ML20235A069

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Informs That Gessar 251 Application Insufficient for Initiation of Detailed Review.Deficiencies Include Outstanding Items in Electrical,Instrumentation & Controls Area (Chapter 7).Response Schedule Requested
ML20235A069
Person / Time
Site: 05000000, 05000531
Issue date: 10/18/1974
From: Anthony Giambusso
US ATOMIC ENERGY COMMISSION (AEC)
To: Stuart I
GENERAL ELECTRIC CO.
Shared Package
ML20234C970 List:
References
FOIA-87-40 NUDOCS 8707080303
Download: ML20235A069 (19)


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General Electric Company ATIN: Mr. Ivan F. Stuart Manager, Safety and Licensing 175 Curtner Avenue San Jose, Califomia 95125 Gentlemen:

1.

In accordance with the Commission's nr.ilations (Section 2.101 of.10 CFR Part 2) we have ce=Arted a preliminary nyiew of your p

GBSSAR 251 application. (hi the basis of this review we have ~~

concluded that your application is not sufficiently complete for us to initiate our detailed' review..

l our preliminary review has identified a number of areas of (ESSAR s

251 where the information presented is either inadoquate or incomplete.

1hese deficiencies are identified in the enclosure to this letter.

i 1he most significant of these deficiencies, and the cause for rejection

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of GESSAR 251,.are the outstanding items in th3 electrical,-instrumen-

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tation and contmis area. (Chapter 7). This infomation aust be incorporated in GBSSAR 251 before it is docketed. We are, therefore, requestind that you provide a schedule for response to these items within th:.rty days.

J Sincerely, gg signeW

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l A. Gianbusso, Deputy Director l

for Reactor Projects Directorate of Licensing

Enclosure:

Additional Infomation 1

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- Perm ABC.318 (Rev. 7 53) ABCM 0240 W u. e. oovenwusut parwisus.rrscan son.eae.see

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L. Gifford Manager of Regulatory Operations Unit General Electric Company 4720 Montgomery Lane Bethesda, Maryland 20014 l

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. Ivan F. Stuart

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InaccordancTwith'

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CPR Part 2). we have, Commission's fogulations.(Section 2.101 of'10

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cted a preliminary review of-your tendered l

GESSAR 251 application, On the basis of this review we have conclude that your application is l

detailed review.

ficiently complete for us to initiate our lete to p%sve concluded that the application is While we 1

sufficiently comp.

l identified a number of areas {t docketing, our preliminary review has lI ern i

GESSAR 251 where the information presented is either inadequate

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identified in the Enclosure to th incomplete.

M ass deficiencies are these deficiencies are those items letter.

The most significant of electrical, instrumentation and controlstanding items on the j

e' area (Chapter 7).'"'

We shall docket GESSAR 251 on October 11 of STN 50-531 subsequent to receiving the a974,underthedScketnumber of the documents required by Section 50.30(c) ropriate tamber of copies addition we' plan to phbiish a notice in the F f 10 CFR Part 50.

effect that we have accepted GESSAR 251 for reviral Register to the In Safety Evaluation Report M e nting the results o and plan ~to prepare a the standardization ACRS for its review. policy and subsequently to.refe our review under docketing date'and you will be advised of key mileW e detailed rev to begin on the as soon as a"sch'edule is developed.

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The Enclosure,.-1 u-.,

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2 dentifies the additional information req detailed review.

his requested information should be inco for our CESSAR 251 as soon after docketing as possible ated in within seven days after docketing.requasting that you provide a We are, there re, ese it information should be subaltted in appropri tthe informa es i

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nerefore, 2S1 application on or prior to the final responso d ta e aseminants to the C s

round questions.

response to these items,within thirtfdaiQfter docketin ;We a e for the first r

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Local;PDR /4)- E' 6~ 7 M Docket File LWR 2-l' File-V. A. Moore m

J. Hendrie A. Kenneke D. Eisenhut R. Klecker.

OGC' RO.(3) p?/ndffin H. Smith (4)'

