ML20059J258
| ML20059J258 | |
| Person / Time | |
|---|---|
| Site: | 05200001 |
| Issue date: | 10/29/1993 |
| From: | Liza Cunningham Office of Nuclear Reactor Regulation |
| To: | Borchardt R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9311120117 | |
| Download: ML20059J258 (9) | |
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. NUCLEAR REGULATORY COMMISSION
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2 WASHINGTON, D.C. 20066-0001 6
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october 29, 1993--
'l MEMORANDUM FOR:
Richard W. Borchardt Standardization Project Directorate Division.of Advanced Reactors and Special Projects, NRR' Office of Nuclear Reactor Regulation j
'FROM:
.LeMoine J. Cunningham, Chief Radiation Protection Branch Division of. Radiation Safety and Safeguards, NRR-
SUBJECT:
SBWR STANDARD SAFETY ANALYSIS REPORT (SSAR)
REQUEST FOR ADDITIONAL INFORMATION-(PARTIAL)
-CHAPTER'12 The facilities Radiation Protection Section (FRPS) of the Radiation Protection Branch has completed a partial review of Chapter 12 of GE's SBWR SSAR. On-the basis.of this review, we are enclosing the attached requests for additional information (RAls). The RAIs from the Radiation Measurement and Health Effects Section (reviewer is Jay Lee) of the Radiation Protection Branch will be submitted at a later date.
The FRPS review centers primarily on the-Radiation Protection information'.
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contained in Chapter 12 of the SSAR, although some pertinent information is.
also addressed in Chapters.9 and 11. Due to the fact that a new reviewer was-recently assigned to perform the SBWR review, there has not' been sufficient -
time to perform an in-depth. review of the pertinent material. The attaclsed RAIs represent a ' fairly comprehensive review of. Chapter 12, with the exception-of the radiation zone drawings referenced in:Section 12.3.
This' review also.
does not' include an evaluation of the' radiation protection related material contained in Chapters 9.and 11.
FRPS will' submit an additional set-of RAIs which will cover the remaining unreviewed information by November 30,1993.
On the basis of our review, the staff found' portions of Chapter.12 to' be incomplete. GE has not responded to'the staff's round zero RAls which tereL sent to GE on January 28,- 1993.
In addition..GE needs toTaddress the.
following' subject areas in more detail:
o Radiation source terms - The SSAR contains:insufficidnt information' for the. staff to perform confirmatory shielding calculations.
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. Airborne radioactivity. levels '- The SSAR.contains no tabulation of airborner'adioactivity levels for various plant' areas; f C..L/
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(Note: Both CE and GE-(for ABWR) addressed the'above two-issues in the form /
of Design Acceptance Criteria).
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Richard W. Borchardt 2
.l As is stated above, FRPS has yet to complete its review of Chapter 12 and other pertinent chapters of the SSAR. When the review is completed, FRPS would like to set up a meeting with the applicant (GE) to discuss the 1
inadequacies of the material reviewed.
By conveying-our concerns to the applicant at this early stage in the review process, we would hope to resolve l
any misconceptions on the applicant's part aboutL what is required in.the SSAR and thereby minimize the impact on the review schedule.
This review was l
performed by Charles Hinson, FRPS (x1845).
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Safety and Safeguards, NRR
Enclosure:
As stated a
cc: Melinda Malloy DISTRIBUTION:
Central File,' P137 PRPB R/F PRPB, SBWR PDR, LL6 F. Congel T. Essig J. Wigginton C. Hinson R. Erickson P. McKee R. Anderson, TTC I
0FC PRPB:DRSS RPBgRSS:SC RPpg NAME CHINSON:g Jk tETONLhMi
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DATE 10 /28/93 OFFICIAL RECORD COPY Document Name:SBWLTR
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'1 Enclosure REQUEST FOR ADDITIONAL INFORMATION FACILITY RADIATION PROTECTION SECTION/
RADIATION PROTECTION BRANCH ABWR 471.1 Table 1.9-2 in the SSAR provides a listing of Regulatory Guides which are applicable to the SBWR. Modify this table to include the following Regulatory Guides which are listed in Chapter 12 of NUREG-0800 (Standard Review Plan).
