ML20199F276

Forwards RAI Re Open Items on AP600.NRC Has Not Completed Review of W Request That Portions of Info Submitted in June 1992 Application for Design Certification Be Exempt from Mandatory Public Disclosure

ML20199F276
Person / Time
Site:	05200003
Issue date:	12/15/1997
From:	Kenyon T NRC (Affiliation Not Assigned)
To:	Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
NUDOCS 9802030117
Download: ML20199F276 (10)

Text

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. December 15, 1997 I

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:

REQUEST FOR ADDITIONAL INFORMATION RN.ATED TO OPEN ITEMS ON THE AP600 As a result of its review of the June 1992 application for design certification of the AP600, the staff has prepared the final safety evaluation report (FSER) on Section 13.6 of the AP600 Standard Safety Analysis Report (SSAR), Revision 17, the AP600 Security Design Report, Revision 4, and the AP600 Security Design Vulnerability Analysis Report, Revision 1. The FSER identifies 22 open items needing resolution by Westinghouse before the staff can complete its review of this SSAR section. The open items are identified in the enclosure with the tracking numbers associated with them.

You have requested that portions of the information submitted in the June 1992 apr'ication for design certification be exempt from mandatory public disciocure. While the staff has not completed its review of your request in accordance with the requiremants of 10 CFR 2.790, that port'on of the submitted information is being withheld from public disclosure pending the staffs final detem11 nation. The staff concludes that the enclosure does not contain those portions of the information for which exemption is sought. However, the staff will withhold this letter from public disclosure for 30 calendar days from the date of this letter to allow 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 disclohre in accordance with 10 CFR 2.790, this letter will be placed in the NRC's Public Document Room. T If you have any questions regarding this matter, you can contact me at (301) 415-1120.

(

Sincerely, original signed by: i Thomas J. Kenyon, Project Manager J Standardization Project Directorate Division of Reacto: Program Management Office of Nuclear Reactor Regulation Docket No. 52 003

Enclosure:

As stated s

cc w/ encl: See next page 50 M R ET.d CDPV DISTRIBUTION:

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DOCUM'NT NAME: A:SFE-GRD.RAI To rcceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment /enclopure "N" = No cyo OFFICE PM:PQW)ORPM D:PDST:pBRM -l l l TJKenyS:sg TRQuayL\Mi NAME DATE 12/n /97' 1216/97 \ P 9002030117 971215 OFFICIAL RECORD COPY PDR ADOCK 05200003 A .

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' DISTkfBUTION: Letter to Mr. Nicholas J. Lloarulo. Dated: December 15, 1997

, . Docket File

• Enclosure to be held for 30 days

• PUBLIC PDST R/F TQuay TKenyon WHuffman JSebrosky DScaletti

- JNWilson ACRS (ii)

WDean,0 5 E23 JMoore,015 B18 MPSelmen,015 B18 RAlbert,0-11 E22 1

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• Mr. Nicholas J. 'Jparuto Docket No.52-003 Westinghouse Electric Corporation AP600 cc: Mr. B. A. McIntyre Ms. Cindy L. Haag Advanced Plant Safety & Licensing Advanced Plant Safety & Licensing Westinghouse Electric Corporation Westinghouse Electric Corporation Energy Systems Business Unit Energy Systems Business Unit 1 P.O. Box 355 Box 355 Pittsburgh, PA 15230 Pittsburgh, PA 15230

}

Enclosure to be distr!buted to the following addressees after the result of the propiietary evaluation is .

received from Westinghouse g

Mr. Russ Bell Ms. Lynn Connor x

} Senior Project Manage., Programs DOC-Search Associates Nuclear Energy Institute Post Office Box 34 1776 i Street, NW Cabin John, MD 20818 Suite 300 Washington, DC 20006 3706 Mr. Robert H. Buchholz GE Nuclear D:ergy Dr. Craig D. Sawyer, Manager 175 Curtner Avenue, MC-781 Advanced Reactor Programs San Jose, CA 95125

[ GE Nuclear Energy L 175 Curtner Avenue, MC 754 Mr. Sterling Franks San Jose, LA 95125 U.S. Department of Energy NE-50 Barton Z. Cowan, Esq. 19901 Germantown Road Eckert S?amans Cherin & Mellott Germantown, MD 20874 600 Grant Street 42nd Floor Pittsburgh, PA 15219 Mr. Charles Thompson, Nuclear Engineer AP600 Certification M: Frsrik A. Ross NE 50 U.S. Department of Energy, NE-42 19901 Germantown Road Office of LWR Safety and Technology Girmantown, MD 20874 x 19901 Germantown Road

1. Germantown, MD 20874 Mr. Robert Ma!ers, P.E

- Pennsylva7ia Department of Mr. Ed Rodwell, Manager Environmental Protection PWR Design Certificat;on Bun au of Radiation Protection Electric Power Research Institute Rah Carson State Office Building

,, 3412 Hillview Avertue P.O. Box G469 Palo Alto, CA 94303 Harrisburg, PA 17105-8469 E-

4 OPEN ITEMS ON SSAR SECTION 13.6 920.6F Section 13.6 of the SSAR is titled " industrial Security." Industrial Security is a misnomer that does not accurately denote the level of protection required at a nuclear facility. The title " Nuclear Security" is preferred and has evolved as the industry standard. The staff recommends that Section 13.6 be revised ,

accordingly.