R. Meccary V. Stello R. Tedesco H. Denton J. P. Knight S. Pawlicki L. Shao T. Novak D. Ross R. Houston T. Ippolito C.Long G. Lainas V. Benaroya

-:R. Vollmer B. Grimes W. Gammill-J. Kastner' M. Spangler R. Ballard J. Stolz K. Kniel A. Schwencer D. Vassallo W. Butler K. Goller ACRS (16)

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l ENCLOSURE 1'

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LIST OF DEFICIENCIES AND REQUEST FOR~ ADDITIONAL INFORMATION-GENERAL ELECTRIC 'OMPANY C

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GESSAR 251 FOR NSSS Project No. STN 538 k

i Legend - Question Numbers XX.KK Refer to this question number in response (XX.XX) Refers to PSAR section covered by question o

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?012-1 012.0 EFFLUENT. TREATMENT SYSTEMS

'012.1 (11.3 For the Compact RECHAR System for treating of fgases from.

the main condenser air ejector exhaust, provide the following information':

(1) The. inventories of radioactive materials in each component.

(2). the heat generation rate due to radioactive. decay.in

'each component, l

(3), the maximum temperatures that will be reached.at the centerline of the desiccant dryer and charcoal delay beds during periods of no flow, (4) the volumes and' activity levels of liquid wastes produced when desiccant dryers are regenerated.

l' (5) the frequency of replacement of desiccant 'and charcoal, and the isotopic composition of the solid wastes

produced, (6) 'the'dyhamih adsorption coefficients employed in.your analysis of.the delay time for the desiccant dryer and justification for. the selected values, (7) the volumes and radioactivity levels of gases released when the desiccant dryer is regenerated, and the method of disposing of..these gases.

012.2 (None)

The following unresolved issues have been identified in our review of the CESSAR-238 application, and need to be addressed in the CESSAR-251 PSAR:

(1) The quality group classification of the components of the liquid, gaseous and solid radioactive waste treatment systems do not meet the attached ETSB Position No. 1.

(2) The seismic design classification of a portion of the offgas system and the structure in which it is housed do 7

not meet the attached ETSB Position No. 1.

(3)

Inndequate storage space is provided for filled solid waste containers.

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(4) Thevaluesforthedynamicadsorptioncoefficients(g) for xenon and krypton in charcoal delay systems at low temperatures (0*C) need to be confirmed by large scale tests that are now being conducted in Germany.

(5) Tanks and components that require charcoal adsorbers on vent -lines for iodine removai need to be identified

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for our review.

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040-1

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l 040.0 CONTAINMENT SYSTEMS i

040.1 Update the text and references given in Section 6.2 on steam (6. 2) line and recirculation line blowdown to include modeling of i

pipe mass inventories.

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040.2 Provide the mass and energy release rates as a function of time (6.2) which will be specified as input to containment subcompartment I

analyses for postulated ruptures of a RWCU line and RHR head l

spray line, j

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'110-1.

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110.0 g CHANICAL ENGINEERING 110.1 In Section 3.6.1.2 of the PSAR, the statement is made that it is (3.6.1 2) recognized by the industry that the definition of exact forces, movements, etc. in.the subject pipe whip analysis is beyond the capabilities of existing techniques of analysis., Verify that none of the computer programs listed in Appendix SA is capable of performing such an analysis.

110.2 In Section 3.6.1.2 of the PSAR, the: rationale 'for assuming a (3.6.1.2) pinned or built-in hinge at the second change in' direction is not completely acceptable.. An acceptable statement on this subject can I.

be found in Section 3.6.1.2 of the Perry Nuclear Power Plant, Units 1 and 2 PSAR, Amendment 18, pg. 3.6-3.

110.3 With. respect to Section 3.6.4.1.2 in the PSAR, an acceptable (3.6.4.1) basis to remove rebound consideration from this specific pipe whip restraint design when the total gap size (initial clearance plus deformation) is approximately 6" or larger is provided.

However, rebound effects may become more severe when the gap size is small.