" Guide for Administrative Practices in Radiation Mor.itoring" RG 8.3,
" Film Badge Performance Criteria" RG 8.15,
" Acceptable Programs for Respiratory Protection" RG 8.20,
" Applications of Bioassay for I-125 and I-131" RG 8.26,
" Applications of Bioassay for Fission and Activation Products" RG B.27,
" Radiation Protection Training for Personnel at Light-Water-Cooled Nuclear Power Plants
" Audible-Alarm Dosimeters" RG 8.29,
" Instructions Concerning Risks From Occupational Radiation Exposure" The staff is in the process of revising some existing regulatory-guides and developing additional regulatory guides to address some of the new issues contained in the revised 10 CFR Part 20.
Some of the new, or revised regulatory guides which pertain to Chapter 12-of the SBWR SSAR and which should also be addressed in Table 1.9-2 are listed below.
" Instructions for Recording and Reporting Occupational Radiation Exposure Data" (Revised)
'" Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program" (Revised)
" Air Sampling in the Workplace" RG 8.34,
" Monitoring Criteria and Methods to Calculate Occupational Radiation Doses" RG 8.35,
" Planned Special Exposures"
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2 RG 8.36,
" Radiation Dose to the Embryo / Fetus" RG 8.38,
" Control of Access to High and Very High Radiation Areas in Nuclear Power Plants" 471.2 As of January 1,1994, all licensees must comply with the revised 10 CFR Part 20. Accordingly, all references to sections of 10 CFR Part 20 in the SSAR, should reference the revised section numbers.
471.3 Section 12.1.2.1 of the SSAR lists several general design considerations for ALARA exposures.
In order to minimize job set-up time in radiation areas, needed services should be readily available at the job site. Discuss your plans for providing service outlets for all service systems (compressed air, breathing air, communications, service water, demineralized water, electricity, vacuum cleaning system, video and data collection cables) on all plant' elevations in the vicinity of where maintenance or operating activities are expected to be performed.
471.4 For complex jobs to be performed in plant areas having high radiation levels, the use of mockups serves to familiarize workers with the exact operations that they will perform at the job site.
Section 12.1 of the SSAR should be modified to describe how mockups i
will be used as an ALARA preplanning aid to train workers.
s 471.5 Section 12.1.2.2 of the SSAR states that past experience has been factored into current equipment designs to reduce personnel exposures. However, the only example of this that is provided in the SSAR is the redesign of the steam relief valves.
Amend this section of the SSAR to include other examples of how experience from past designs and operating plants has been incorporated into the
.i design of equipment and facility layout for the SBWR design.
Your response should include varied examples of equipment / design improvements throughout the plant.
471.6 Section 12.1.2.2 of the SSAR lists some equipment design considerations to limit time spent in radiation areas.
This section i
should be amended to describe what considerations have been given to the use of radiation resistant materials in high radiation areas.
Use of such " radiation. hardened" materials in these areas would reduce the need for frequent replacement and thereby reduce personnel radiation exposure.
471.7 Section'12.1.2 of the SSAR describes several design considerations i
that will be used in the SBWR to maintain inplant radiation.
exposures ALARA. Amend this section to discuss how robotics will be utilized in the SBWR design to minimize personnel doses. -Examples of some areas where robotics can be used to reduce personnel doses include remote weld inspections, in-service inspections, and surveys s
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In addition, discuss how the SBWR design / layout will facilitate the use of robotics (e.g., use of ramps versus stairs in certain areas, accessibility of reactor pressure vessel belt line to perform weld inspections, use of wide doorways).
l 471.8 Regulatory Guide 1.70 (Standard Format and Content-of Safety
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Analysis Reports for Nuclear Power Plants) states-that the SSAR should contain sufficient' source-term characterization (i.e.,
radionuclide concentration, component location and geometry, component and cubicle dimensions, composition of adjacent shielding, etc.) of contained sources for the staff to be able to perform
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confirmatory calculations to determine dose rates in potentially occupied areas adjacent to these components. Although the SSAR provides the radionuclide concentrations and volumes for several-of _
i the contained sources, the SSAR should be amended to include the i
additional information needed (e.g., component location-, geometry, and material composition) for the staff to be able to perform.the i
necessary confirmatory shielding calculations.
471.9 Regulatory Guide 1.70 states that the SSAR should include a tabulation of the calculated concentrations of airborne radioactive materials, by nuclides, expected during normal operation and anticipated operational occurrences, for equipment cubicles, corridors, and operating areas normally occupied by operating personnel.
