ML20198S703
| ML20198S703 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 12/12/1997 |
| From: | Joseph Sebrosky NRC (Affiliation Not Assigned) |
| To: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 9801260261 | |
| Download: ML20198S703 (14) | |
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.3 t Decemb:r!12p~1997? 2 D
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"g i Mr. Nicholas J.'Liparuto, Managerw..
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Nuclear Safety and Regulatory Analysis ',
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SUBJECT:
" OPEN ITEMS ASSOCIATED WITH CHAPTER 20 OF THE AP600 SAFETY :
- EVALUATION REPORT (SER) 1
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Dear Mr. Liparulo:
The Plant Systems Branch has provided the subject SER to the projScts staff. However, the =
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' SER contained some open items., These open items have been extracted from the SER and can.
be found in the enclosure to this letter.
- You have requested that portions of the information submitted in the June 1992, application for J
Edesign certification be exempt from mandatory public disclosure. While the staff has not :
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U 1 completed its review of your request in accordance with the requirements of 10 CFR 2.790, that.
- portion of the submitted information is being withheld from public disclosure pending the staffs i
final determination. The staff concludes ' hat these follow on questions do not contain those e
- portions of the information for which exemption is sought.' However, the staff will withhold this
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h letter from public disclosure for 30 calendar days from the date of this letter to allow L
' Westinghouse the opportunity to verify the staffs conclusions, if, after that time, you do not" request that all or portions of the information in the enclosures be withheld from public disclosure in accordance with 10 CFR 2.790, this letter will be placed in the iluelear Regulatory Commission-'
Public Document Room.-
If you have any questions regarding this matter, you may contact me at (301) 415-1132.
Sincerely, originalssigned by:
Joseph M. Sabrosky, Project Manager Standaruization Project Directorate
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-Division of Reactor Program Management
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Office of Nuclear Rear.or Regulation Docket No.~ 52-003 DISTRIBUTION" See next page 1
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Enclosure:
'As stated
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4-Docket No.52-003 4
Mr. Ncholas J. Liparuto APbOO Westinghouse Electric Corporation.
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Mr. B. A. McIntyre Ms. Cindy L. Haag -
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L Advanced Plant Safety & Licensing Advanced Plant Safety & Licensing Westinghouse Electric Corporation Westinghouse Electric Corporation :
Cnergy Systems Business Unit-Energy Systems Business Unit P.O. Box 355 Box 355
- Pittsburgh, PA -15230 Pittsburgh, PA 15230 4
Enclosure to be distributed to the following addressees after the result of the proprietary evaluation is received from Westinghouse:
Mr. Russ Bell --
Ms. Lynn Connor Senior Project Manager, Programs DOC-Search Associates Nuclear Energy institute Post omce Box 34 1776 ! Street, NW Cabin John, MD 20818 Suite 300 Washington, DC 20006 3706
?.ir. Robert H. Buchholz GE Nuclear Energy Dr. Craig D. Sawyer, Manager 175 Curtner Avenue, MC-781 Advanced Reactor Programs San Jose, CA 95125 GE Nuclear Energy 175 Curtner Avenue, MC-754 _
Mr. Sterling Franks San Jose, CA 95125_
U.S. Department of Energy NE 50 Barton Z. Cowan, Esq.
19901 Germantown Road c
Eckert Seamans Cherin & Mellott Germsniown, MD 20874 600 Grant Street 42nd Floor Pittsburgh, PA 1521g Mr. Charles Thompson, Nuclear Engineer AP600 Certification
..Mr. Frank A. Ross -
NE-50 U.S. Department of Energy, NE -19931 Germantown Road Office of LWR Safety and Technology Germantown, MD 20874 19901 Germantown Road Germantown. MD -20874 i
Mr. Ed Rodwell, Manspr PWR Design Certifestion Electric Power Research Institute 3412 Hillview Avenue L
Palo Alto, CA 94303 L
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DISTRIBUTION: Letter to Mr. Nicholas J. Lloarulo; Dated: December 12, 1997
- Docket File -fEnclosure to be held for 30 days
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OPEN ITEMS ASSOCIATED WITH CHAPTER 20 650.15F: Issue B-36:
Develop Design, Testing, and Maintentnce Criteria for Atmosphere Cleanup System Air Filtration and Adsorption Units for Engineered Safety Features Systems and Normal Ventilation Systems As discussed in NUREG-0933, Issue B-36 addressed the staff concem that the then-current guidance and staff technical positions regarding ESF and normal ventilation system air filtration and adsorption units needed to be revised. This issue was resolved by the issuance of Revision 2 of RG 1.52 for ESF ventilation filter units in March 978, and Revision 1 of RG 1.140 for normal ventilation filter units, in October 1979.
