ML20236F699
| ML20236F699 | |
| Person / Time | |
|---|---|
| Site: | 05000601 |
| Issue date: | 09/30/1987 |
| From: | WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | |
| Shared Package | |
| ML19304B654 | List: |
| References | |
| REF-GTECI-A-29, REF-GTECI-SA, TASK-A-29, TASK-OR NUDOCS 8711020269 | |
| Download: ML20236F699 (13) | |
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WESTINGHOUSE CLASS 3-1 W
. AMENDMENT 1 TO RESAR-SP/90 PDA MODULE 2 O REGULATORY CONFORMANCE-p "O
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'WAPWR-RC AMENDMENT 1 5960e:1d SEPTEMBER, 1987
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ANENDMENT'l TO RESAR-SP/90 PDA MODULE 2 REGULATORY CONFORMANCE Instruction Sheet-Insertcomplete' package (page910-1through'page910-11)behindQuestions/
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WAPWR-RC AMENDMENT 1 f
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' REQUEST FOR ADDITIONAL INFORMATION O' ON RESAR SP/90 ,
SABOTAGE PROTECTION FEATURES T '910'.1- The discussion in Section 5.1 of Module 2, on Generic Issue
.A-29, includes the statement: .
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"The SP/90 design will.. incorporate several features. which should provide improved protection against industrial 1 sabotage. These features include safeguards fluid system designs with reduced or ~e liminated interconnections, I separation between safety and normal operation functions, improved redundancy and diversity, and improved plant layout. Also, the SP/90 plant layout provides improved. :
physical separation between ' safeguards trains A and B as well as between the' safeguards trains and the control systems. This layout allows control of access to vital. 1 areas while still . allowing free' access to: most normally operating equipment."
a) Does the statement regarding improved' protection provided by the layout depend upon controlling access in a way that restricts persons with authorized access to safeguards train l O A from having a'uthorized access .to safeguards train- B, or V persons .with authorized -access to the control' systems from j having authorized access to the safeguards systems? If so, i s are there any emergency conditions, or si.tuations that could l 1ead to emergency conditions', for which this could result- in interference with rapid ingress or egress of personnel? Do you intend'to restrict access to paths between trains A'.and B of control systems?
b) Discuss if and how the layout would benefit protection against outsider sabotage threats.
RESPONSE: 1 a) As indicated on the SP/90 layout drawings (Figure 1.2-2 (9 Sheets) of RESAR-SP/90 PDA Nodule 3 " Introduction and Site"), redundant trains of safety related equipment are located in dedicated areas designated A and B. At each Elevation 77.4 in, 84.8 in, and 92.2 in, a door is provided that could be used to restrict access between these two O
WAPWR-RC 910-1 AMENDMENT 1 5728e:1d - SEPTEMBER, 1987
is y. l redundant--areas; however, as indicated in the review, this could-lead to interference with rapid movement of personnel i that may be required during emergency conditions.
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As stated in Section 6.1 of Nodule 2, access control to
! (q/ vital areas must consider issues such as the one outlined above. -For example, it is possible to have these doors l-locked, with access and egress only by keycards when the ;
equipment is not normally operating. If routine operation )
(q/ and maintenance operations are envisioned in an area, the doors could then be unlocked but provided with alarms that would allow plant security personnel to approve and monitor, by closed circuit--TV, access and egress of these areas.
This could apply to areas where, because of availability of space, some control grade equipment is located in the safety related areas (e.g., instrument air supply); de facto, this equipment becomes subject to the same access control as safety related. equipment.
b) A' defense-in-depth principle is utilized with regard to outsider sabotage.
The first line of defense is the fence surrounding the nuclear power plant. If a person (or persons) were to penetrate the plant fence, this would not automatically lead to access to vital areas, since the Nuclear Power Block does not contain any normally open doors at grade.
Access to the Nuclear Power Block is via the Service Building. This then constitutes the second level of defense; again, although the detailed access control is the responsibility of the utility, we would expect plant
\ security personnel to be located in the Service Building.
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. / Finally,'personne1' access from the,' Service Building- to the
-Nuclear Power Block is via two single doors, one to the
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" clean" and one to the " dirty" (or radiation controlled)
<. area. Again, security -personnel would normally be expected to be .present in these locations, and this would thus O constitute tho' third line-of-defense. Key-locked or alarmed doors provide,a fourth line of -defense by providing plant security Lpersonnel with _ clear information as to the path of the saboteurs.