Since this information is not contained in Section 12.2 of the SSAR, state how you plan to comply with this guidance.
471.10 Section 12.2.1.2 of the SSAR states that the reactor water concentration at the reactor core exit (decay corrected since the SBWR does not have an external recirculation loop) will have an estimated value of 5.1 MBq/gm. Clarify whether this concentration is for N-16 alone or for all the: radionuclides contained in the coolant.
If this concentration is for N-16 alone, justify the apparent discrepancy between this value of 5.1 MBq/gm and_ the valuo of 7.0 MBq/gm for N-16 in reactor water contained in Table 12.2-4.
471.11 The footnote to Table 12.2-4 states that the steam concentration for N-16 should be increased by a factor or four during operation with hydrogen 4ter chemistry.
1.
Explain why the N-16 concentration in reactor water should not also be increased by a. factor of four during operation with hydrogen water chemistry.
2.
Discuss whether the SBWR is intended to operate using hydrogen water chemistry at all times.
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State whether the effect of hydrogen water chemistry on the N-16 concentration (increasing the level by a factor of four) was incorporated into the plant shielding design.
4.
Section 12.4.5 of the SSAR states that N-16 levels are increased about five times by the use of hydrogen water chemistry. Clarify the apparent discrepancy between this value and the value stated in the Table 12.2-4 footnote.
471.12 Regulatory Guide 1.70 states that Section 12.2 of the SSAR should include a listing of source activities contained in the spent fuel pool water.
Provide a table listing the source activities (by radionuclide) in the spent fuel pool water for both normal and design basis conditions.
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471.13 In Section 12.2 of the SSAR, provide graphs showing the calculated dose rates in water axially above and from the side of the maximum spent fuel assembly. On these graphs, indicate how the dose rates
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vary as a function of time out of the core.
471.14 Section 12.3.1 of the SSAR states that the cobalt content will.be limited to no more than 0.05% in the XM-19 alloy used in the SBWR control rod blades and in the Inconel X750 used in the SBWR fuel assembl ies.
Several operating facilities have replaced their control rod blades with replacement blades having a cobalt content
-j in the range of 0.015 to 0.020%.
Justify your reasoning for not committing to a cobalt content of between 0.015 and 0.020% for components which will be in contact with reactor coolant in the reactor coolant system.
i 471.15 Section 12.3.3.2 of the SSAR describes how HVAC filters for the
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control room ventilation system will be maintained.
Verify that adjacent filter trains (for the control room and for other areas of the plant) are adequately shielded from each other so that personnel changing out filters in one train are not exposed to radiation from the adjacent filter train.
471.16 Area radiat 4n monitors located in high noise areas should have visual as weil as audible alarms.
State how you plan to comply.
471.17 State the reasons why several of the area radiation monitors listed in Tables.12.3-2,12.3-3, and 12.3-4 are not provided with local area alarms.
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471.18 Section 9.4 of the SSAR should be amended to include air flow-diagrams for each of the ABWR ventilation systems.
For each ventilation system which services an area having a potential for airborne radioactivity, these air flow diagrams should indicate the locations of the airborne radioactivity monitors.
These monitors should be located upstream of the filter trains so that they monitor representative radioactivity concentrations from the areas being l
sampled.
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-471.19 Section 12.3 of NUREG 0800 (Standard Review Plan) states that the-plant airborne radioactivity monitors should be able to detect ten MPC-hours of particulate and iodine. radioactivity from 'any compartment which has a possibility of containing airborne radioactivity and which normally may be occupied by personnel, taking into account dilution in. the ventilation system.
Verify that the airborne radioactivity monitors at SBWR will have this-sensitivity.
471.20 The plant radiation zone maps (Figures 21.12.3-1 through 21.12.3-4) should be revised to indicate the following:
1.
Normal personnel traffic patterns used in entering.the RCA and accessing various areas of the plant during routine plant walkdowns.
2.
Personnel traffic patterns used in accessing plant vital areas during post-accident conditions.
3.
Boundaries for the radiation / contamination control areas.
4.
Location of the health physics facilities (including the f
onsite counting labs and the post-accident sampling station) and their design-basis radiation levels.
i 471.21 The SSAR section entitled " Post-Accident Radiation Zone Maps" (page 12,3-20) makes reference to a Figure 12.3-2.
