ML20202E687
| ML20202E687 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 11/26/1997 |
| From: | Huffman W NRC (Affiliation Not Assigned) |
| To: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 9712080120 | |
| Download: ML20202E687 (11) | |
Text
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NtMrter 26,1997
.Mr.- Nicholas J. Liparulo, Manager Nuclear; Safety: and Regulatory Anal / sis Nuclear and Advanced Technology Division Westinghouse Electric Corporation
-P.O. Box-35d 4,4 Pittsburgh, PA 15230
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hUBJECT:,OPEN ITEMS ASSOCIATED WITH SAFETY EVALUATION REPORTS (SERs) ON AP600
, TECHNICAL SPECIFICATIONS (TSs)
DearfMr. Liparulo:
The U.S. Nuclear Regulatory Commission (NRC) Standardization Project Director-i; ate has received SER inputs from the Instrumentation and Controls Branch, t'
Emergency Preparedness and Radiation Protection Branch, and a partial SER'
';. submittal from the Containment _ Systems and_ Severe Accident Branch on the AP600 '
_TSs.
These_ input have open items which have been extracted and designated as an FSER.open-items in the enclosures to this letter.
-If you have any questions regarding this matter, you may contact me at (301)'415-1141 Sincerely, original signed by:
William C. Huffman, Project Manager Standardization Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003 k! g g pa g
g
Enclosures:
As stated cc w/ encl:
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PUBLIC DMatthews TQuay TKenyon WHuffman JSebrosky JNWilson DScaletti JMoore, 0-15 B18 WDean,-0-5 E6 ACRS (11)
CBerlinger, 0-8 H7 EThrom, 0-8 H7 JKudrick, 0-8 H7 JWermiel, 0-8 i
HLi, 0-8 H3 MGareri, 0-8 H3 REmch, 0-10 D4 SNewberry 0-8 E2 CHinson, 3-10 D4 MReinhart, 0-13 H15 CMiller, 0-10 D4
=AChu,l0-13 H15' WBeckner, 0-13 H15
-DOCUMENT NAME: A:TS-1-01.SER' -
. To seceive a copy of tide doeurnent, andcate in the bou' "C" = Copy wMhout attachment / enclosure
- E* a Copy with attachment / enclosure
- N* = No copy OfflCE PM:PDST:DRPM BC:TSB:ADPR D:PDST:DRPM NAME' WCHuffman:(sY/ts7(WBeckner' TRQuayiTA DATE<
11Q5/97 llM/97 11/8/97 97120e0120 971126
^cFICIAL RECORD COPY
- See previous concurrence.
'PDR ADOCK 05200003 E
PDR s
Mr. Nicholas J. Liparulo Docket No.52-003 Westinghouse Electric Corporation AP600 cc:
Mr. B. A. McIntyre Mr. Russ Bell Advanced Plant Safety & Licensing Senior Project Manager, Programs Westinghouse Electric Corporation Nuclear Energy Institute Energy Systems Business Unit 1776 I Street, NW P.O. Box 355 Suite 300 Pittsburgh, PA 15230 Washington, DC 20006-3706 Ms. Cindy 6.
Haag Ms. Lynn Connor Advanced Plant Safet.. & 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 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 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 Palo Alto, CA 94303
SER OPEN ITEMS ASSOCIATED WITH AP600 FSER SECTION 6.2.5 HICB OPEN ITEM 420.126F The NRC Instrumentation and Controls Branch received a letter from Westinghouse dated November 5, 1997, (NSD-NRC-97-5415) which contained mark-ups related to the AP600 I&C technical specifica-tions (TS). These mark-ups should be incorporated into the next revision of the technical specifications.
In addition, the mark-ups did not completely address the inconsistent use of " channel" versus " channel / division," (e.g., ESFAS Condition "V" and Required Action "V.1").
Westinghouse should confirm that all cases of this inconsistency have been identified and corrected.
PERB OPEN ITEM 470.45F The Emergency Preparedness and Radiation Protection Branch has identified two places in Technical Specification 5.7 (High Radia-tion Area) where symbols associated with dose rate limits were omitted. A marked-up copy of Sectior. 5.7 with the missing symbols is provided in Enclosure 2.