.910.2 What assumptions about saboteurs' capabilities will be used in-the sabotage assessment indicated in Section 5.1 of Module 27
. RESPONSE: j
-l There was--no sabotage assessment included in the PRA performed for the RESAR-SP/90 PDA. Although consideration has been given to the possibility of sabotage' in_ the design of plant structures, systems and components through closer attention 'in the ' areas _ of separation, redundancy and to plant systems vital l
to the_ safe operation of the plant, the Probabilistic ' Safety- 1 Study performed for the SP/90 PDA (Module 16) did not specifically address the issue of the characteristics (or ,
capabilities) of' saboteurs which would result in a definitive profile _of an " effective" saboteur. It is difficult to l realistically assign probabilities to the possible success of j saboteurs at each stage in a series of ill-defined activities l aimed at disabling a plant and its systems such as to lead to an !
O eventual core melt. ;
1 Each applicant's physical security plan, employee screening l
program and training, and the implementation of programs to preclude sabotage -
including insider threat .
will greatly l determine tho' possibilities of sabotage success or failure. The i SP/90 plant design features already enhance the possibility of i O
WAPWR-RC 910-3 AMENDMENT 1 5728e:1d - SEPTEMBER, 1987
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M . protecting.against " saboteurs.: Further -consideration- would- be given to -this- issue during- the Final ' Design stage to ensure m .- :
E< meeting the intent of any imposed regulatory requirements aimed at_. precluding the' intentional disabling Lof any_ plant systems-
'important1 to' safety.
-s 910.3 Section 6.1 of. Module 2 states' clearly that:
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" Plant. physical protection plans (including access controls i to nuclear' power' plant vital areas) are the responsibility
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-of each utility using the SP/90 design."
While it'is reasonable that. physical protection equipment 'and ,
organization- be utility specific,-it would simplify licensing of sites if the identification of equipment to be protected as vital within the nuclear power block, which is within the W scope, was l standard, rather than utility specific. Pleasi identify the systems and components (includingpipingrunsand valvemotorcontrolcenters),and their locations, withinL your 1 scope that- should be considered vital in- the sense of 10CFR73.2(i).. It would suffice to limit the list 'of components '
to 'those outside of containment. Also. address what systems not within your scope, such as the service water system, should be
. vital. (This response should be protected as Safeguards .
Informationinaccordancewith,10CFR73.21.) '!
J-RESPONSE: i
-Attachment A provides a list of vital systems and areas which are outside of containment,-but within the Westinghouse Nuclear PowerBlock(NPB) scope.. 'The list was compiled from Figure 1.2-2 (Sheets 1-7) of Nodule 3 " Introduction and Site". The areas include associated piping and pipe runs, and valves and valve compartments.
The major vital non-NPB systems outside of containment are the
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910.4 As some equipment within the nuclear power block will be vital, consideration of the needs of vital barriers during building design could be beneficial. Consideration could be given in WAPWR-RC 910-4 AMENDMENT 1 5728e:1d ' SEPTEMBER, 1987 L
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,.. p fs Section 6.2.3 of Module 2 to the regul'atory position on physical V barriers in Regulatory Guide 5.65, which could' impact on design
'of.some ducts and penetrations. l RESPONSE: .
L d, We- understand the comment; the regulatory position (s) in Reg.
Guide 5.65 will'be taken into account during the Final Design.
Clarify whether the plot plan of ~ Figure 1.2-1 of Module ~ 3 is 910.5 Os simply. illustrative or intended to be a standard plot plan or, for physical protection purposes. a " bounding" plot plan.
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RESPONSE: l 1
i The total plot plan cannot be designated as standard. The I location. of the Waste Disposal, Service, and Turbine Buildings-relative to the Nuclear Power Block is fixed because of the )
interface' provisions included in the design -of' the Reactor j
.O External Building; however, the size of these buildings could- j
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change depending on factors such as utility preference, turbine generator ' supplier, need for on-site waste- storage,
.etc...
The location and size of the other buildings is fully within the-scope of utilities and could change relative to the plot plan shown.
910.6 There are inconsistencies between the areas cross-hatched in O Figure 1.2-1 (Mod. 3) as areas of the nuclear power block and the NPB scope specified in Section 1.2.3. For example, the figure shows the Turbine Building and Guard House are in the NPB but they are not. Please clarify.
RESPONSE
The inconsistency that exists in Figure 1.2-1 of Module 3 is due to an error of omission on the part of Westinghouse. .The O '
WAPWR-RC 910-5 AMENDMENT 1 E728e:1d - SEPTEMBER, 1987
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/ -orientation of the schematic given in the figure was changed from the original internal W drawing, but Lthe cross-hatched block, representative of the areas of the nuclear power block, was not. re-oriented to be consistent with the figure. The areas and buildings which are currently shown- as. NPB areas (turbine O building, service building, etc...) are outside the nuclear power block. The areas which are included in the NPB are all within the reactor containment building and the reactor external.
building. This figure will be corrected in the FDA.