This figure appears to be missing from the SSAR.
471.22 Section 12.3 of the SSAR should include 1) a listing in the text and
- 2) location on the appropriate radiation zone layout drawing, of all accessible plant areas where, during normal and anticipated operational occurrences, personnel could receive a radiation dose of I gray (100 rads) or more in one hour.
In addition, the SSAR should describe design considerations that will ensure that potentially-lethal overexposures of personnel will not occur.
Particular-i attention should be focused on transient very high radiation areas
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as well as areas with intense sources of radiation continuously present. An example of a transient very high radiation area is the l
upper drywell area which could experience elevated dose rates in the event a spent fuel bundle were to be dropped onto-the reactor.. flange.
during fuel movement.
I 471.23 10 CFR 50.34 (f)(2)(vii)(Item II.B.2 of NUREG-0660 and NUREG-0737) states that the post-accident design dose rates should be such that 3
the dose to plant personnel should not exceed 5 x 10E-2 sieverts (C' rem) whole body, or its equivalent to any part of the body, for the i
duration of the accident (per General Design Criteria (GDC) 19).
The dose rate in areas requiring continuous occupancy (vital areas) should be less than 15 x 10E-5 sieverts/hr ( 15 mrem /hr)(averaged over 30 days). Verify that personnel exposures will meet GDC 19.and NUREG-0737 guidelines following a design basis accident.
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6 471.24 10 CFR 50.34 (f)(2)(vii) states that systems containing high levels of radioactivity in post-accident situations be identified.
State how you plan to comply with this requiremer' t
471.25 Verify that the Containment Atmospheric nonitoring system describad in Section 12.3.4 of the SSAR complies with all of the requirements of 10 CFR 50.34 (f)(2)(xvii)(Item II.F.1-3 of NUREG-0660 and NUREG-0737) including detector range, response, redundancy, separation, location, in-situ calibration, and environmental design qualification.
471.26 10 CFR 50.34 (f)(2)(xxvii)(Item III.D.3.3 of NUREG-0660 and NUREG-0737) states that all plants shall have equipment and associated training and procedures for accurately determining the airborne iodine concentration in potentially occupied areas during an accident.
State how you plan to comply with this requirement.
471.27 Section 12.4 of the SSAR provides man-hour estimates and average dose rates for various tasks performed at typical BWRs.
These values are then modified, based on SBWR design improvements, to arrive at projected man-hour estimates and average dose rates for the SBWR design (listed in Table 12.4-1).
Provide your bases (number of plants in the data base and recentness of data used) for arriving at the typical BWR person-hour and dose rate values.
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471.28 Regulatory Guide 1.70 states that Section 12.4 of the SSAR should address inplant personnel exposures due to airborne radioactivity.
This section should list the peak airborne concentrations, estimated i
person-hours of occupancy, and estimated inhalation exposures for all areas of the plant accessed by plant personnel.
This section should also list the assumptions used to determine airborne radioactivity in each building.
471.29 Section 12.4.2 of the SSAR states that instrumentation work in the reactor building requires 1000 person-hours.per year at a typical BWR. This section then goes on to say that reactor building instrumentation work at the SBWR should take about the same effort.
However, Table 12.4-1 indicates that reactor building instrumentation work for the SBWR will only require an estimated 600 person-hours. Clarify this apparent discrepancy.
t 471.30 Section 12.4.5 of the SSAR states that the average dose rate for work at power at a typical BWR is 6.6 mrem /hr.
This section does not indicate that the dose rate for work at power at the SBWR will be any different. However, Table 12.4-1 states that the dose rate-for work at power for the SBWR will be only 3.5 mrem /hr. Amend Section 12.4.5 to. state why the expected SBWR dose rate for work at power will be less than the typical BWR dose rate.
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7 471.31 Make the following editorial changes in Section 12 of the SSAR:
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Page 12.2-12: There appears to be some text' missing. in the last sentence of the section entitled, " Radioactive Sources in the Main Steam and Feedwater Lines".
o Page-12.2-16: The' word " Guide" should be inserted after
" Regulatory" in the third line of Section 12.2.6.4 '
o Table 12.2-16: Provide the units to be used for the data in this table.
o Page.12A-4: Equation 12A-5 is missing a " lambda" in the'second
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