ML20137L483
| ML20137L483 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 04/03/1997 |
| From: | Martin T NRC (Affiliation Not Assigned) |
| To: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 9704070243 | |
| Download: ML20137L483 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enmaa anni April 3,1997 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, PA 15230
SUBJECT:
AP600 TECHNICAL SPECIFICATION (TS) LIMITING CONDITION FOR OPERATION (LCO) 3.0.3
Dear Mr. Liparulo:
In a letter dated December 6, 1996, we sent you a list of potential critical path issues in the design certification process for the AP600.
One of the issues (key issue #19) involves Westinghouse's proposed modification to standard TS LCO 3.0.3.
In the standard technical specifications (STS),
LCO 3.0.3 directs that the reactor be placed in cold shutdown when an opera-tional situation arises which is not within the conditions of an LCO or its associated actions requirements. Westinghouse took exception to STS LCO 3.0.3 because the safe shutdown condition for the AP600 is 420 'F and the design i
does not have any safety related method of achieving cold shutdown.
It was Westinghouse's contention that because TS operability restric'tions are not placed on the nonsafety-related systems needed to get to cold shutdown (e.g.,
the startup feedwater system (SFW) and the normal residual heat removal system (RNS)), entry into LC0 3.0.3 would not be applicable if these nonsafety-related systems are not available for getting the plant to cold shutdown when entry into LCO 3.0.3 would otherwise be required.
In our letter to you dated December 24, 1996, we stated that this position was unacceptable and that Westinghouse should either make LC0 3.0.3 consistent with STS or provide TSs controlling the availability of SWF and RNS.
Your response in Westinghouse letter NSD-NRC-97-4984 dated February 13, 1997, provided additional justification for your position. Our staff reviewed the Westinghouse response and did not find it sufficiently compelling to change our initial evaluation. Following additional discussions with Westinghouse on this issue, Westinghouse sent the staff a letter (NSD-NRC-97-5030 dated March 19,1997) which revised its position and deleted the exemption for entry into LCO 3.0.3.
Westinghouse states in the March 19, 1997 letter that its
" approach meets the direction provided by the Director of Nuclear Reactor Regulation at a senior management meeting last year." The staff does not believe that Westinghouse has properly characterized the NRC position on LC0 3 0.3.
The NRC position has remained unchanged since the May 8, 1996 senior management meeting with Westinghouse and can be simply stated that, to the extent'that.the AP600 design supports Mode 4 as a safe state, individual technical specification LCOs can end at Mode 4; otherwise, the staff expects cold shutdown, consistent with STS LCO 3.0.3 to be the appropriate safe end state.
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- '11 Our review of the March 19,1997'Westingdouse.submittalnotes-thatwhilethe exemption to entry into LCO 3.0.3,has been' deleted, the completion times to get to cold shutdown have been extended to'seven days., The basis for the extended completion times is to provide'the plant operators sufficient time to restore the nonsafety-related systenstneeded.to cool the plant to. cold j
shutdown if these systems are unavailable when the plant enters LCO 3.0.3.
Westinghouse has not justified that the extended shutdown times'are demonstrably. safer using risk informed measures, or that the extended times are needed due to capacity limitations of the nonsafety-related systems that would be used to achieve cold shutdown, or are warranted due to burdens the STS times would place on the plant oper tors.
Both Westinghouse and the staff recognize that nonsafety-related systems will i
be necessary to achieve cold shutdown conditions for the AP600.
It is the staff's understanding that the AP600 is capable of reaching cold shutdown within the completion times currently specified in' STS when using the non-safety-related systems. Since these nonsafety-related systems are not subject to technical specifications, it will be incumbent on the plant operator.to
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ensure that the capability for achieving cold shutdown in an expeditious manor is maintained for those rare occasions where entry into LCO 3.0.3 may be required.
It is, therefore, the staff's conclusion that Westinghouse has not provided sufficient justification to extend STS LCO 3.0.3 completion times to the times proposed by the March 19, 1997 submittal. The staff also notes that the Westinghouse proposed wording for LCO 3.0.3 provides additional guidance which is not consistent with STS. The staff considers this guidance to be sufficiently vague to potentially cause confusion or misinterpretation by plant operators. Consequently, it is the staff's position that LCO 3.0.3 completion times and wording be restored to the wording in the STS.
The staff's position also applies to LCO 3.0.2.
If you have any questions, you can call Bill Huffman at (301) 415-1141.
Sincerely, l
original signed by-Thomas T. Martin, Director I
Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003 1
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Mr. Nicholas J. Liparulo Docket No.52-003 Westinghouse Electric Corporation AP600 cc: Mr. B. A. McIntyre Mr. Ronald Simard, Director Advanced Plant Safety & Licensing Advanced Reactor Programs Westinghouse Electric Corporation Nuclear Energy Institute Energy Systems Business Unit 1776 Eye Street, N.W.
1 P.O. Box 355 Suite 300 Pittsburgh, PA 15230 Washington, DC 20006-3706 Mr. Cindy L. Haag Ms. Lynn Connor Advanced Plant Safety & Licensing Doc-Search Associates Westinghouse Electric Corporation Post Office Box 34 Energy Systems Business Unit Cabin John, MD 20818 Box 355 Pittsburgh, PA 15230 Mr. James E. Quinn, Projects Manager LMR and SBWR Programs Mr. M. D. Beaumont GE Nuclear Energy Nuclear and Advanced Technology Division 175 Curtner Avenue, M/C 165 Westinghouse Electric Corporation San Jose, CA 95125 One Montrose Metro 11921 Rockville Pike Mr. Robert H. Buchholz Suite 350 GE Nuclear Energy Rockville, MD 20852 175 Curtner Avenue, MC-781 San Jose, CA 95125 Mr. Sterling Franks U.S. Department of Energy Barton Z. Cowan, Esq.
NE-50 Eckert Seamans Cherin & Mellott 19901 Germantown Road 600 Grant Street 42nd Floor Germantown, MD 20874 Pittsburgh, PA 15219 Mr. S. M. Modro Mr. Ed Rodwell, Manager i
Nuclear Systems Analysis Technologies PWR Design Certification Lockheed Idaho Technologies Company Electric Power Research Institute Post Office Box 1625 3412 Hillview Avenue Idaho Falls, ID 83415 Palo Alto, CA 94303 Mr. Frank A. Ross Mr. Charles Thompson, Nuclear Engineer U.S. Department of Energy, NE-42 AP600 Certification Office of LWR Safety and Technology NE-50 19901 Germantown Road 19901 Germantown Road Germantown, MD 20874 Germantown, MD 20874 4
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