ML20198M287

Forwards Request for Addl Info Re Rev 3 of AP600 Tier 1 Info Including Itaac.Review of Rev 3 Should Include Verification That All Tier 1 Info Was Extracted from AP600 Std Safety Analysis

ML20198M287
Person / Time
Site:	05200003
Issue date:	01/09/1998
From:	Joshua Wilson NRC (Affiliation Not Assigned)
To:	Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
NUDOCS 9801200062
Download: ML20198M287 (7)

Text

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Januar, 9, 1998.

i Mr. Nicholas J. Liparulo, Manspr Nuclear Safety and Regulatory Analysis Nuclear &nd Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, PA 15230

SUBJECT:

AP600 INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA (ITAAC)

Dear Mr. Liphrulo:

The enclosure to this letter cf.-'elns requests for additional information or corrections conceming Revision 3 of the AP600 Tier 1 information including the ITAAC. Your review of Revision 3 should include a verification that all Tier 1 information was extracted from the AP600 Standard Safety Anelysis (Tier 2) and that Yler 1 is consistent with the infom,ation in Tier 2. If you have any questions regarding this matter, you may phone me at (301) 415-3145, Sincercly, original: signed by:

Jeny N. Wilson l Senior Policy Analyst Standardization Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003

Enclosure:

As stated cc w/ encl: See next page k

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Docket File PDST R/F JRoe PUBLIC DMatthews TQuay JNWilson TKenyon BHuffman DScaletti ACRS (11)

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DOCUMENT NAME: A:\\lTACCLTR.JNW,

- To receive a copy of this document, n the box: "C" = Copy without attachment / enclosure "E" = Copy with attachmant/ enclosure "N" = No e OFFICE PA:PDST:DRPM, [__ D:PDWT:DRPM f

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l NAME JNWilsor(Brpf' TRQuay DATE 01/T/98 (/

01/?j /98 OFFICIAL RECORD COPY 9901200062 990109 PDR ADOCK OS2XX)o3

d Mr. Nicholas J. Liparulo.

Docket No. 52 003 Westinghouse Electric Corporation AP600 cc:

Mr. B. A. McIntyre Mr. Russ Be!!

Advanced Plant Safety & Licensing Senior Project Manager, Programs Westinghouse Electric Corporation Nuclear Energy Instituto Erergy Systems Business Unit 1776 l 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 & Lloonsing Doc Search Associates Westinghouse Electric Corporation Post Office Box 34 Ener9y Systems Business Unit Cabin John, MD 20818 Box 355 Pittsburgh, PA 15230 Dr. Craig D. Sawyer, Manager Advanced Reactor Programs Mr. Storting Franks GE Nuclear Energy U.S. Department of Energy 175 Curtner Avenue, MC-754 NE 50 San Jose, CA 95125 19901 Germantown Road 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 Germantown Road Barton Z. Cowan, Esq.

Germantown, MD 20874 Eckert Seamans Cherin & Mellott 600 Grant Street 42nd Floor Mr. Charles Thompson, Nuclear Engineer Pittsburgli, PA 15219 AP600 Certification NE.50 Mr. Ed Rodwell, Manager 19901 Germantown Road PWR Design Ccrtification c

Germantown, MD 20874 Electric Puwer Research institute 3412 Hillview Avenue Mr. Robert Malers, P.E.

Palo Alto, CA 94303 Pennsylvania Departmerit of Environmental Protection Bureau of Radiation Protection Rachel Carson State Oifice Building P.0, Box 8469 Harrisburg, PA 17105-8469

RAls for AP600 ITAAC 640.166 Your responses to RAls 640.21 and 640.100 are unacceptabio. The NRC staff has told Westinghouse, in numerous meetings, that Ms process for preparing Tier 1 design descriptions for the AP600 ITAAC was unacceptable. Your response indicates that the Westinghouse approach has not changed and, as a resuN. the statt's review can not be oc:rg:eted. Westinghouse needs to revise No approach and address the attached examples of the staffs problems with your approach for describing the Liquid Radweste System and the Passive Core Cooling System.

The Tier i design descriptions (OD) should be sufficient to reasonably understand the structure or system. The DD should neither be limned to the "most impo#1 ant" ele-monts of a structure or system, nor be necesserty limhed to the design commitments.