In Section 1.9.4 of the SSAR, Westinghouse states that there are no safety-related air filtration systems in the AP600 design. The specific functions of the normal ventilation systems are oudined in Sections 6.4 and 9.4.1 of the SSAR, with a discussion on the conformance with RG 1.140 in SSAR Appendix 1 A. However, Westinghouse needs to provide in the SSAR a detailed list of how the AP600 normal ventilation systems conform to each regulatory position of RG 1.140. In addition, a link to this information should be provided in Sections 1.9 and 9.4 of the SSAR. This is Open item 650.15F.
Therefore, Issue B-36 is not resolved for the AP600 design.
650.16F: Issue B46: Control Room Infiltration Measurements The control room area ventilation systems and control building layout and structures are reviewed to ensure that plant operators are adequately protected against the effects of accidental releases of toxic and radioactive gases and that the control room can be maintained as the ba-kup center from which technical personnel can safely operate during an accident. A key parameter affecting control room habitability is the rate of air infiltra*Jon into the control room.
Current estimates of these rates are based on data relating to buildings that are substantially different from typical control room buildings in nuclear power plants.
As discussed in NUREG-0933, issue B-66 was to facilitate compliance with the following staff requirements and guidance on control room habitability: (1) GDC 19 and (2) SRP Sections 6.4,
" Control Room Habitability Systems," and 9.4.1, " Control Building Ventilation Systems."
Additional experimentally measured air exchange rates of operating reactor control rooms resulted in Revision 2 of SRP Section 6.4. See also the resolution of issues 83 and Ill.D.3.4 for the AP600 design in Sections 20.3 and 20.4, respectively, of this report.
In Section 1.9.4 of the SSAR, Westinghouse states that the main control room for the AP600 design is essentially leak-tight. Unfiltered air in-leakage is minimized by maintaining the main control room at a slightly positive pressure and the verification of the design infiltration rate is in accordance with SRP Section 6.4, " Control Room Habitability Systems." Control room habitability is discussed in Section 6.4 of the SSAR.
This issue is still not resolved because the staff has concluded that the AP600 design does not meet the dose limits of GDC 19. This is open item 650.16F.
Enclosure
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- 450.17F:lasue'43: Reliability of Air Systems
- As discussed in NUREG-Og33, issue 43 is not required for the AP600 design to meet 52.47(a)(1)(ii) or (iv); however, the staff believed it should be addressed for the AP600 design because the lasue dealt with all causes of air system unavailability. The issue addressed the incident at Rancho Seco where desiccant particles in the valve operator caused the slow closure of a containment isolation vahm. Desiccant contamination in the instrument air system (IAS) was also found to be a contabuting cause of the loss of the salt water coolmg system at San Onofre in March 1980; this incident resulted in issue 44, Tailure of the Saltwater Cooling System."
Since the only new generic concem found in the evaluation of the San Onofre event was the common-cause failure of safety-related components due to contamination of the IAS, issue 44 was combined with issue 43.