Section 5.7 should be revised to incorporate these corrections.
SCSB OPEN ITEMS LC0 3.6.4 Containment Pressure 480.1088F The LCO 3.6.4 BASES provides only a reference to SSAR Section 6.2,
" Containment Analysis," and does not provide the results of the containment analyses. This is unacceptable and needs to be corrected following the staff's review and acceptance of the analyses methods.
A place holder with reference to the current SSAR revision number should be provided, for example (44.8 psig, SSAR Rev. 13]. This is considered to be an open item.
. LC0 3.6.5 Containment Air Temperature 480.1089F The following open item relates to LCO 3.6.5 BASES.
The APPLICA-BLE SAFETY ANALYSES Bases discussion deviates from the STS. The response to SCSB comment 32 (Ref. Westinghouse letter NSD-NRC-97-5263, " Response to NRC SCSB Comments on Containment Systems Technical Specification," from Brian. A. McIntyre (W) to T. R. Quay (NRC), dated August 19,1997) is only partially accept-able.
(i)
The identification of the limiting accident is not provided, it would be the DEG Hot Leg LOCA based on the i
staff's current understanding of the supporting analyses, SSAR Rev. 13. This is considered to be an open item.
(ii)
The results of the analyses are not provided, only a refer,
ence to SSAR Section 6.2, " Containment Analysis," is provided. This is unacceptable anineeds to be corrected following the staff's review and acceptance of the analyses -
methods. A place holder with reference to the current SSAR revision number should be provided, for example (390.3 'F for a DEG Hot Leg LOCA, SSAR Rev. 13).
In addition, the containment design temperature, 280 *F, needs to be included. This is considered to be an open item.
(iii) The discussion with respect to the influence of the short durations when the calculated containment air temperature exceeds the design temperature must be included. The analyses to demonstrate that these short deviations are acceptable with respect h the containment design tempera-ture need to be performed and referenced.
This is consid-ered to be an open item.
3.6.6 Passive Containment Cooling System (PCS) - Operating 480.1090F For the development of an ACTION COMPLETION TIME or a SURVEILLANCE REQUIREMENTS FREQUENCY the staff believes that STS Containment Spray and Cooling Systems (Credit not taken for iocine removal by the Containment Spray System) LC0 3.6.68 is the appropriate basis.
The AP600 containment spray is not safety-related, therefore STS Containment Spray and Cooling Systems (Credit taken for iodine removal by the Containment Spray System) LOO 3.6.6A is not consid-ered to be an appropriate basis as referenced in Westinghouse's response to SCSB comments 34 and 44 (Ref. Westinghouse letter NSD-NRC-97-5263, " Response to NRC SCSB Comments on Containment Systems Technical Specification," from Brian A. McIntyre (H) to T. R. Quay (NRC), dated August 19,1997).
This is considered to be an open item.
480.1091F-The staff is concerned about blockage of the upper annulus drains (due to such possible failure modes as debris accumulation, animal
l habitation obstructions, freezing, or other unidentified /
unanticipated mechanisms) rendering the passive containment cooling system (PCS) inoperable. Westinghouse's response to SCSB comment 36(g) (Ref. Westinghouse letter NSD-NRC-97-5263, " Response to NRC SCSB Comments on Containment Systems Technical Specifica-tion," from Brian. A. McIntyre (W) to T. R. Quay (NRC), dated August 19,1997) is only partially acceptable to the extent that the upper annulus drains are at least mentioned in the BACKGROUND section. The PRA results which illustrate that the AP600 is consistent with the Commission's safety goals is based on a stated surveillance interval of 7 days (weekly) to verify that the upper annulus drains are not obstructed to preclude blockage of the air flow path. Therefore, this requirement should be incorporated into LCO 3.6.6.
Westinghouse needs to develop conditions, actions, completion times and surveillances for upper annulus drains. A revised surveillance interval would be acceptable if, when factored into the PRA, does not alter the perceived safety of the PCS design. This is considered to be an open item.
