ML20197K008

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Forwards Reactor Sys Branch SER Input Which Has Open Items That Have Been Extracted & Designated as Final SER Open Items
ML20197K008
Person / Time
Site: 05200003
Issue date: 12/16/1997
From: Huffman W
NRC (Affiliation Not Assigned)
To: Liparulo N
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
NUDOCS 9801050175
Download: ML20197K008 (6)
v • d • e


Text

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e s Decernber 16, 1997 Mr. Nicholas J. Liparuto, Manager Nuclear Safety and Regulatory Analysis Nuclear and Advanced Technology Division Westinghouse Electr,c Corporation

' l P.O. Box 355  ;

Pittsburgh, PA 15230 -l l

SUBJECT:

OPEN ITEMS ASSOCIATED WITH REACTOR SYSTEMS BRANCH SAFETY EVALUATION REPORT (SER) ON AP600 TECHNICAL SPECIFICATIONS (TSs)  ;

i

Dear Mr. Liparulo:

The U.S. Nuclear Regulatory Commission Standardization Project Directorate has received an SER input from the Reactor Systems Branch on the AP600 TSs. This input has open items which have been extracted and designated as final safety evaluation report open items in the enclosures to this letter, if you have any questions regarding this matter, you may contact me at (301) 4151141.

Sincerely, original signed by:

William C. Huffmen, Project Manager Standardization Project Directorato Division of Reactor Program Management Office of Nuclear Reactor Regulation -

Docket No. 52 003 ,

Enclosures:

As stated ,

cc w/ encl: See next page QLSTRIBUTION:

Docket File PDST R/F TQuay -1 PUBLIC TKenyon- . WHuffman JSebrosky DScalett!' JNWilson '

ACRS (11) WDean,0 5 E23 JMoore,0-15 B18 '

SNewberry,0 8 E2 GHolahan,0-8 E2 HLi,0-8 H3 MGareri,0 8 H3 GHsil,0-8 E23 RCaruso,0-8 E23

. TCollins,0-8 E23 MReinhart,0-13 H15 AChu,0-13 HIS WBeckner,013 H15 DOCUMENT NAME: A:TS 2 OI.SER To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy ,

with rttachment/ enclosure "N" = No copy [

OFFICE PM.PDGT:DRPM l- BC:TSB:ADPil 1- D:PDST:DRPM l l 'l .

NAME WCHuffman:MWBeckneW7 TRQuayhl h DATE 12/15/97 12/16/97 12/R /97M ,. .

OFFICIAL RECORD COPY 9801050175 971216 PDR ADOCK 05200003 E PDR llllpil,IlJlllJ,Ill NRC FiE Cmm eev

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  • Mr. Nicholas J. Liparulo Docket No. 52 003 Westinghouse Electric Corporation AP600 cc: Mr. D. /.. McIntyre Mr. Russ Bell Advanced Plant Safety & Licensing Senior Project Manager, Programs Westinghouse Electric Corporation Nuclear Energy Institute Energy Systems Business Unit 17761 Street, NW P.O. Box 355 Suite 300 Pittsburgh, PA 15230 Washington, DC 20006-3706 Ms. 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 Dr. Craig D. Sawyer, Manager Advanced Reactor Programs Mr. Sterling Franks GE Nuclear Energy U.S. Department of Energy 175 Curtner Avenue, MC-754 NE 50 San Jose, CA 95125 19901 Gennantown Roed Germantown, MD 20874 Mr. Robert H. Buchholz GE Nuclear Energy Mr. Frank A. Ross 175 Curtner Avenue, MC 781 U.S. Department of Energy, NE-42 San Jose, CA 95125 Office of LWR Safety and Technology 19901 Geimantown Road Barton Z. Cowan, Esq.

Germantown, MD 20874 Eckert Seamans Cherin & Mellott 600 Grant Street 42nd Floor Mr. Charies Thompson, Nuclear Engineer Pittsburgh, PA 15219 AP600 Certification NE 50 Mr. Ed Rodwell, Manager 19901 Germantown Road PWR Design Certification Germantown, MD 20874 Electric Power Research Institute 3412 Hillview Avenue Mr. Robert Maiers, P.E. Palo Alto, CA 94303 Pennsylvania Department of Environmental Protection Bureau of Radiation Protection Rachel Carson State Office Building P.O. Box B469 Harrisburg, PA 17105-8469

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REACTOR SYSTEMS BRANCH SER OPEN ITEMS ASSOCIATED WITH AP600 TECHNICAL SPECIFICATIONS 440.776F LCO 3.0.6 LCO 3.0,6 contains a typographic error where the term " Specification 5.5.9," should be "Specifi-cation 5.5.8."

440.777F LCO 3.0.7 and BASES LCO 3.0.7 and BASES contain a typographic error where the term '; ,0 3.1.9" should be

  • LCO 3.1.8."

440.778F LCO 3.4.12 BASES BASES B 3.4.12 contains several statements that the ADS has a total of 16 valves, which are inconsistent with the ADS design of 20 valves. This should be corrected in the next TS revision.