Issue 43 was broadened to include all causes of air system unavailability because U.S. LWRs rely upon air systems to actuate or control safety-related equipment during normal operation even though they are not safety-grade systems at most operating plants. Safety system design criteria require (and plant accident analyses assume) that safety-related equipment dependent upon air systems will eithar " fail safe" upon loss of air or perform its intended function with the assistance of backup accumulators. An NRC Office for Ana'ysis and Evaluation of Operational Data (AEOD) case study highlighted 2g failures of safety-related systems that resulted from degraded or malfunctioning air systems. These failures contradict the requirement that safety-related equipment dependent upon air systems will either " fail safe" upon loss of air or will perform their intended function with the assistance of backup accumulators. Some of the systems that may be significantly degraded or failed are DHR, auxiliary feedwater, BWR scram, main steam isolation, salt water cooling, EDG, containment isolation, and the fuel pool seal system. The end result of degradation or failure of safety or safety-related systems is an increase in the expected frequency of core-melt events and, therefore, an increase in put,lic risk.
This issue was resolved by the issuance of GL 88-14, " instrument Air Supply Problems Affecting Safety-Related Equipment," dated August 8,1988, which required licensees and applicants to review the recommendations of NUREG 1275 (" Operating Experience Feedback Report - Air Systems Problems," two volumes, dated July and December 1987, respectively) and perform a design and operations verification of the IAS. The following is a discussion of how Westinghouse considered the recommendations in NUREG-1275, Volume 2, for the AP600 design:
(1)
To ensure that air system quality is consistent with equipment specifications and is periodically monitored and tested.
In Section g.3.1 of the SSAR, Westinghouse states that in accordance with NUREG-1275, instrument air quality meets the manufacturer's standards for pneumatic equipment supplied as part of the plant. In addition, periodic checks are made to assure high quality instrumen' air as specified in ANSI /ISA-S7.3, "fluality Standard for Instrument Air."
(2);
To ensure adequate operator response by formulating and implementing anticipated transient and system recovery procedures for loss-of air events.
Westinchouse has not addressed this recommendation.
(3)
To improve training to ensure that plant operations and maintenance personnel are
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sensitised to th:importanos of air eyttoms to common mode failures.
West 6nghouse has not rddressed this recommwistion.
(4)
To confirm the adequeoy and reliability cf safety related backup accumulators.
I in Section g.3.1 of the SSAR, Westinghouse states that there are no safeiy related air operated vehes that rely on safety related air accumulators to actuate to the fall safe i
i poshion upnn bas of air pressure.
(5)
To verdy equipment rSeponse to gracNal losses of air to ensure that such losses do not I
resuN in events which fall outside FSAR analysis.
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._in Section g.3.1.4 of the SSAR, Westinghouse states that dudng inhial plant testing prior to reactor startup, safety systems utilizing instrument air wiii be tested as part of the safety system test to vertfy fail safe operation of air-operated vabes upon sudden loss of f
instrument air or gradual reduction of air pressure as described in RG 1.68.3, 4
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- Prooperational Testing of instrument and Control Air Systems."
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Westir.,, house concluded that this lasue was not relevant to the AP600 design because the issue l
la the responsibility of the COL applicant. In the DSER, the staff re aested that Westinghouse
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sddress this issue for the AP600 design because some of the recommendations in i
NUREG 1275, Volume 2, pertain to the quality of the design of the air systems, the adequacy and reliability of safety related backup accumulators, and to verify equipment response to gradual losses of air do not results in events outside the accident restyses, which are not the 1
responsibility of the COL applicant. Westinghouse revised the SSAR as described above to address recommandations 1,4, and 5 which the staff finds acceptable. However, Westinghouse needs to add a statement to the SSAR desertbes that recommendations 2 and 3 are the l
respoisibility of the COL applicant. Therefore, Open hem 20,3-4 (650.17F)is still unresolved.
ThereWe, issue 43 is not resolved for the AP600 design.
l 850.1 issue 82: Beyoed.Oesigneasls Accidents in Spent Fuel Pools The risks of beyond-design basis accidents in the spent fuel storage pool were examined in
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l WASH 1400, " Reactor Safety Study, An Assessment of Accident Risks in U S. Commercial Nuclear Power Plants," dated October 1975, and it was concluded in the report that these risks were orders of magnitude be!ow those involving the reactor core. Issue 82 in NUREG-Ogg3 was
- the reexamination of accidents in the spent fuel storage pool. The reasons are two-fold. First, spent fuel is being stored instead of reprocessed. This issue, however, is not roouired for the 4
AP600 design to meet 52.47(a)(1)(ii) or (iv).