Verify that all the pipe whip restraints in GESSAR-251 related plants do not have gap size less than 6".

In the event of smaller gap size, either provide additional justification or commit to use a. thrust force amplification factor of 1.2..

110.4 Complete the information presented in Sections 3.9.1.3 and 4.2.2

. (3.9.1.3) of the PSAR by providing a detailed description of the methods and procedures 'which will be used in the dynamic system analysis which will be performed to confirm the structural design adequacy -

of the reactor internals (including fuel element assemblies, control rod assemblies and drives) to withstand dynamic effects under a simultaneous occurrence of steam line break and SSE.

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110.5 2he loading combinations and stress limits which are prasented j

(3.9.2.2, in Section 3.9.2.2.1. of the PSAR are not completely acceptable.

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3.9.2.3)

Acceptable criteria may be found in Regulatory Guide 1.48,

" Design Limits and Loading Combinations for Seismic Category I Fluid System Components".

The response to Question 5.2, Amendment 19 to R1 GESSAR also contains acceptable criteria with the exception of the loading combination for the upset condition.

An acceptable loading combination for the upset

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condition is upset plant condition loadings plus OBE unless

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it can be justified by methods such as a time history analysis i

that such a combination is not required. Revise Section 3.9.2.2.1 in the PSAR accordingly.

110.6.

In Section 3.9.4.1 pg. 3.9-20 of the PSAR, IEEE Standard 344, (3.9.2.4) 1971 is referenced. Verify that the seismic qualification procedures which will be used for the subject components will meet the criteria outlined in Attachment A, " Electrical and Mechanical Equipment Seismic Qualification Program".

l 110.7 Provide the criteria for any Class 1, 2 and 3 field run piping (3.9.2.7, systems supplied by G.E. as a part of NSSS GESSAR.

Revise 5.2.1.19)

Sections 3.9.2.7 and 5.2.1.19 in the PSAR accordingly.

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110.8 The loading combinations for anchor bolts presented in (3.9.3)

Section 3.9.3.4.2 of the PSAR are not completely acceptable.

To be acceptable, the combinations should be modified as follows:

Upset Condition - add dynamic system loads associated with the upset condition to the existing loads.

Faulted Condition - add dynamic system 1 cads associated with the faulted condition to the existing loads.

Revise Section 3.9.3.4.2 accordingly.

110.9 The information presented in Section 3.10 of the PSAR is not (3.10) completely acceptable.

An acceptable program for the seismic qualification of electrical equipment and instrumentation is outlined in Attachment A.

Provide a program which is consistent with Attachment A.

110.10 The loading combinations and stress limits which are presented (5. 2.1. 5 )

in Table 5.2.5 of the PSAR are not completely acceptable.

Acceptable criteria may be found in Regulatory Guide 1.48, J

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110-3 110.10

" Design Limits and Loading Combinations for Seismic Category I (5.2.1.5)

Fluid System Components".

We response to Question 5.2, Amendment 19 to RI GESSAR also contains acceptable criteria ~

with the exception of the loading combination for the upset condition.

An acceptable loading combination for the upset condition is upset plant condition loadings plus OBE unless

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it can be justified by metheds such as a time history analysis that such a' combination is not required.

Revise Table 5.2.5 in the PSAR accordingly.

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G' 12/3/73

Att chment A y

~ ELECTRICAL AND MECHANICAL EOUIPMENT SEISMIC QUALIFICATION PROGRAM I,! Seismic Test for Equipment Operabil'ity 1.

A., test,. program is required to confirm the functional operability Lof.all Seismic Category I electrical'and mechanical equipment and instrumentation during.and af ter an earthquake of magnitude up to and including the SSE.

Analysis without 1.esting may be acceptable only if. structural integrity alone can assure the' design intended function._ When a complete seismic testing is impracticable, a combination of test-and analysis may be. accept.

able.

2.

The characteristics of-the required input motion should be

_j specified by one of the following:

(a)' response spectrum (b) power. spectral density function

'(c) time history Such characteristics, as derived from the structures or systems seismic analysis, should be representative of the input motion at the equipment mounting locations.

