ML20151S305
| ML20151S305 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1988 |
| From: | Rubenstein L Office of Nuclear Reactor Regulation |
| To: | Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| References | |
| PROJECT-675A NUDOCS 8804280275 | |
| Download: ML20151S305 (8) | |
Text
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April 14, 1988 Project No. 675 Mr. A. E. Scherer, Director Nuclear Licensing Combustion Engineering 1000 Prospect Hill Road Post Office Box 500 Windsor, Connecticut 06095-05I0
Dear Mr. Scherer:
SUBJECT:
NRC STAFF COMMENTS (i COMBUSTION ENGINEERING LICENSING REVIEW BASES FOR CESSAR-DC SYSTEM 80+ DESIGN We have reviewed the CESiAR-DC System 80+ Licensing Review Bases as transmitted by letter dated tanuary 19, 1988 and revised by letter dated March 2, 1988. Our comments are enclosed in the enclosure, "Staff Review Coments Concerning CESSAR-DC Licensing Review Bases (LRB)." You may choose to change the LRB to reflect these comments or change the LRB in those areas where we agree and subsequently meet with us to discuss the implementation of those coments where you do not agree.
In either case we request your response within 45 days from the date of this letter.
Sincerely, original signed by Lester S. Rubenstein, Director Standardization and Non-Power 8804280275 880414 PDR PROJ Reactor Project Directorate 675 A PDR Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
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April 14, 1988 Project No. 675 Mr. A. E. Scherer, Director Nuclear Licensing Combustion Engineering 1000 Prospect Hill Road Post Office Box 500 Windsor, Connecticut 06095-0500
Dear Mr. Scherer:
SUBJECT:
NRC STAFF COMMENTS ON COMBUSTION ENGINEERING LICENSING REVIEW BASES FOR CESSAR-DC SYSTEM 80+ DESIGN We have reviewed the CESSAR-DC System 80+ Licensing Review Bases as transnitted by letter dated January 19, 1988 and revised by letter dated March 2, 1988. Our comments are enclosed in the enclosure, "Staff Review Coments Concerning CESSAR-DC Licensing Review Bases (LRB)." You may chcose to change the LRB to reflect these comments or change the LRB in those areas where we agree and subsequently meet with us to discuss the implementation of those comments where you do not agree.
In either cese we request your response within 45 days from the date of this letter.
Sincerely,
'.,3 n
\\
.c d'b u4 kN Lester S. Rubenstein, Director Standardization and Non-Power i
Reactor Project Directorate Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated cc:
See next page
l j
Combustion Engineering, Inc.
Project No. 675 Advanced CESSAR l
cc: Mr. C. B. Brinkman, Manager Washington Nuclear Operations Combustion Engineering, Inc.
7910 Woodmont Avenue, Suite 1310 Besda, Maryland 20814 Dr. Michael Green Manager of Licensing Combustion Engineering 1000 Prospect Hill Road Post Office Box 500 Windsor, Connecticut 06095-0500
STAFF REVIEW COMMENTS CONCERNING CESSAR-DC l
LICENSING REVIEW BASE 5 (LRB)
JINCLUDING COMMENTS ON REVISED 7.2.4-7.3.3)
EXECUTIVE
SUMMARY
Strike out first part of first sentence of second paragraph "In the absence of
.............................and Policy Statement."
1.0 INTRODUCTION
Page. 3 - Insert at beginning of first sentence "Both CE and".
Strike out all of material from the second paragraph beginning with "The development of LRB is particularly important because:" through to the second paragraph of page 4 ending in
".....................without further design review."
Page 4 - Strike out last sentence of last paragraph "This would ensure that,
.................and certified in CESSAR-DC."
1.1 Scope and Content of CESSAR-DC Strike out last two sentences of first paragraph on page 5.
Strike out the remainder of material on page 5.
I Page 6 - Strike out first partial sentence and first full sentence top of page 6.
Insert appropriately a similar Scope and Content as is on page 2 of the GE LRB, August 1987 - All of 1.1 of GE LRB.
"The Executive Summary indicates that the CESSAR-DC will meet all current regulations. However, there is no statement as to how CE proposes to meet 10 CFR 50.34( ).
Define how CESSAR-DC will meet the Standard Review Plan, 10 CFR 50.34( )."