' This has led to the expansion of onshe fuel storage by rneans of high-Jensity storage rocks, which results in a larger inventory of fission products in the pool, a greater host loaci on the pool b
cooling system, and less distance between adjacent fuel assemblies. Second, some laboratory studies have offered evidence of the possibility of fire propagation belween assemblies in an air-cooled environment. These two r3asons, in combination, provide me basis for an accident scenario that was not previously considered.
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4 As sta6ed in NUREG 0933, because of the large inherent safety margins in the design and construction of opent fuel pools, this issue was resolved and no new requirements were established.
in Section 1.9.4 of the SSAR, Westinghouse states that the AP600 includes design provisions that preclude draining of the spent fuel pool. /Joo, provisions are availabis to supply water to the l
pool in the event the water covering the spem fuel begins to boli off. In the DSER, the staff I
requested that Westinghouse address probabilistic risk assessment for ecoldents in the spent fue! pool for the AP600 design. This was designated as Open item 20.>10. Oper, Hem 20.>10 (660.18F) is still unresolved because the id f:": risk assessment has not been addressed.
l Thorofore, lasue 82 is not resolved for the AP900 desigd.
f 480.19F: lesue 83: Control Room Habitability i
. As discussed in NUREG-0933, issue 83 addressed the signl9 cant ditorepancies found during a 1-survey of existing plant control rooms before 1983. These discrep. mies included the l
- inconsistenales between the design, construc4n, and oportilon or the contM room habitability systems and the descriptions in the licensing-Dasis documentation, lu addition, the staff determined that total system testing was inadequate and that the control systems were not always tested in accordance with the plant TS. The following issues are related to lasue 83:
i (1) Issus B 36 on ortleria for air filtration and adsorption units for atmospheric cleanup systems, (2) lasue 866 on control room infiltration measuremords, and (3) issue Ill.D.3.4 also on control room hatntability. These three issues are discussed elsewhere in 2octions 20.2 and 20.4 of this i
report.
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in Section 1.9.4 of the SSAR, Westinghouse states that habitability of the main control room during normal operation is provided by the non safety-related nuclear Island nonradioactive e
ventilation system (VSS). In the event of a design basis accident involving a radiaGon release or i
a loss of all ac power event, the non safety-related nuclear island nonradioactive ventilation j
system is automatically terminated, the rnain com,ol room pressure boundary is isolated, and the 4
L safety related main control room emergency habitability system (VES) is actuated.
The safety-related main control room emergency habitability system supplies breathable quality sir for the main control room operators while the main control room is isolated. In the event of extemal smoke or radiation release, the non safety-related nuclear Island nonradioactive ventilation system provides for a supplemental filtration mode of operation, as discussed in Section g.4 of the SSAR. In the event of a Hi-Hi radiation level, the ufety-related main control room emergency habitability system is actuated, in the unlikely event of a toxic chemical release, i
the safety rstated main control room emergency habitability system has the capability to be l
manually actuated by the operators. Further, a 6-hour supply of self-contained portable breathing i
equipment is stored inside the main control room pressure boundary, j
- In the DSER, the staff requested that Westinghouse address control reom habitability and
- issue 83 for the AP600 design. This was designated as Open item 20.311. Open item 20.311 (650,19F)is still unresolved because (1) the staff has determined that the AP600 design does
- not meet the dose limits of GDC 19 and (2) Westinghouse needs to stdo in Section 6.4.7 of the SSAR that the COL applicant referencing the AP600 design is responsible to verify that the as-l built design, procedures, and training are consistent with the licensing basis documentation and l
the intent of issue 83 (see COL Action item 6.4 2).
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Therefore, lasue 43 is not resolved for the AP600 design.