3.

Equipnent should be tested in the operational condition.' ' Oper-ability should be verified during and after the testing.

4.

The actual input motion should be characterized in the same manner as'the required input motion, and the conservatism in

- amplitude and' frequency content should be demonstrated.

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Seismic excitation generally have a broad frequency content.

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' Random vibration input motion should be used.

However, single frequency input, such as sine beats, may be applicable provided one of' the following conditions are met:

1 (a) The characteristics of the required input motion indicate I

that the motion is do inated by one frequency (i.e., by structural-filtering effects).

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(b) The anticipated response of the equipment is adequately represented by one mode.

(c) The input has sufficient intensity and duration to excite all modes to the required magnitude, such that the testing response spectra vill envelope the corresponding response spectra of the individual modes.

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The. input motion should be applied to one vertical and'one principal.. (or two orthogonal) horizontal axes simul'taneously unless it can be ' demonstrated that the equipment response d

along the vertical ~ direction is not sensitive to the vibratory 7

notion along - the horizontal direction', and vice versa.. The.

time'. phasing of the. inputs in the vertical.and horizontal direc-

'tions must be such that a purely rectilinear resultant input is:

. avoided. The acceptable alternative is to have vertical and o

. horizont' 1 inputs in-phase, and ther. repeated vith inputs a

180' degrees out-of-phase.. In addition, the test must be repeated with' the equipment rotated 90 degrees horizontally.

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The fixture design should meet.the following requirements:

E (a). Simulate the actual service mounting -

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(b) Cause no dynamic. coupling = co, the test item.

8.

The in-situ application of vibratory devices to superimpose the~

seismic vibratory loadings on the complex active device for operability. testing is acceptable when application is justifiable.

o 9.

The test program may be based upon selectively testing a repre-sentative nu=ber of mechanical components according to type, load level, size, etc. on a prototype basis.

  • 11.

Seismic Design Adecuacy of Supports _

1. ~ Analyses or tests should be performed for all supports of electrical and mechanical equipment and instru=entation to w

ensure their structural capability to withstand seismic

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' excitation.

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2.

The analytical results must include the following:

(a) The required inputtmotions to the counted equipment should be obtained and characterized in the manner as stated in S'ction I.2.

e (b) The combined stresses of the support structures should be within the limits of ASME Section III, Subsection hT -

Component Support -Structures" (draf t version) or other comparable stress limits.

3.

Supports should be tested with equipment installed.

If the equipment is inoperative durin's the support test, the response at the equipment mounting locations should be monitored and 4

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characterized in the manner as stated in Section I.2.

In such a case, equipment should be tested separately and the actual input to the equipment should be more conservative in amplitude and frequency content than the monitored response, i.-

4.

TheEequirementsofSection,I.2,I.4.I.5,I.6andI.7are applicable when tests are (;nducted on the equipment supports.

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4 120.0 MATERIALS ENGINEERING (Note: Numbers in parenthesis are SAR section numbers) 120.1

-In Section 4.'2.2.1.2.5 of the SAR you state that the material f:

, (4.2.2) used for fabricating most of the reactor vessel core support.

and reactor internal structures is solution. heat-treated, unstabilized type 304 austenitic stainless steel.

List other materials used for these components and list their specifications.

120.2-In Section 4.2.3.1.1.2 of the SAR you state that type 304

(4.2.3) austenitic stainless steel comprises the major porti'on of the assembly. List other materials used for the reactivity control system and list their specifications.

120.3 Provide the following information concerning me,tallic materials (6.0) used for.compenents of engineered safety features.

(1) Liat the specifications for the principal pressure-retaining ferritic materials, austenitic stainless steels, and non-ferrous metals, including boicing and weld materials, in each component (c.,g., vessels, piping, pumps, and valves) that is part of the ESF.

(2) List the ESF materials of construction that will be

-exposed to the core cooling water.and containment sprays in the event of a loss-of-coolant accident, and describe the compatibility of the construction materials with the cooling solutions.