440.779F LCO 3.5.4 PRHR HX Operating in its letter of September 23,1997 (B. McIntyre to T. Quay, NSD NRC 97 5341) Westinghouse provided a revision to Response to RAI 440.670, and stated that Requeed Action F.2 will be revised to *Be in MODE 3" within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Westinghouse should ensai e this revision is incorporated in the next revision to the AP600 TS.

440.780F LCO 3.7.2 Main Steam Isolation Valves in a letter (B. McIntyre to T. Quay, " Transmittal of Responses to RAls 440.731 Through 440.734,"

NSD NRC 97 5438) of November 17,1997, Westinghoui e provHed a revised Specification 3.7.2 and BASES. In this revision, the restoration completion time of an inoperable MSIV is changed to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, consistent with the STS, and the restoration completion of the MSIV backup and branch valves remains at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The acceptable closure time in SR 3.7.2.2 for the MSIV backup and branch valves is changes to 5 seconds, consistent with the safety analysis assump-tions. Westinghouse should ensure that this proposed change as described in the November 17, 1997 letter is incorporated in the next TS revision.

440.781F LCO 3.7.3 Main Feedwater isolation and Control Valves (MFIV and MFCV)

The first page of TS 3.7.3 is missing in the TS version 08/97, Amendment O. This page was included in the June 18,1997 Westinghouse submittal (B. McIntyre to T. Quay, "Advar,ce Markup Of AP600 Technical Specifications," NDS-NRC 97 5176, June 18,1997). The missing page should be restored.

E, ute

2-440.782F LCO 3.4.16 RCS Pressure isolation Valve (PlV) Integrity There are typographic errors in *SR 3.4.11.1" and "3.4.11.2", which should be *SR 3.4.16.1" and '

"3.4.16.2" respectively,in Sur alliance Requirements and BASES 3.4.13. They should be corrected in the next TS revision.

440.763F LCO 3.4.12 ADS Operating LCO 3.4.12 specifies that the ADS, including 10 flow paths, shall be operable during MODES 1 through 4 operation if one flow path, or one stage 1 flow path and one stage 2 or stage 3 flow path is inoperable, Action A.1 requires restoration of these flow path within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

BASES 3.4.12 does not provide sufficient jusTEcation for the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action completion time. In response to RAI 440.671 (Westinghouse letter, B. Mc'ntyre to T. Quay, NSD NRC 97 5278, August 27,1997), Westinghouse provided justifications for the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time.

Westinghouse contended that the basis for 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is consistent with the STS PORV,3.4.11, Action B, and consistent with two train ECCS systems that can perform their safety function without a single failure. The applicant also contends that the !noperable ADS flow path conditions (Condition A) have been assumed as single failures in the Chapter 15 LOCA analyses. The staff finds that the design bases and functional requirements are so different between the PORVs and the APG00 ADS valves that it is not prudent to draw an equivalence between them, in addition, a single failure assumption in the safety analyses is not to be used for a faliure that has been found to exist. The applicant should provide additional justifications, which should be documented in the TS BASES, to justify the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time. This is open item.

440.784F LCO 3.4.15 Low Temperature Overpressure Protection (LTOP) System LCO 3.4.15 specifies that either the RNS suction relief valve, or the RC6 depressurized and an RCS vent path of greater than or caual to 5.4 square inches, or both, shall be operable with the accumulators isolated. The operability of the PORV in STS is deleted because APG00 does not have, nor require, a pressurizer PORV for overpressure protection. A NOTE is added to restrict startup of a RC pump when the PCS temperature is greater than 200*F and the pressurizer level is greater than or equal to 92 percent span. This limitation is necessary to limit the heat input tra".sient to within the capacity of the RNS suction relief valve. This is acceptable.

The applicability of LCO 3.4.15 is different from the STS LTOP LCO which is applicable for MODE 4 when all cold leg temperatures are less than 275'F, and MODE 5. The applicability of LCO 3.4.15 is for MODES 4 and 5 operations with the RNS alianed and open to the RCS and the RCS temperature less than 350 F, as well as for MODE 6 when the reactor vessel head is on.

Limiting the LCO 3.4.15 applicability to the alignment of RNS to the RCS is necessary to ensure that the RNS suction relief valve is availabla for pressure protection. LCO 3.4.7 requires operability of the pressurizer safety valves (PSVs) to provide overpressure protection during MODES 1,2,3, and 4 with the RNS isolated or RCS temperature greater than or equal to 350*.

However, in MODE 5 with RCS temperature less than 200*F, and the RNS is isolated from the RCS, neither LCOs 3.4.7 nor 3.4.15 are applicable to provide overpressure protection. In l

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3-addition, with the PSV lift setting of greater than or equal to 2460 psig, the PSVs wkl not be able to provide LTOP protection. The applicant should evaluate or revise LCO applicabiSty to provide suitable LTOP protection with the RNS isolated from the RNS. This is open item.