460.30r's leeue 134: Auxiliary Foodwater System Reliability
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f Following the loss of foodwater even', at Davis Besse in 'g86, as discussed in NUREG Og33, d
Issue 124 addressed increasing reliability of the auxiliary or EFW system to 10 i
unavailability / demand, in 1985, operating experience as well as staff and industry studies t
indicated that these systems failed at a high rate. A function of this system in the majority of current plants is to supply water to the secondary side of the SGs during system fill, normal plant l
hostup, normal plant hot standby, and normal plant cold shutdown. The EFW system also functions following loss of normal feedwater flow, including loss due to offsite power failure, and supplies EFW following such postuisted accidents as a MFW line break or a MSLB. Therefore, l
the reliability of this system is important to plant safety.
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The NRC investigation of the Davis Besse event indicated that the potentialinability to remove decay heat from the reactor core was due to the gostionable reliability of the EFWS caused by any or all of the following:
e loss of all F.FW due to common-mode failure of the pump discharge isolation valves to open f
e excessive delay in recovering EFW because of a difik 4ty in restartir ; '.he pump steam-
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driven turt>ines once they tripped e interruption of EFW flow becauw of failures in steamline break and feedline break accident mitigation features In 9ddition, the investigation of the event indicated that (1) a two train system with a steam turbine driven EFW pump may not be able to achieve the desired level of reliability and (2) the provision to automatically isolate EFW from a SG affected by a main steamline or feedwater line break may tend to increase the risk that adequate DHR is not available, rather than to decrease it.
in Section 1.g,4 of the SSAR, Westinghouse states that this issue is not applicable to the AP600 design because the design does not have a safety related auxiliary feedwater system. The passive core cooling system is stated to provide the safety related function of cooling the RCS in the event of loss of feedwater to the SGs. The startup feedwater system (SFS), which has no safety related function beyond containment isolation, provides the SGs Mh foodwater during plant conditions of startup, hot standby, cooldown, and when the main :vedwater pumps are unavailable.
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This issue required the use of a plant PRA to demonstrate the reliability of the auxiliary feedwater I
system (AFS), or EFW syy.em, to have a minimum reliability of 1.0E 4 unavailability / demand to
.' ensure its reliability / availability. Westinghouse contended that this issue is not applicable to the AP600 design because the design does not have a safety-related AFS and the passive core cooling system for the design provides the safety related function of cooling the RCS in the event L
ofloss of feedwater. The SFS has no safety-related function.
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l The staff in SECY.94 004, hmwover, has established a prooses of regulatory treatment of nork safety systems (RTNSS) for identifying risk signincent non CMM active systems for regulatory treatment. Thorofore, the SFS reliability remains an open issue as it will be subject to i
this RTNSS evaluation. This is Open Nom 20.319 (660.20F).
l The resolution of Essue 124 for the AP600 design w611 be addressed after the staff completes its review of the reliability of the SFS.
Therefore, lowse 11'4 luot resolved for the AP600 design.
SSO.21F: lota N.E.1.3:
Update Standard Review Plan and Devolepment of Regulatory Guide As discussed in NUREG-0933, issue ll.E.1.3 addressed improving the reliability of the auxiliary feedwater system or the emergency feedwater system (EFWS). Section 10.4 of the SRP was to-be updated, and RG 1.26 was to be revised to include these systems and possibly endorse certain standards. The SRP section was updated in July 1981; however, no additional public and occupational risk reduction was identified to support the need to revise the regulatory guide and it was not revised. This issue is resolved and the requirements were established in the changes to the SRP.
in Section 1.9.3 of the 88AR, Westinghouse stated that this issues was a requiremer:. to update Section 10.4.g of the Standard Review Plan to address the requireerds of item II.E.1.1 and ll.F.1.2 for auxiliary feedwater systems. Westinghouse also stated tit Star %rd Review Plan 10.4.0 was revised and this issue is classified as resolved. Ahhough the resolution of this issue was for NRC to update the SRP section, the application of the SRP section to a specific plant design is relevant to the AP600 design because NUREG-0933 stated, for issue ll.E.1.3, that the resolution of the issue resulted in new requirements and the requirements apply to all PWRs, including the AP600 design. Therefore, the staff does not agree with this conclusion and requests that Westinghouse discuss how the AP600 designs meet 6 the SRP and RG 1.26 for the EFWS. This was designated as open item 20.412 in the DSER and is still unresolved. This is open item 650.21F.