Consider inserting similar paragraph as GE LRB 3.1.
1.2 Scope and Content of Future Applications Referencing CESSAR-DC Strike out the word "only" on page 7, 2.0 SCHEDULE Pg. 8 - Second sentence insert "18" for "six months." Strike out remainder of paragraph beginning with "This is an appropriate review period.....
l l
. Table 1 - Provide submittals of complete chapters. Provide a draft SER date 18 months from last submittal date of each chapter except chapters 1, 10, 2 and 17.
Figure 2 - Revise to reflect an average of 18 months review time.
3.2 CESSAR-DC Format Strike second sentence of last paragraph on page 11 "CESSAR-F has already
...........for the current FDA."
4.0 INCORPORATION OF NEW ISSUES Strike out first sentence of second paragraph on page 14 "By issuing FDA-2 to Combustion Engineering.......................Fafety of the public."
It should be pointed out that while Palo Verde i, 2 and 3 were eligible for relief from certain rules and regulations, similar requests for relief may not be granted for future Systen 80+ plants. An example of such relief from the regulations relates to inservice testing)of pumps and valves as required by Code and Standards Rule,10 CFR 50.55a(g. All of the plants so far have been allowed to request relief from the ASME Section XI inservice testing rules for a limited number of pumps and valves. The reason being that the plont piping systems designs were completed prior to the implementation of the ASME Section XI requirements and limitations in the designs made it difficult to test the pumps and valves without design changes. The System 80+ design could be such as to accomodate inservice testing requirements of the ASME code.
CE states that any NRC required revisions to the design beyond those sponsored by CE will be considered a backfit. The staff has problems with this since there are a numbered of areas where staff positions have evolved and undergone change since the Systen 80 design was approved. Some of these areas are: (1) preoperational vibration testing of ASME Class 1, 2 and 3 piping systems; (2) functional testing of hydraulic and mechanical snubbers; (3) inservice testing of pumps and valves; and (4) generic and unresolved safety issues related to 1
inservice testing (for example, leak rate testing of pressure isolation valves).
Implementation of the current staff positions may result in revisions to the System 80+ design. The staff will review the entire design proposed to the System 80+ design against all current licensing criteria.
Since our position concerning the Backfit Rule has not been fully determined, we will leave this until later. However, we have the following coment which is appropriate: While we recognize that the SRP is the only currently available review guidance and criteria for the acceptance of the CESSAR-DC, it j
is our position that it may be inappropriate in a number of areas, based on current knowledge and understanding of reactor safety. We believe application of the backfit procedure is necessary where the staff and the applicant cannot come to agreement.
In those review areas where we know imarovements in safety can be made, we will request the applicant to consider sue 1 improvements.
In addition, the current SRP criteria for fire protection and equipment qualification may not be appropriate for advanced plant designs.
D Also CE's position on the Backfit Rule appears to be inconsistent with other statements within the LRB. For instance, they have indicated that the System 80+ will meet all current regulations and meet the requirements of the Severe Accident Policy. What CE is really stating is that the Backfit Rule could be applied on any changes which the staff would require and which have not been proposed by CE. All changes which CE would propose to satisfy the l
Severe Accident Policy would have to be accepted by the staff or CE could apply the Backfit Rule.
5.0 REVIEW PROCEDURES 5.3 prestionsandResponses All of 5.3 is too prescriptive and inappropriate. Suggest consider something similar to GE LRB Section 5.
Section 5.4, page 20 - Modify first sentence to read:
"At the completion of the review of the individual CESSAR-DC chapters, the staff will perform an integrated review of the complete CESSAR-DC to ensure all open review issues are resolved."
6.0 ACRS PARTICIPATION Strike out this paragraph and insert paragraph similar to GE LRB Section 6.
7.0 SEVERE ACCIDENT POLICY Provide discussion of what process CE proposes to address their aspect to the policy statement with regard to sabotage.
7.1 Introduction Second paragraph, page 22 - Change first sentence to read:
"The Comission further recognized the need to provide defense in depth by striking a balance between accident prevention and consequence mitigation,.....................
...................................... night need to be established."
Top of page 23 - Strike our "guidance" and insert "requirements."