The DD should include the important design features and performance characteristics of a structure or system that will apply for the life of a plant that references this design.

Whereas, the design commitments will no longer be requirements after the ITAAC have been verified. Refer to the discussion in 640.100.

640.167 Your response to RAI 640.101 is unacceptable with_rsgard to verification of closure times for containment isolation valves. Specifically, your response to RAI 640.101 conflicts with your response to RAI 640.05. Also, the ADS opening times need to be included in the AP600 ITAAC. Remember trat your selection criteria in SGAR 14.3 has not been approved by the NRC.

640.168 The AP600 ITAAC must verify all of the important assumptions in the final revision to Westinghouse report 1100 SOC-001, " Containment Volumes and Heat Sinks," and Section 4 of WCAP-14407,"WGOTHIC Application to AP600." This RAI supplements

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RAI 640.155.

640.16g Your response to RAI 640.6g is unacceptable. In addition, RAI 640.6g was generic.

Therefore, the following ITAAC must be used for all MOVs that perform a safety-related function (not just MOVs in ;he reactor coolant system). The NRC staff requires an ITAAC en MOVs that does, at a minimum, the following two things:

(1) A test or type test must be performed at the MOV vendor's test facility to demon-strate the valve's ability to function under design (full flow and temperature) conditions.

The acceptance criterion should be the existence of a test report that verifies that the valve performs its safety function. Westinghouse's proposed ITAAC for this test is acceptable. Eee ITAAC in Table 2.1.2 4, item 12.(a)(l).

(2) A test must be performed of the as-installed MOV under partial flow condit;or.s (i.e., under preoperational plant conditior,s). The acceptance criterion should be that the MCN partial fins test is bounded by the full flow test or type test and char,ges poshion as indicated in Table 2.1.21. This is a resight-forward and reasonable request (and ABWR and System 80+ included this test in their !TAAC). You are proposing that an inspection (not a test) be performed for the existence of a report that verifies the MOV is bounded by the vendor test or type test. Tt,is is unacceptable and

. would allow (perhaps) some type of analysis to demonstrate that the as-installed MOV is bounded by the vendor test or type test. The analysis might not even be relevant to Enclosure

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l the as-installed MOV N is intended to qualsfy. Although the NRC allows licensees of operating plants to use analyses (i.e., EPRI PPM) to demonstrate their MOV design capability, we believe N would not be appropriate to use analysis alone for an MOV in a l

newly-constructed plant where the as-installed valve has not seen any actual service.

i' A partial flow test that is correlated to a full flow test is the most reliable approach to demonstrate the as-installed MOV capability.

640.170 Your response to RAI 640.157 is unsoceptable because it did not respond to the generic portion of the question. Specifically, Westinghouse must review all of its references to a report in the ITAAC acceptance orNoria and verify that the subject report is identified and desortbed, as appropriate, in the SsAR. Also, references to the

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test spoolfications and procedures that are prepared for the initial Test Program do not

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resolve this concom.

l 640.171 Your responses to RA's 640.54 and 640.151 are unacceptable. The inspection of the functional arrangement of a structure or system needs to be consistent with the approach taken by the evolutionary designs and cannot be limited to disconnected pieces of the "most important" elements of a structure or system. Yoc. definition of

" functional arrangement" must be revised, as follows:

Functional arrangement means the physical a,.ancement of structures, systems, and components to provide the service for which the structure or system is intended.

640.172 Your responses to RAls 640,163 and 640.151 are unacceptable. The ITAAC for the functional arrangement inspection of a structure or system needs to be consistent with the approach taken by the evolutionary designs and cannot be limited to disconnected pieces of the "most important" elements of a structure or system. The ITAAC for

" functional arrangement" must be revised, as follows:

Design Commitment "The funcUonal arrangement of the (building or system)is described in Section ITA

• inspection of the as built system will be performed."