440.785F Reactra Vessei Head Vent (RVHV) in accordance with the requirement of 10 CFR 50.34(f)(2)(vi), the AP600 desbn uses the reactor vessel head vent valves to remove noncondensable gases or steam from the reactor vessel head to mitigate a possible condition of inadequate core cooling or impaired natural circulation through steam generators resulting from the accumulation of noncondensable gases in the reacto system. The RVHV valves, which can be ope;ated from the main control room to provide an en.orgency reactor coolant letdown path, can also be used to prevent pressurizer overfill fonowing long term toss of heat sink events. A flow-limiting orifice is provid6d downstream of each set of head vent valves to limit the emergency letdown flow rate. The emergency Midown of the reactor coolant is credited in the se'ety analysis of some design basis events that otherwise could result in the pressurizer overfill. Therefore, a LCO is required for the RVHV system per TS screening Criterion 3. The AP600 TS does not include the RVHV system. This is open item.

440.786 F TS 5.6,5 Core Operating Limits Report (COLR)

Specification 5.6.5, in addition to requiring that the core operating limits be established and documented in the COLR for the parameters listed, lists the approved analytical methods used to determine the core operating limits. WCAP 12472 P A," BEACON Core Monitoring and Operations Support System,"is listed at the approved method used for TS 3.2.3 for monitoring compliance with the core operating limits specified in the COLR. The BEACON system has been accepted by NRC for performing continuous on-line core monitoring and operations support functions for Westinghouse PWRs subject to conditions described in the staff safety evaluation report and accompany technical evaluation report for the acceptance of WCAP-12472 P-A.

Though the BEACON syste.m is potentially suitable for other reactors, it has been examined in the topical report and by the staff only for current standard Westinghouse systems. For applications of BEACON to plants or core designs that differ sufficiently to have a significant impact on the WCAP-12472 P A data base, the generic uncertainty components may require reevaluation in order to ensure that the assumplicas made in the BEACON uncertainty analysis remain valid, and assure that the power peaking uncertainties for enthalpy rise and heat flux provide 95 percent probability upper toluance limits at the 95% confidence level. Acceptance for these applications would require further review and approval. SSAR Subsection 4.3.1.6.2 indicates that AP600 uses fixed in-core detectors, in-core thermocouples, and loop temperature measurements. This is different from the instrumentation data base described in WCAP-12472-P-A, which use, among other instrumentation, movable incore detectors. The applicant does not provide documentation for the use of fixed in-core detectors in the OPDMS for AP600 for NRC review and approval. TS 5.6.5 contains a " REVIEWER'S NOTE" stating that additional power distribution control and surveillance methodologies (for MSHIM and OPDMS monitoring) are currently under development and will be added upon NRC approval. This is an open item.

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4 440.791F LCO 3.4.13 ADS - Shutdown, RCS Intact LCO 3.4.14 ADS - Shutdown, RCS Open

, LCO 3.5.3 CMTs - Shutdown, RCS Intact LCO 3.5.5 PRHR HX - Shtdown, RCS Intact LCO 3.5.7 IRWST - Shutdown, RCS inventory High LCO 3.5.8 IRWST - Shutdown, RCS Inventory Low These technical specifications are still under review by the staff as part of the shutdown risk evaluation and will therefore be tracked as an open item.

440.792F LCO 3.3.2 Engineered Safety Feature Actuation System Instrumentation There are severalinconsistencies in the engineered safeguards actuation system instrumenta-tion actuation setpoints between those listed in TS Table 3.3.2-1 and those listed in SSAR Table 7.3-1. For example, the safeguards actuation signal and the steam line isolation signal are both listed as High-2 containment pressure in TS versus High-1 containme,,t pressure in the SSAR table. The CVS makeup system isolation signal is listed as High-1 pressurizer water level in TS versus auto or manual safeguards actuation signal coincident with High-1 pressurizer water level. The IRWST recirculation valve actuation signalis listed as safeguards actuation in TS versus safeguards actuation signal coincident with low IRWST level. The applicant should evaluate and make appropriate corrections in the TS Table 3.3.21 and/or SSAR Table 7.3-1 to ensure their consistency as well as consistency with the input to the safety analyses of the des'gn basis accidents. This is open item.

NOTE: LCO 3.4.16 RCS Pressure Isolation Valve (PlV) Integrity PlV leak testing is an open item in the Reactor Gystems Branch SER on technical specifications as discussed in NRC letter to Westinghouse,"Open item Associated with AP600 Pressure isolation Valve Leak Testing," dated October 16,1997. The staff is reviewing Westinghouse letter NSD NRC-97-5452, dated November 21,1997, which responds to the staff concems on PlVs, however, the staff still considers this an open item.

Westinghouse has already captured this open item in its tracking system under OITS# 6040 through 6043 related to FSER Open items 250.30F through 250.33F. It has been included again to emphasize the importance of the resolution of this issue.

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