480.1092F The COMPLETION TIME of LCO 3.6.6, ACTION C.2, deviates from STS ECCS LC0 3.5.2 Action C and STS RWST LCO 3.5.4 Action C and is unacceptable. The required COMPLETION TIME for C.2 of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> to be in MODE 5 is unacceptable, it should be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This is consistent with STS ECCS LC0 3.5.2, STS RWST LCO 3.5.4 and STS Containment Spray and Cooling Systems (Credit not taken for iodine removal by the Containment Spray System) LC0 3.6.6B.
While 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> would be consistent with STS Containment Spray and Cooling Systems (Credit taken for iodine removal by the Containment Spray System) LC0 3.6.6A, the AP600 containment spray is not safety-related. This is considered to be an open item.
480.1093F The LC0 3.6.6 SURVLILLANCE and FREQUENCY of the PCS air flow path and baffles, SR 3.6.6.4, are consistent with STS Containment Spray and Cooling Systems (Credit not taken for iodire removal by the Containment Spray System) LC0 SR 3.6.6B.5 and on that basis are acceptable.
It is P.oted that in response to SCSB comment 44 (Ref.
Westinghouse letter NSD-NRC-97-5263, " Response to NRC SCSB Com-ments on Containment Systems Technical Specification," from Brian A. McIntyre (W) to T. R. Quay (NRC), dated August 19,1997),
Westinghouse references STS Containment Spray and Cooling Systems (Credit taken for iodine removal by the Containment Spray System)
LCO 3.6.6A.
The AP600 containment spray is not safety-related and therefore STS LC0 3.6.6B is deemed to the appropriate basis.
While there is no difference between SR 3.6.6B.5 and 3.6.6A.5, use of LC0 3.6.6A is considered to be unacceptable.
This is consid-ered to be an open item.
480.1094F The LCO 3.6.6 SURVEILLANCE FREQUENCY of verifying PCS flow and water coverage, SR 3.6.6.6, is unacceptable. The FREQUENCY needs to be consistent with STS Containment Spray and Cooling Systems (Credit not taken for iodine removal by the Containment Spray System) LC0 SR 3.6.68.8.
The mechanical alignment of the PCS 1
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. water distribution system.(bucket and weirs) needs to be main-i
- tained and it needs to be demonstrated that-the-PCS flow and water coverage are maintained consistent with the APPLICABLE SAFETY ANALYSIS. A SURVEILLANCE test at the first refueling outage
[24 months) needs.to be-added to tne 10 year. interval. This-is
- considered to be an open item.
480.1095F
- (a):
The LCO-3.6.6 BASES BACKGROUND needs additional descriptive I
information based on a review of STS Containment Spray and Cooling Systems (Credit not taken for iodine removal by the Cor.uinment Spray System) LCO SR 3.6.6B.
(1)
Augment the discussion.to include, as an exampia, "The PCS is designed to _ ensure that the heat removal capability required during the post accident period can be attained. The PCS. limits and maintains post accident conditions to less then the containment design values." This is considered to be an open item.
(ii)
Aegment the GDCs.with "10 CFR 50 Appendix A."
This is considered to be an open item.
(iii) Augment.the design details to include the recircula-tion pumps.
This is considered to be an open item.
(iv)
Augment the design details to include the recircula-tion heaters. This is considered to be an open item.
(v)
Augment the design details to include the ancillary water storage tank and additional suppoit systems.
This is considered to be an open item.
1 (vi)
Correct the typographical error in " INSERT Back-1 ground, fifth paragraph." This is considered to be an open item.
480.1096F The LCO 3.6.6 BASES description of the APPLICABLE SAFETY ANALYSES lacks specific details-and contains errors.
'(1)
The peak containment air temperature occurs during a DEG Hot Leg LOCA (Ref. SSAR Rev.13. Table 6.2.1.1-1), not the SLB as indicated. This is considered to be an open itein.
(ii)
As discussed in LCO 3.6.4 BASES 4(b)(ii) and in LCO 3.6.5 BASES 4(b)(1), 4(b)(ii) and-4(b)(iiO, the analyses results 4
need more specific details. This is cow,d. red to be an
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. 480.1097F The LCO 3.6.6 BASES description of the LC0 is unacceptable. - Both sections only discuss an OPERABLE flow path. There is no discus-sion of an OPERABLE PCCWST. This is considered to be an open item. Add, for example, based on LCO 3.5.4:
(1)
"The PCCWST ensures that an adequate supply of water is available to cool _ and depressurize the containment in the event of a Design Basis Accident (DBA)."