Acceptance Criteria "The as-built (building or system) conforms with the description in Section t

640 473 Your response to RAI 640.150 is unacceptable. Your Tier 1 design descriotion and ITAAC must include the cnteria for the Sa'smic Monitoring System (SJS), specificelly the criteria set forth in the last 4 sentences of RAI 640.150. Furthermore, your specF.ed rationale for not providing this information is wrong The fact that the design details are described in SSAR Section 3.7.4 (Tier 2) does not justify excluding this informat6on from Tier 1. All Tier 1 information must exist b Tier 2. The selection criteria and meihodology in SSAR Section 14.3 has not been approved by the NRC

- and, therefore, does not justify exclesion of the requested information. The NRC staff has determined that the criteria for SJS is important and, therefore, it meets the

• graded approach" guidance in SRP 14.3. Possible future technology im;.rovements is not an acceptable rationaln for excluding the requested lnformation and the SJW criteria do not exclude future improvements in seismic instrumentation.

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3 640.174 Your response to RAI 640,152 is unacceptable. The Nuclear Fuel System and the Control Rod Drive System require Tier i design descriptions consistent with the significance of these systems and the approach used on the evolutionary desigt.s.

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These syst*ms also require an inspection of the functional arrangement, similar to the fuel and control rod systerr.s ITAAC for the System 80+ design.

640.175 Your response to RAI 640.136 is unacceptable. The test for the first (prototype)

AP600 reactor intemals must be included in your ITAAC. The ITAAC will be similar to type tests (refer to ABWR ITAAC) that may only be performed once, provided the the test results are applicable to subsequent plants that reference this design.

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REVIEW OF LloulD RADWASTE SYSTEM IN AP6% CERTIFIEQ DESIGN MATERIAL i

AGAINST THE SRP 143. APPENDIX C.1 DESIT@ESCRIPTION AND FIGURES.

I The AP600 Certified Design Material (CDM) should provide a narrative design description that explains what the system is about according to SRP 14.3, Appi ndix C.1. The staff has reviewed the CDM Section 2.3.10, Liquid Radweste System, against th6 SRP, and identified l

4 the following items to be inadequate in the design description and figures.

A.

DESIGN DESCRIPTIONS 1.

System Purpose and Functions i

The information provided in the CDM is incomplete and misleading. Specifically, the statement in item 1 of Section 2.3.10, "the functional arrangement of the applicable portions of the WLS is as shown in Figure 2.3.10-1,"is misleading because Figure 2.3.101 does not Inc.ude the components that carry out the major function of the liquid redweste system, it shows only waste input to the system, but does not include most of the system components such as holdup tanks, ion exchangers, filters, monitor j

tanks...etc.. The staff identified the above concem in a mumber of meetings with Westinghouse and in RAI 460.76 by a letter to Westinghouse, dated August 22, igg 7, i

but has not received any response from Westinghouse. Based on the current information, the staff has determined that the system 5 not reviewable and not acceptable.

2.

The location of the system is not specifed.

3.

The key features and components that are used for receiving, storing, processing, and discharging the redwestes such as holdup tanks, ion exchangers, fiPars, monitor tanks,

...etc. are not included.

4. '

The system operation information is not included.

B.

FIGURES 1.

The figure does not include all the components that are nseded to characterize the system function. This is discussed in item A.1 above.

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Identification of the system boundaries with other systems is incomplete because of the missing components as identified in item A.1 above.

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REVIEW OF PASSIVE CORE COOLING SYSTEM AGAINST THE SRP 14,3. APPENDIX C.1 DESIGN DESCRIPTIONS 'DD) AND FIGURES,

1. System pumose and function Rev.3 does not capture system components that are involved in accomplishing the direct safety function of the system. The purpose of PRHR HX, Accumulator, CMT or IRWST is not included.

It is not specifed whether the system is safety related or not. Since the DO does not designate the system as safety related system, the exceptions are not noted.

2. Location of System The location of the system is not specified.

3. Key design features of the system Key design features of the system like PRHR HX, CMTs, Accumulators, IRWST are not described. Risk significant features such as diverWty between the accumulator check valves and CMT check valves, diversity of the squib valves in the IRWST injection lines and recirculation lines and diversity of PRHR AOVs from the AOVs in the CMT are not included. IRWST gutter and its isolation valves are not specified as safety grade.

4. System operation it is not specified that the system is not in operation during normal operation and is on Standby.

5. Interface requirements Interface requirements are not included.

FIGUPES Systems boundaries with other systems should be clearly delineated in the figures.

System boundaries are not clearly delineated in the figure.

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