Therefore, Issue ll.E.1.3 is not resolved for the AP600 design.
480.22F: lasue lit.D.3.4: Control Room Habitability
- As discussed in NUREG-0933, lasue Ill.D.3.4 addmssed upgrading the habitability of the control i
room for the operators. The requirements were given in NUREG 0737.
In Section 1.9.3 of the SSAR, item (2)(xxviii), Westinghouse states that normally a non safety-related heating, ventilation, and air conditioning (HVAC' system keeps the AP600 main control room slightly pressurized to prevent infiltration of air from other plant areas. During accident :
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oonditions, a safety-related isolation of the main control room is automatically actuated. Upon the loss of non-safety related ac power, the main control room environment is sufficient to protect the operators and support the markmachine interfaces necessary to establish and maintain safe.
shutdown conditions for the plant following postulated design basis accident conditions.
The main control room is stated to be sealed with safety related connections to a safety-related compressed air breathing source, This compressed air system provides continued I
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j pressurisation and a source of fresh air for operator habitability. The air supply is sized to last for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an sooident. The unsNe nonc".:Fiited normal HVAC system will be operational h% the installed compressed air supply is exhausted.
l it is further stated that the non saf. Fiited HVAC system, equipped with a refrigeration-type air conditianing unN and powered from the onsNe diesel generetors, normally provides mein control room oooling. If the normal HVAC system is not available, outside air is not allowed into the l
main control room, and the safety related compressed air storego system is actuated.
in the DSER, the staff requested Westinghouse to address the possibility of toxic gases and substances onsite and offsite effecting control room habitability; the signals, or procedures and 9
operstor action, for actuation of equipment for control room habitability, and the responsibility of the COL applicant. In addition, the staff requested that Westinghouse discuss the potential exposure of operators to radiation brought into the control room after the compressed air supply l
is exhausted, the filtration provided by tha HVAC, and dose limits. This was designated as Open i
i item 20.4 33. Open hem 20.4 33 (650.22F)is still' unresolved because (1) the staff has l
determined that the AP600 design does not meet the dose limits of GDC is and (2) l Westinghouse needs to add a sentence in Section 6.4 of the SSAR. The sentence should state that the COL applicant referencing the AP600 design is responsible for (1) the amount and location of possible sources of toxic chemicals in or near the plant, (2) provision for selsmic Category 1, Class 1E toxic gas monitoring, and (3) evaluating the conformance of the onsite and offsite toxic releases with the guidelines of RGs 1.78 and 1.g5 in order to meet the TMl Action Plan tiem Ill.D.3.4 and GDC is requirements (see COL Action item 6.4-1).
r Therefore, lasue Ill.D.3.4 is not resolved for the AP600 design.
. 480.23F:
BL40 24, Prevention of damage due to water leakage inside containment Westinghouse stated that this bulletin is addressed in Section 3.4.1.2.2.t of the SSAR.
However, Westinghouse has not provided sufficient information in Section 3.4.1 of the 6SAR for the staff to malte a determination about the applicability of this bulletin to the AP600 design. For example, the definition of an 'open system"in Section 3.4.1 of the SSAR is different than the definition in the bulletin. This is open item 650.23F.
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Therefore, this bulletin is not resolved for the AP600 design.
SSO.24F:
BL4443, Refueling cavity water seal in Revision 1 of WCAF%1355g, Westinghouse stated that this bulletin was not appl; cable to the AP600 design because the design does not use this type of seal; however, the bulletin request licensees to address the probability and consequences of failure of these seals. In the DSER, the staff requested that Westinghouse address these aspects of the bulletin. This was dettinted as open item 20.712. Westinghouse has not addressed this issue and therefore, Open item 20.712 (650.24F) is still open.