(ii)
"To be considered OPERABLE, the PCCWST must meet the water volume and temperature limits established in the SRs."
(iii)
"To be considered OPERABLE, the upper annulus drains must be unobstructed and provide a path for PCCWST water runoff to preclude blockage of the air low path." This is consid-ered to be an open item.
480.1098F The LC0 3.6.6 BASES description of the SURVEILLANCE REQUIREMENTS need to be modified.
(i)
For SR 3.6.6.1, a reference to the SUP3EILLANCE note is requires, for example, "The SR is modified by a Note that eliminates the requiremer t to perform this Surveillance when ambient air temperature are within the operating limits of the PCCWST. With ambient temperatures within the band, the PCCWST temperature should not exceed the limits."
(See also 3 SR 3.6.6.1.)
This is considered to be an open item.
(ii)
For SR 3.6.6.2, the text "through operating experience" needs to be removed. This is considered to be an open item.
(iii) SR 3.6.6.3 is partially consistent with 3.5.2 ECCS - Oper-ating SR 3.5.2.2.
The Surveillance frequency and its justification need to be included in the BASES.
This is considered to be an open item.
(iv)
SR 3.6.6.4 is partially consistent with 3.5.2 ECCS - Oper-ating SR 3.5.2.5 and SR 3.5.2.6.
The Surveiilance frequency and its justification need to be included in the BASES.
This is considered to be an open item.
(v)
SR 3.6.6.5 is partially consistent with 3.5.2 ECCS - Oper-ating SR 3.5.2.8.
While the SR is indeed prudent, the format is unacceptable. To be consistent with the STS the text should be revised to " Periodic inspections of the PCS air flow path from the hield building annulus inlet to the exit ensures that it i, unrestricted and ensures that it stays in proper operating condition by confirming proper placement of the baffle plates. The 24 month Frequency is based on the desire [need] to perform this Surveillance
9 under conditions that apply during a plant outage, on the need to have access to the locations, and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This Frequency has been found to be sufficient to detect abnormal degrada-tion in similar situations." This is considered to be an open item.
(vi)
SR 3.6.6.6 is partially consistent with STS Containment Spray and Cooling Systems (Credit not taken for iodine removal by the Containment Spray System) LC0 SR 3.6.6B.8.
However the passive nature of the PCS which relies on the mechanica' alignment of the PCS water distribution system (bucket and weirs) needs to be maintained and it needs to be demonstrated that the PCS flow and water cov6 age are maintained consistent with the APPLICABLE SAFETY ANALYSIS.
A SVRVEILLANCE test at the first refueling outage [24 months) needs to be added to the 10 year interval.
This is considered to be an open item.
(vii)
SR 3.6.6.7 needs to be added for the upper annulus drains, consistent with the alternative used to address 1 (iii).
This is considered to be an open item.
480.1099F The LC0 3.6.6 BASES REFERENCES should be corrected.
References ? and 3 are not used and need to be deleted.
Refer-ence 4 becomes reference 2 and the attendant text needs to be corrected.
This is considered to be an open item.
3.6.7 Passive Containment Cooling System (PCS) - Shutdown 480.1100F Similar to Open Item 440.1091F above, the Westinghouse response to SCSB comment 36(g) (Ref. Westinghouse letter NSD-NRC-97-5263,
" Response to NRC SCSB Comments on Containment Systems Technical Specification," from Brian. A. McIntyre (W) to T. R. Quay (NRC),
dated August 19,1997) is only partially acceptable to the extent that the upper annulus drains are at least mentioned in the BACKGROUND section. The PRA results which illustrate that the AP600 is consistent with the Commission's safety goals is based on a stated surveillance interval of 7 days (weekly) to verify that the upper annulus drains are not obstructed to preclude blockage of the air flow path. Therefore this require-ment must be incorporated into the technical specification. A revised surveillance interval would be acceptable if, when factored into the PRA, does not alter the perceived safety of the PCS design. Westinghouse will need to develop the appropri-ate LCO condition, required actions, and completions times to totally address this concern. This is considered to be an open item.