7.2. Compliance with General Licensing Criteria Insert the following:
"CE will comply with all applicable Comission regulations, including those listed in 10 CFR 50.34(f) applicable to the CESSAR-DC, except 10 CFR 50.34(f)(2)(1). Aay future applicant that references the CESSAR-DC design must satisfy 10 CFR 50.34(f)(2)(i) by providing simulators."
7.3 Severe Accident Performance Goals CE statement that they will use the Severe Accident Performance Goals as guidance rather than requirements is inappropriate. Change "goals" to "requirements".
D Page 24 - Strike out last paragraph.
7.3.1 Prevention of Core Damage Page 25 - Last paragraph - change "goals" to "requirements."
7.3.3 Offsite Consequences for Severe Accidents Insert a containment design containment conditional failure probability of less than one in ten when weighted over credible core damage sequences.
First sentence - change design "goal" to design "requirements." This is true through out this section, 8.1 Physical Security and Sabotage Insert from the GE LBA Sections 8.2.1, Basis for Requirements and 8.2.2, Acceptance Criteria. Also, discuss analyses of system power module alternatives that could reduce the reliance on physical security for prevention of sabotage.
8.2 Site Envelope Parameters Strike out last sentence of last paragraph, page 29, beginning with:
"A nearly identical site envelope was
......................in terms of such parameters."
The proposed LBA contends that the CESSAR-DC can meet the necessary regulatory requirements for the maiority of potential nuclear power plant sites in the s
United States despite variations in site parameters from the assumed values at t most specific locations. However, it is important.ths.nete that the NRC's
/ft y acceptance of CESSAR-DC does not constitute a qualifi' d approval for any and e
all sites without a future site specific review.
8.3 Completion of Design Documentation Look at the GE LBA. This section could duplicate the GE LBA Section 8.4.1, Completeness of Design.
The last two paragraphs of the GE LL.,Section 8.4.1, page 11 should be included.
8.4. Program for Assurance of Quality in Design Strike out last sentence and replace with:
"The program will be reviewed to confirm it to be in compliance with the provisions of Appendix B of 10 CFR 50."
8.5 Standardize Functional Descriptions Strike out first clause of first sentence "In order to ensure that all applicable regulatory issues are closed out during the NRC Review and Design Certification process."
l
e Page 33 - Change last paragraph at "(2) the Staff's revied of...." to:
"(2) the Staff's review of future applications referencing the System 80+ Standard Design will consist of a complete review of the site specific considerations."
8.7 Generic Letters and IE Bulletins Change this section to reflect that CE will address all generic letters and bulletins for CESSAR-DC including an explanation of how the issue has been incorporated in the system design.
Delete last sentence "This will help...
............. design process."
8.9 Safety Goal Policy Statement Page 35 - Change implementation "guidance" to "requirements." Strike out
"-- as appropriate -."
8.10 Standardization Policy Statement Strike out last sentence "It will be necessary, however,
............to avoid last minute delays."
9.0 FINAL DESIGN APPROVAL Change to read:
"In August 1985, Combustion Engineering requested that the current CESSAR-F FDA (FDA-2) be amended to permit forward referenceability to those plants which hold a preliminary design approval in accordance with the NRC Severe Accident Policy Statement (the Severe Accident Policy requirements would be resolved on plant specific basis for each applicant of a full power license).
i Upon completion of NRC Staff review of that request, the Staff will issue a i
forward referenceable FDA Amendment (FDA-2, Amendment 1) that will be applicable to Docket No. 50-470 as described in Section 3.1."
When the NRC Staff completes its review of CESSAR-DC, the FDA (on the new docket only) will be amended again to permit forward referenceability in complete compliance with the Severe Accident Policy Statement (the Severe Accident Policy requirements would be resolved for the CESSAR-DC standard design). The amended FDA (FDA-2, Amendment 2) will be the basis for a System 60+ Design Certification Rule and will be applicable to the new docket no."
Insert, appropriately the GE FDA Section 9.
10.0 DESIGN CERTIFICATION Insert all of the GE LBA Sections 10.1, 10.2, 10.3, 10.4, 10.5 and 10.6 with changes to tailor it to CESSAR-DC and not GE ABWR.
APPENDIX B - PRA This appendix appears to be consistent with prior discussion with CE. The last paragraph of page B-13 shculd be exprnded to include data from more current NUREG 1150 PRAs.