Therefore, this bulletin is not resolved for the AP600 design.
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GL40409, Low Level Radioactive Waste Disposal i
i This genedc letter conoemed the requirements for solid waste shipments from a plant, i
Westinghouse stated that this genedc letter is addressed in Section 11.4 of the SSAR.
The staff has reviewed SSAR Section 11.4 and has not found GL-8Hg being addressed.
Westinghouse is requested to be specific in addressing this genede letter for the AP600 design.
This is Open Nem 650.25F.
i Therefore, this genede letter is not resolved for the AP600 design.
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680.26F:
GL4149, NRC volume reduction policy This generic letter provided a copy of the Commission policy statement on reduction of low-level radioactive wastes at plant sites. Westirghouse stated that this generic letter is addressed in Section 11.4 of the SSAR.
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The staff reviewed SSAR Section 11.4 and found that GL-8139 was not addressed.
Westinghouse is requested to be specific in addressing this generic letter for the AP600 design.-
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This is Open item 650.26F.
e Therefore, this generic letter is not resolved for the AP600 design.
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680.27F:
GL4412, Compliance with 10 CFR Part 41 and implementation of radiological effluent TS, attendant process control program Westinghouse stated that this gener:c letter is addressed in SSAR Chapter 16, on plant TSs, and i
Section 5.7. By adoption of the improved Westinghouse STS, Westinghouse should adequately address the TS issues in this generic letter. The TS for the AP600 design are in SSAR Chapter 16 and discussed in Chapter 16 of this report.
The staff has reviewed SSAR Chapter 16, Section 5.7 and found that GL-84-12 was not adiossed. Westinghouse is requested to be specific in addressing this generic letter for the AP600 design. This is Open item 650.27F.
Therefore, this generic letter is not resolved for the AP600 design.
i 450.28F:
GL4814, Instrument air supply system problems affecting safety related equipment I
Westinghouse stated that this generic letter is addressed in Section g.3.1 of the SSAR. Ses Open item 20.3-4 (650.17F) of issue 43 in this enclosure.-
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Therefore, this generic letter is not resolved for the AP600 design. This is open item 650.28F.
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- 880.29F:l. GL4913, Service water system problems affectin:;.afety-related systems i
This generic letter requested information about compliance of service water systems with certain
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GDC and quality assurance requirements, as test conieon. Westinghouse stated that this generic letter is addressed in Section 16.2 of the SSAR on plant TSs. This response does not appear to p
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i address the issues raised on the ODC and quality assurance requirements in the generic letter.
j This is Open hem 20.7 44 (650.2pF).
i Thorofore, this generic letter is not resolved for the AP600 design.
Note: FSER Open items 650.34F through 680.34F discuss COL action items. M is not clear to the staff how Westinghouse will treat the Bulletins and Generlo Letters that are l
I the responsibility of the Combined Lloonee applicant as discussed in a previous FSER open item (480.14F).
480.30F BL40-10, Contamination of nonrediomotive system and resulting potential for unmonitored, uncontrolled release to environment j
The staff noted in the DSER that the issues in this bulletin would be consi6'od during staff reviews of SecSon 6.2 and 11.5 of the SSAR. However, the issues in this bulletin were considered during the staff review of Sections 3.2.g and 9.3.5.
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In Section p.3.5 of the SSAR, Westinghouse states that there are no permanent connections between the WRS and non-radioactive piping. However, provisions are included for temporary i
diversion of contaminated water from normally nonradioactive drains to the WLS. Therefore, the WRS is designed to prevent the inadvertent transfer of contaminated fluids to a non contaminated drainage system for disposal.
d In Revision 1 of WCA*813559, Westinghouse stated that this bulletin was not applicable to the AP600 design and was the responsibility of the COL applicant.
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The event at Brunswick Nuclear Facility was caused by the use of a 16mporary heating hose which resulted in contamination of a nonradioactive system and an unmonitored, uncontrolled release of radioactivity to the environment. Based on the above, the staff does not believe that such an event is caused by poor system design but because of poor system operation and maintenance programs. Therefore, the staff agrees with Westinghouse that the COL applicant should address this event in its plant operating and mair.tenance procedures. This is COL Action item 20.7-??.