920.7F in Section 1.0, " Introduction," of the Secarity Design Report (SDR), second paragraph, a range of wall thickness is describ-d. The lower range is consistent with specificai!ons listed under security hardened walls, but the higher range exceeds it. It is not clear to the staff if any calculations were based on the higher range. If the higher range were needed to achieve the desired blast results, then Westingt.ouse needs to revise the AP600 minimum standard for hardened walls.

Address this concem.

920.8F in Section 1.2, " Security Portal," of the SDR, the full spectrum of alarms for doors,-

hatches, and tumstiles is act clear to the staff. The SDR reflects one type .of .

alarm, but is silent on others. Revise the SDR to reflect all alarm types.

- In addition, in Section 13.6.7.2 of the SSAR, Westinghouse states that an intrusion detection system is u*ilized to notify the security organization of any unauthorized attempt to gain access into the protected area. Doors entering a protected tri.a are equipped with an alarm to detect tampering and unauthorized access into the protected area. It is not clear that this statement demonstrates that the requirements of 10 CFR 73.55(e)(2) and (3) are satisfied by the design.

Address this issue in both the SSAR and the 80R.

t 920.9F .in Section 4.2, " Controlled Access Areas," of the SDR, the title " Controlled Access Areas" contradicts the text and is not consistent with the definition specified in 10 CFR 73.2. Because contro',, access areas and vital areas are regulated differently, revise the title of ti = section for consistency.

920.10F in maction 4.3," Protected Area Enclosures," of the SDR, the phrase "provided with CCTV capability" is misleading. It is not clear to the staff if it means that CCTV shall be installed or that the capability to install CCTV will exist. Revise this section and other sect:ons with the referenced phrase to reflect that CCTV shall be installed.

920.11F in Section 4.3.1, " Primary Access Point," of the SDR, the phrasa "can be monitored" relative to CCTV is misleading. It is not clear to the staff t'it means that CCTV shall be monitored by the secunty organization or that they merely may be monitored. Revise this section to reflect that CCTV shall be monitored as appropriate.

920.12F Section 4.3.3," Containment Access," of the SDR is misiending. It reads as though scarches and positive identification can be performed by a member of Enclosure l

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2-the security organization or by control equipment independent of security personnel. Revise this section to reflect a security presence, even if access control equipment is usod.

920.13F in Section 4.4, "Alarrs Stations," of the SDR, the UL-752 rating (High Power Rifle Rating) needs to include a level 4 round (220 grein soft point with a muzzle velocity of 2,410 feet per second and a muzzle energy of 2,830 foot pounds)in the bullet-resisting criteria. Revise this section and any other section pertaining to bullet-resisting criteria to refioct a level 4 round.

920.14F in Section 4.5.2," Protected Area and Protected Area Enclosure Barriers," of the SDR, the use oi"typictt!!y" to describe a minimum standaid is unacceptable.

Replace " typically"in this section and all other sections whers it is used with r-ore appropriate language.

020.15F In Section 4.5.3, " Vital Area and PA/VA Barriers," of the SDR and Section 13.6.5.2 of the SSAR, the staff takes exception to the definition of "amsible" and requires expansion of the definition of'unmonitored." The issue conceming the definition of accessible was raised in writing to Westinghouse and also discussed with them during a meeting on May 13,1997. Westiaghouse has not given a rationale for its definition of accessible. Relative to 18 feet, the Commisson has give,) the industry guidance on this height pertain!ng to protected area barriers and protected area lighting. The guidance is as follows:

• For buildings and walls which constitute part of the protected crea barrier, ,

an acceptable security plan would typk. ally affirm that the buikiings and walls have non-scalable facades,18 feet or more in haight. Such buildings and walls need not be protected by a top quarc.

• An acceptable securi9 plan would typically affirm to maintain i!!umination of the tops and sides of all accessible structures. Note: A structure should be considered "accescible"if it is less than 18 feet in height or has a ready mans of access to the roo!, such as ladders, stairs, climbing bars, etc.