(3) Provide the following information for avoidance of stress-corrosion cracking of austenitic stainless steels for components of the ESF during all stages of component manufacture and reactor construction:

(a)

Sufficient details for avoidance of significant sensitization during fabrication and assembly of austenitic stainless steel components of the ESF to

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indicate that the degree of freedom from sensitization will be comparable to the recommendations of Regulatory Guide 1.44, " Control of the Use of Sensitized Stainless Steel." Provide a d'scription e

of materials (including provision for 5% minimum h

delta ferrite,when required), welding and heat trent-ing processes, inspections, and tests.

(b)

Sufficient details about the process controls to minimize exposure to contaminants capable of causing stress-corrosion cracking of austenitic stainless

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steel componients of'the ESFlto show that the_ process controls will provide a degree of surface cleanliness,;

-during all stages of component manufacture and

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reactor construction comparable'to the recommenda -

tions of Regulatory,Cuide~l'.44, " Control of the Use of' Sensitized Stainless Steel," and Regulatory.

Guide 1.37, " Quality Assurance. Requirements for

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Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants."

(c), Details on cold worked austenitie stainless steels for components of.the ESF. ' If such steels haveL yiel'd strengths greater than 90,000_ psi, provide assuranceithat they will be compatible with the core cooling' water and the containment sprays in'the event of a loss-of-coo'lant accident.-

(d) Sufficient information about the selection,' procure-ment, testing, storage, and. installation of'any nonmetallic thermal' insulation for"austenitic stoinless. steel components of the ESF to' indicate that concentration'of chloride,' fluoride, sodium, and silicate'in the insu,lation will be comparabic to the recommendations of Regulatory Guide 1.56,

" Nonmetallic Thermal Insulation for Austenitic Stainless Steel."

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130-1

-130.0 STRUCTURAL ENGINEERING 130.1 The applicant should.* identify those systens and components (3.3) within the 251 GESSAR NSSS scope nf supply that should not be exposed to the effects of wind and tornado in Section 3.3 for balance of plant (80p) designers to datermine appropriate plant layout and select protective structures as needed for the identified items. Alternatively, the applicant may define in Section 3.3 prescribed levels of wind and tornado loadings to which systems and components of the USSS are designed so that a BOP designer can determine whether the systems and components require protection from applicable wind and tornado effects given a set of pertinent site parameters.

130.2

.NSSS-80p interface design information applicable to water

'(3.4) level and flood consideration for 251 GESSAR components and systems s.imilar to those specified in Question 130.1 should be included in Section 3.4.

130.3 NSSS-80p interface design information regarding missile (3.5.1) protection consideration for 251 GESSAR components and systems similar to those specified in Question 130.1 should be provided "in Section 3;5.1.

130.4 In Section 3.7, clear stipulation of allowable USSS-80p (3.7) interface seismic loads, forces, displacements and strains, etc., for systems and components within the scope of supply of 251 GESSAR should be included.

130.5 In Sections 3.8.1 and 3.8.2 the interface design infon:ation (3.8.1 and and parameters that will be provided by General Electric 3.8.2 Company to applicants referring to 251 GESSAR or vice versa, for use in the design of either the USS system or the containment should be described and discussed with augmen-tation by sketches as required.

This would include contain-ment pressure, mass and energy releas~es following LOCA accidents, the loads from various postulated pipe breaks and pipe reaction forces, equipment reaction loads, floor response' spectra and deflections which could be tolerated by systems and components within the scope of 251 GESSAR USSS.

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In Section 3.8.3, General Electrje Company should outline >

'(3.8.3) the method.to be utilized which will-address the dasign-t interfaces between the flSS systems and.equiprent supplied

, by General Electric Company and the internal structures of

' theLeontainment which constitute a.part of the balance of:

plant._ It should.be made clear as' to whether CE will have:

4 a range _of values for interface' design parameters or specific ~

l values of..the~ same parameters for.which the balance of plant must be designed.