V 910.7 Discuss how many decay heat removal systems would have to be l defeated to prevent mitigation of a loss of offsite power-transient. .How would this be affected by loss of cooling water .
to the diesel generators, or other loss of the service water '
system?
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RESPONSE
The Emergency Feedwater System (EFWS) in conjunction with the main steam PORV's constitute the primary means of decay heat O removal. The EFWS contains four emergency feedwater pumps, two motor driven and two steam driven. One of.these four pumps is j sufficient to remove the decay heat following a loss-of-offsite power transient.
If both diesel generators were to fail for whatever reason, the motor-driven EFW pumps would be unavailable; in that case, one of the remaining two turbine-driven EFW pumps would be required to remove decay heat. Note that the turbine-driven EFW pumps are totally independent of AC power.
910.8 Discuss the protection afforded the Emergency Feedwater Storage Tanks and Emergency Water Storage Tanks by their locations ,
inside the Reactor Building.
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RESPONSE
By locating the Emergency Water Storage and Emergency Feedwater
() Storage Tanks within the reactor building, these components are WAPWR-RC 910-6 AMENDMENT 1 5728e:1d - SEPTEMBER, 1987 L__ __ _ _ - - -
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p\ pumps, valves,etc.)'.
l 910.9 .Page 1.9-l'of Module 3 states that. ;
C " Table 1.9-2 provides a listing of programs.and analyses to l be developed on a site specific basis that must interface i with programs initiated during the design of the~NPB.. This I table identifies' the PDA module where the interface- t requirements are described."
^ - That table identifies Module 16 for " Industrial Security." l Where' are interface requirements for physical protection 1 identified in Nodule 16? j
. RESPONSE: 1
.I The - interface requirements for. physical protection for non-NPB structures, systems and components were not identified in Module 16,. "Probabilistic Safety Study", as it had been stated earlier :
in Table 1.9-2 of Nodule'3, " Introduction and : Site".- This will
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O be done for the Final Design Application (FDA) at which time any V imposed regulatory requirements--in the area of plant physical protection--may better define the extent tp which all'struc-
-tures,' systems and components, vital to the safe operation of.
i the plant, , can (or must)-be protected from possible sabotage activities. ,
I 910.10 Although not part of current safeguards regulatory requirements,. !
we request you 1 address the sabotage protection design features i discussed in the January 15, 1987 ACRS letter to Chairman Zech, j "ACRS Recommendations on Improved Safety For Future Light Water J Reactor Plant Design." .
RESPONSE
The ACRS letter contains some specific recommendations:
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- 1. locating the control rooms away from exterior ground I
level
.'WAPWR-RC 910-7 AMENDMENT 1 5728e:1d SEPTEMBER, 1987 l l
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- 2. rooms massive
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concrete structures
- 3. physical separation of redundant safety trains !
- 4. hardening or: separation of vital functions.
We believe that the SP/90 layout is generally responsive to the.
above recommendations. l l
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WAPWR-RC 910-8 AMENDMENT 1 5728e:1d SEPTEMBER, 1987 L
~,. j ATTACHMENT A (SHEET 1 of 3)
VITAL SYSTEMS AND AREAS WITlilN NPB.
AND OUTSIDE CONTAINMENT O' SHEET 1 (EL. 72.0 M)
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O SHEET 2 (EL. 77.4) .
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WAPWR-RC 910-9 AMENDMENT 1 I 5728e:1d SEPTEMBER, 1987 l
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l ATTACHMENT A (SHEET 2 of 3)
VITAL SYSTEMS AND AREAS WITHIN NPB AND OUTSIDE CONTAINMENT
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. SHEET 4 (EL. 84.8 N)
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i SHEET 5 (EL. 92.2 N) ]
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i SHEET 6 (EL. 100.0 M)
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WAPWR-RC 910-10 AMENDMENT 1 5728e:1d SEPTEMBER, 1987
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ATTACHMENT A (SHEET 3 of 3)
.~ VITAL SYSTEMS AND AREAS WITHIN NPB
.AND OUTSIDE CONTAINMENT O ' SHEET 7 -(EL. 107.'6'N)
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WAPWR-RC 910-11 AMENDMENT 1 5728e:1d SEPTEMBER, 1987 l
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