Since the accessible definiticn likely impacts vital-area openings, Westinghouse needs to ensure that such openings, even those above 18 feet, satisfy the requirements of 10 CFR 75.55(d)(7)(1)(D).

Westinghouse's definition of unmonitored in Section 13.6.5.2 of the SSAR does not include the monitoring capabilities oithe alarm stations via closed circuit television (CCTV), as describcd in the SDR. Westinghouse needs to revise this section to reflect C,CTV capabilities.

Address these concems and revise the SDR and SSAR accordingly.

920.16F Section 5.2," Intrusion Detection and Surveillance System," of the SDR does not adequately address the requirement to check periodically all exterior creas within the protected area, as specified in 10 CFR 73.55(c)(4). Review the requiremer.ts and revise the SDR accordingly.

3, 920.17F in the section "AP600 Security Force Armed Response Team" of the Security Design Vulnerabitity Analysis Report (SDVAR), the contingency equipment listed did not include a protective mask, which is necessary to protect against one aspect of the design basis threat. Relative to the protective strategy, the duties and responsibilities of all responders are not clearly delineated. Review thess areas and revise the BDVAR accordingly.

920.18F in Section 13.6.1 of the S3AR, Westinghouse states that the objectives and functional requiremonts of the AP600 physir,al protection system and the i description of security features are provided in the submitted AP600 SDR, submitted under separate cover in accordance with 10 CFR 2.790(d). The report includes the security boundary drawings and a listing of vital equipraent and components. The vulnerability analysis, which demonstrates that the AP600 certified security design adeq ;ately protects the AP600 from radiological sabotage, is included in the report.

Westinghouse further states that the AP600 security design features a reduced protected area that does not require a perimeter fence such as found in current plant security plans. This results in a reduced requirement for security staffing.

Personnel screening, selection, performanc.e evaluation, and training aspects of the physical security program will be addressed by the Combined License (COL) epplicant ,

The staff concludes that Westinghouse did not support its rationale for reduced ,

staffing. It is not clear if Westinghouse's claim of reduced security staffing is being attributed to a reduced protected area or other factors. Clarify your rationale for reduced security staffing.

920.19F The staff requires that, at least 60 days before loading fuel, a COL applicant will confirm that security systems and programs described in its physical security plan, safeguards contingency plan, and training and qualification plan have achieved operational status and are available for the staff's inspection. Operational status meant, that the security systems and programs are functioning in their entirety, as they will when the reactor is operating, and will continue to do so. The COL applicant's determination that cperational status has been achieved must be based on tests conducted under realistic operating conditions of sufficient duration to demonstrate that:

a. the equipment is properly operating and capable of long-term, reliable operation-b, proceduret 2.3 been c'eveloped, approved, and implemented; and

c. personnel responsible for security operations and maintenance have been appropriately trained and have demonstrated their capability to perform their assigned duties and responsibilities This informrtion should be included in the SSAR as a COL Action item.

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020.20F In Section 13.6.3.1 of the SSAR, Wettinghouse states that a physical protection system and security organization is provided to protect the AP600 from '

radiological sabotage, as required by 10 CFR 73.55, and that, to achieve this objective, the physicel protection system;

a. includes a security c ganization; =

b. locates vital equipment within vital areas; c, controls points of personnel. vehicle, and material access into the a protected and vital areas;

d. annunciates alarms in a continuously manned central alarm station ano at least one other continuously manned alarm station that is physically separated from the central alarm station; e, provides for continuous communications br r. -n the security officers and the continuously manned alarm stations;

f. provides for testing and maintenance of the alarms, communications, and .

physical barriers; and

g. responds to threats of radiological sabotage in accordance with a developed contingency plan.

The staff agrees that the SDR and SDVAR submitted by Westinghouse satisfy all but one of the stated regulatory requirements. The staff does not agree that the SDR or SDVAc is relevant to g because a contingency plan will be developed by (

the COL licensee. Even though Westinghouse did not develop a contingency plan, the reference in quest!on infers that it did. Revise the SSAR to clarify that a contingency plan will be developed by a COL licensee.

920.21F in the SDVAR, Westinghouse states that the AP600 design is less vulnerable to issues associated with the requirements of 10 CFR Part 26, " Fitness for Duty Progrcms," and did not provide any guidance on implementation of 10 CFR Part 26 relative to the AP600 design. To satisfy NRC Generic Letter 91-16, Westinghouse should include a COL Action item in the SSAR to require each COL applicant to describe in its physical security plan how the requirements of 10 CFR Part 26 will be met.