These specific interface design parameters for the flSSS should be adequately defined ;and provided in; the section., Examples of > some of the paraneters which must be

considered are mentioned in the question 130.5. With the interface de' sign parameters defined. S0P designers may adopt appropriate ' design measures to ensure that the. required "SSS-interface.~parametersiand requirements are fully met. ' Alta -

natively,'a specific BOP design associated with a specific

~ ite can be. evaluated against 251 GESSAR i:SSS interface design.-

s parameters to establish compatibility between the two plant systems.

The applicant should indicate its. basic ' position regarding these design interface integration problems and provide sufficient-information for review,- accordingly.

130.7 Because of an increase in diameter of the reactor' vessel and'

(3.7) its associated changes, the seismic responses of the PPV and internals system may be significantly changed from

'those of a model using a sraller diameter vessel.

The applicant should di: cuss any changes in dynanic model, key analytical parameters and responses in the~ SAR.

130.8 In Section 3.7.3.15, a ' reference is made to Section

-(3.7.3)-

3.7.3.2.3 for a description of the reactor seismic analysis.

The referenced section cannot be found in the SAR.

130.9 The' basis for adopting damping valuas of 5% for OBE and

'(3.7.1 )

6% for SSE in determination of seismic responses for fuel L

elements as proposed in Table 3.7.1 should be provided.

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220-1 220.0 ELECTRICAL INSTRUMENTATION AND CONTROL SYSTEMS

.220.1 Provide the preliminary designs of the Rod Pattern Control System (7.0)

(RPCS), the proposed method of increasing the scram reactivity rate..the use of ganged control rods,-the revised control' rod position detection and indication system and the solid state, 2-out-of-4 protection system.

In addition, you should evcluate>

the effect of these design changes on the plant in enough detail to conclude that the plant can be built and operated ~ safely. The information in GESSAR-251 is not in sufficient detail to permit us to perform an independent analysis of the adequacy of the design.

- 220.'1 (7.0, 15.0)

Information contained in Chapter 7 is not consistent with other portions of Chapter 7 nor is all of the information in Chapter 7 consistent with other chapters in GESSAR. We cannot perform a meaningful evaluation until an accurate and consistent document is provided.

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. RADIOLOGICAL ASSESSt1Efli 2-'

331.0 331.1:

Provide the justification for the use of 100,000 u C1/sec for.

-(12.1'3.5.1)

Lthe. radioactive = sources in the gas treatment system.- It is p

not clear in section 11.1.1.1, exactly what. operating experience-was used to select.this value.

-"331.2 Is any calibration capability proposed for the range from

. (12.1.4.2);

125 mr/hr to 1000 R/hr'(containment building operating ; floor monitor)?

331.3 This ~ section mentions discussion 'in' Sections 15.1 and 12.1 of

-(12.2.3) '

the modes of relief. valve discharge, the frequency.of occurrence..

and containment occupancy. There is no discussion of these in Section 12.1.

331.4.

The applicant has provided answers to some of the pertinent (Supplementary questions from the review of 238 Reactor Island GESSAR.

information) However..several additional questions from that review should be addresssd'in Chapter 12 of 251 GESSAR.

These are 12.17, 12.31 and 12.48.

331.5

- In the radiation protection design of a nuclear steam supply

-(Chapter 12)

' system, there are several considerations that the applicant can implement for the equipment and components of that system that are important for assuring that occu will be as low as practicable-(ALAP)pational radiation exposures These include design ar.d choice of equipment for low maintenance, design for quick removal (from high. radiation areas), design for maintenance in low radiation fields, design for quick access and entry, design for adequate working space, design for remote handling or tool use,

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and others.

These and any other design considerations relative to the ALAP requirement.should be discussed in Chapter 12.

Illustrative examples of such design features should be provided.

j These should include the reactor and reactor systems during

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normal operation and anticipated operational occurrences (including refueling, purging, maintenance, routine operational surveillance and inservice inspection).

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331.6 Have any design considerations been given to radiation exposure problems that will occur during decommissioning?

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