including steel containment (RC), reactor building (RB), and nuclear annex (NA)."

b. The last paragraph on page 1 should read as follows:

" Displays and controls of the EFWS instrumentation. . . (MCR) and remote shutdown panel or can be retrieved there."

c. Revise DD to include position indications of the valves identified by ABB_CE during sabotage (safeguards) review in MCR.

2. Fiaure 2.8.8-1

a. SSAR Figure 10.4.9-1 include valve numbers EF-238 and EF-239 as part of the EFWS. However, Figure 2.8.8-1 does not include thcoe valves as part of the EFWS. Reconcila the difference.

b. SSAR Figure 10.4.9-1 shows code cu boundaries as class "4" and class "3". However, Figure 2.8.8-1 shows it as class "N" and class "3". Reconcile the difference.

c. Show alarm designation "A" to each EFW storage tank level instrumentation.

d. Revise Figure 2.8.8-1 to include position indications of the valves identified by ABB_CE during sabotage (safeguards) review in MCR.

e. Figure 2.8.8-1 should show relative elevations, specifically, the gravity fed non-safety-related makeup source. (Bagchi/ECGB)

3. ITAAC Table 2.3.8-1

a. Add "and deliver flow to the steam generator (s) within 60 seconds" at end of ITAAC ll.a.

b. Items 7.a, 7.b, and 7.c should add " remote shutdown panel" reference wherever "MCR" is mentioned.

4. SSAR Section 10.4.9

a. Section 10.4.9.2.4, 1st paragraph, 1st sentence should delete phrase, "from the Engineered Safety Feature Actuation Signal (ESFAS)", which is stated twice.

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binding resolution by incorporating the RAI 730.4 (GSI 93) response j i.e., redundant locked closed isolation valves in each EFWS i

subtrain, steam venting through the EFWS tank vent, the temperature l sensors downstream of the EFW pumps and high audible alarm in the  ;

control room. I 1

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2.8.9 CONDENSER CIRCULATING WATER SYSTEM (CWS)

Provide complete Design Description, configuration figure and ITAAC table for the CCWS portions that are in the turbine building and are within the scope of ABB-CE certified design. The Design Description should include the system function, location and ASME code classification of the structures, systems, and components for the CCWS portions within scope. Also it should include the design features to limit flooding in the turbine building. The configuration figure should include components, system boundaries, code classification and minimum instrumentation for the CCWS portions within scope. The ITAAC table should include items for the basic configuiation, MCR alarms and displays, and system isolation for the CCWS portions within scope.

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