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• e 5-920.22F in Section 13.6.3.2 of the SSAR, Westinghouse states that the physical protection system protects against radiological sabotage events, following the requirements of 10 CFR 73.55(a) and the following assumptions:

a. The insider tareat is based on one knowledgeable individual without armament or explosives,

b. The intrusion detection systems cannot be di.?abled without detection and timely response by the security force.

c. Unless precluded by plant design features or prevented by the plant security system, insider s'abotage can potentially result in an initiating event requiring actuation of safe shutdown systems, disabling of safe shutdown systems, disabling of nonsafety-related systems (including offsite power), or any combiration of these,

d. In evaluating vulnerability to intemal sabotage, onsite security system features, effsite resources or both are effective in preventing ur. detected penetration into the protected area by outsiders,

e. While access to cont tinment for maintenance and testing during operation at poweris permitted, such access is controlled and typically nonroutine.

Therefore, if secuity systems are provided to pro +ect and control conta:nment access, equipment inside the containment is inaccessible to a saboteur during operation of the plant.

f. The continuous presence of severd employees precludes acts of sadage in the control room. However, the control room is a vital area and will be prntacted in accordancu with 10 CFR 73.55.

g. Equipment and systems designated as vital for full power operation shall be maintained as vitalin other modes of plant operation. However, during unit shutdown, a vital area can be declassified to nonvitalif app oved by the security plan.

h. Sabotage events do not occur coincident with some other independent single failure or independently initiated event.

1. The security restrictions for access to equipment and plant regions will be compatible with loss of site power, access requirements, fire protection, health phys:es, and local operator actions required for event mitigation.

During operat:ng modes, security access control restrictions will not excessively impede operator functions.

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6-The staff has concems with assumptions a, e, and f, as discussed below:

Assumption a: Relative to the insider threat,10 CFR 73.1(a)(1) states, in part, that an insider includes an employee in any position. Sincs an amled responder is an employee, the assumption is that an insider could possess armaments. This issue was raised in writing to Westinghouse and discussed with them during a meeting on May 13,1997. Section 2.2, " Insider," of the SDR was subsequently revised to reflect that an insider is assumed not to be armed, even if he or she }

were a member of the security organization armed response team. Westinghouse did not provide a basis for this conclusion. Address this concem in the SSAR, the SDR, and the section, " Insider Threat," of the SDVAR.

Assumption e: Westinghouse stato that equipment inside containment is inaccessible to a saboteur during operation of the plant. However, neither the SDR nor the SDVAR Di ves a basis for this conclusion. Address this concem.

Assumption f: It is not clear to the staff how the continuous presence of several employees in the control room can preclude acts of sabotage. Neither the SDR nor the SDVAR gives a basis for this conclusion. This conclusion needs to be validated. Address this concem.

920.23F in Section 13.6.3.2 of the SSAR, Westinghouse states that the AP600 plant ecurity system conforms to the applicable portions of ANS 3.3-1988, "Secunty for Nuclear Power Plants." But the submitted documents do not reflect when adherence to ANS 3.3 takes place. Since the NRC did not endorse the ANS standard, Westinghouse neerte to revise the SDR and the SDVAR to indicate where ANS 3.3 was applied.

920.24F Westinghouse should include a COL Action item in the SSAR to require each COL applicant to address in its safeguards plans how the physical protection system will provide the protection assumed in items a, b, d, and e of Section 13.6.3.2 of the SSAR.

920.25F The SDR references the security organization and states that manning levels are contained in the SDVAR. However, the SDVAR only details minimum manning requirements for the alarm stations and response team. Neither document addresses the individual with the authority to direct physical protection aci /ities, as required and described in 10 CFR 73.55(b)(2). Address this matter.

920.26F in Section 13.6.5.1 of the SSAR, Westinghouse states that where there are portals for personnel or material access into the vital arees, " protected area enclosures" surround the portals with a protected area barrier. The protected area barriers provide an outer boundary to prevent unauthorized access to the vital areas of the plant without detection. The protected area barriers are constructed, as a minimum, of chain , ink fence equivalent to the physical barrier defined in 10 CFR 73.2 for fences. The protectea area barriers are constructed so that any attempt to penetrate into the protected areas will activate counter measures in response to the threat. The protected areas havt intrusicn detection equipment and aiarms that annunciate upon detection of penetration of the encbsure to alert security response forces that the enclosure has been breached.

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~7-The drawings identifying the protected areas are provided in the AP600 SDR.

Except for assessment capabilities, the staff agrees that the measures ir. this section satisfy regulatory re:luirements. Even though assessment capab!!ities are described in the SDR, Westinghouse did not incorponste them, ytiere applicable, into this section. Revise this section to reflect assessment capabilities.

g20.27F in Section 13.6.7.1 of the SSAR, Westinghouse states that because of the security features designed into the AP600, " intrusion detection at the perimeter of the plant is not required. With the exception of the special provisions provided for the Shield Building, the staff agrees. Revise the SSAR to c!arify this statement.

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