1
- 480.1101F (a)
LCO 3.6.7, ACTION C: CONDITION is unacceptable. ACTION C cannot be based on itself. The logic needs to be revised to be based an ACTION A and ACTION B.
This is considered to be an apen item.
(b)
LCO 3.6.7, ACTION C: REQUIRED ACTIONS C.l.1 and C.1.2 are unaccept able.
They should be rewritten to be fully con-sistent with the intent of the BASES ACTION C.1 (as cur-rent documented).
For example:
"C.l.1 If in MODE 5 with the PCS open and/or the pres-surizer level not visible, then close the RCS and/or re-store the pressurizer level to its visible range." This is considered to be an open item.
"C.I.2 If in MODE 6 with the upper internals in place and/or the refueling cavity less than full, then remove the upper internals and/or increase the refueling cavity level to full." This is considered to be an open item.
480.1102F LC0 3.6.7 BASES discussion on the LC0 is unacceptable. Both sections only discuss an OPERABLE flow path. There is no dis-cussion of an OPERABLE PCCWST. This is considered to be an open item. Add, for example, based on LC0 3.5.4:
(i)
"The PCCWST ensures that an adequate supply of water is available to cool and depressurize the containment in the event of a Design Basis Accident (DBA)."
(ii)
"To be considered OPERABLE, the PCCWST must meet the water volume and temperature limits established in the SRs."
In addition, in consideration of Open Item 1097F above, also add:
(iii) "To be considered OPERABLE, the upper annulus drains must be unobstructed and provide a path for PCCWST water runoff to preclude blockage of the air low path." This is con-sidered to be an open item.
480.1103F The LC0 3.6,7 BASES discussions on APPLICABILITY, ACTIONS, and SURVEILLANCE REQUIREMENTS are referenced to LCO 3.6.6 (PCS -
Operating) SRs 3.6.6.1 through 3.6.6.8.
Under the current version of LC0 3.6.6, there are only six SRs. The referenced number of SRs needs to be corrected. This is considered to be an open item.
ArrAcetoe High Radiation Area 5.7 l
l 5.0 ADMINISTRATIVE C041ROLS-
_5.7 High Radiation Area 5.7.1 Pursuant to 10 C7R 20, paragraph 20.1601(c), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is
> 100 Mren/hr but < 1000 mres/hr, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto
.j shall be controlled by requiring issuance of a Radiation Work Permit (RWP).
Individuals qualified in radiation protection procedures (e.g., (Health Physics Technicians]) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assioned duties in high radiation areas with exposure ratesF1000 arem/hr,'
providet they era otherwise following plant radiation protection procedures for entry into such high radiation areas.
Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by ont or more of the following:
a.
A radiation monitoring device that continuously indicates the ']
(
radiation dose rate in the area.
b.
A
'istion monitoring device that continuously integrates the
- ion dose rate in the area and alarms when a preset ra
- int, aterl dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of
- them, c.
An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over tha activities within the area and shall perform periodic radiation surveillance at the frequency specified by the [ Radiation Protection Manager) in the RWP.
(continued)
)
b AP600 5.0 22
. 08/97 Amendment 0 Enclosum 2
High Radiation Area 5.7 5.7 High Radiation Area (continued)
C-5.7.2 In addition to the requirements of Specification 5.7.1, areas with h radiation levels}1000 erse/hr shall be provided with locked or continuously guarded doors to prevent ursuthorized entry cnd the keys shall be maintained under the administrative control of the Shift Foreman on duty or health physics supervision. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maxima allowable stay times for individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive expo P re control over the activities being perforred within t!,e stoa.
5.7.3 For individual high radiation areas with radiation levels of
> 1000 mrem /hr. accessible to personnel, that are located within large areas such as reactor containment, where no enclosure exists for purposes of locking, or that cannot be continuously guarded, and where no enclosure can be reasonably constructed arourd the individual area, that individuai area shall be barricaded and
[
conspicuously posted, and a flashing light shall be activated as a warning device.
b AP600 5.0 23 08/97 Amendment 0 mis
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