Therefore, this bulletin is not resolved for the AP600 design.
660.31F:
BL-96 02, Movement of heavy loads over spent fuel, over fuel in the reactor r
core, or ove. safety related equipment l~
This bulletin reminded licensees of their responsibilities for ensuring that activities involving the movement of heavy loads are performed safely, it eko requested that licensees review their plans and capabilities for handling heavy loads and assure that their load handling operations are in accordance with existing regulatory guidelines and the licensing basis.
in Revision 1 of WCAP-13559, Westinghouse stated that this issue is addressed by the y
resolution of USl A36 in Section 1.g.4.2.2 of the SSAR. Also, see Generic Letter 85-11, J
in Section 1.g 4 of the SSAR, Westinghouse states that the AP600 design conforms to NUREG-0612 and Section p.1.5 of the SRP.
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1 10 The staff has determined that ensuring the safe movement of heavy loads is the responsibility of the COL applicant. This is COL Action Nom 20.7 ??.
L Therefore, this bulletin is not resolved for the AP60') design.
480.32F; GL40477, Refueling waterlevel l
This generic letter requested TS and procedures to assure that exposure of fuel assemblies and control rods can not occur during transfer while refueling. DSER Open item 20.7 24 requested Westinghouse to address procedures concoming exposure of fuel assemblies and control rods during refueling. In Revision 1 of WCAP 1855g, Westinghouse stated that this generic letter is not applicable to the AP600 design and was the responsibility of the CSL applicant. See 1
Sections 13.5.1 and 13.5 2 of th6, SSAR. The staff agrees with Westinghouse that this issue is the responsibility of the COL applicant. Therefore, open item 20.7 24 is closed and the COL d
applicant responsibilltv is identified as COL Action Hem 20.7 ??.
Therefore, this generic letter is not resolved for the AP600 design.
680.33F:
GL41-38, Storage of low level radioactive wastes at power remotor sites DSER Open item 20.7 27 requested that Westinghouse address onsite storage space as part of its description of the redweste system.
4 This generic letter provided guidelines for the storage of low level radioactive wastes at plant i
sites. Westinghouse stated that this generic leMer was not applicable to the AP600 because it is the responsibility of the COL applicant. This is a site specific issue because it will depend upon the available offshe storage space for low level radioactive weste from the plant. This wil! be identified by the COL applicant if H proposes an onsite low-level radioactive waste storage facility to the NRC. The NRC would then evaluate the proposed facility against the criteria in GL-8138.
Therefore, Open item 20.7 27 is closed and the staff has determirsed that this is COL Action item 20.7-4.
Therefore, this generic letter is not resolved for the AP600 design.
650.34F:
GL45-13 Transmittal of NUREG 1154 regarding the Davis Besse loss of main and auxiliary feedwater event DSER Open item 20.7 34 requested Westinghouse to address NUREG 1154 and protection in the AP600 against the Davis Besse event. In Revision 1 of WCAP 13559, Westinghouse stated that this issue is addressed in Sections 10.4.7.1 and 6.3.3.2 of the SSAR.
The cause of the loss of main and auxiliary feedwater event on June g,1985 at Davis-Besse plant was (1) the licensee's lack of attention to detailin the care of plant equipment; (2) the licensee's failure to find anu Vroct root causes of problems because they poorty performed troubleshooting, maintenance and testing of equipment, and they poorty evaluated operating experience related to equipment; and (4) the licensee's ineffective or not utilized engineering
~ design and analysis effort to address equipment problems. Based on the above items, the staff does not believe that such an event is caused by poor system design but because of a poor Lsystem maintenance prog,am. Therefore, Open hem 20.7 34 is closed and the staff has
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. determined that the COL applicant should address this event in Hs plant procedures for operating and maintenance for the main and startup feedwater systems. This is COL Action item 20.7 ??.
Therefore, this generic letter is not resolved for to AP600 design.
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