ML20245B893
| ML20245B893 | |
| Person / Time | |
|---|---|
| Issue date: | 03/21/1982 |
| From: | Brinkman D NRC |
| To: | Nacario V PHILIPPINES |
| Shared Package | |
| ML20245B786 | List: |
| References | |
| FOIA-89-99 NUDOCS 8904260349 | |
| Download: ML20245B893 (11) | |
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i MAR 21 1982 l i I
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Mr. Vicente V. Nacario Philippine Atomic Energy Commission Diliman, Quezon City Post Office Box 932 Manila Philippines
Dear Vic,
I have-reviewed the material you forwarded to me by your letter of-February 21, 1985. My evaluations of the NPC responses are provided in the enclosure. These evaluations are based upon the marked up technical
. specifications and responses provided by '.'PC in the material attached to your letter.
- Mary and I are looking forward to seeing you again when you return to Bethesda. Please give our greetings to Fe and your children.
Please feel free to contact me again if I can be of further assistance to you.
Sincerely, Donald S. Brinkman
Enclosure:
As stated 1
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' this record was' deleted in e o ante with the freedom of Information '
Act er. m0li ES F0lA-
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8904260349 890421c f y' PDR. FOIA PDR);c POTTSCHM89 99 ,
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Evaluations of NPC Responses to Recommended Changes to PNPP-1 Technical Specifications
-Item 1 - NPC Response:
To conform to the PAEC recommended changes, pages.16.1-7, 16.6-8, 16.6-12, 16.6-15, 16.6-19, 16.6-22,.16.6-27 and 16.6-29 are being revised as shown in the attached affected pages to be consistent with the issuance of 10 CFR 50.73 Material on pages 16.6-?3 through 16.6-26 are deleted.
Evaluation:
Proposed Technical Specification 6.5.1'.6.f on page 16.6-8 should' be revised to read: " Review of all REPORTABLE EVENTS." This change should be made since 10 CFR Part 50.73 does not require 24-hour written notifications; it only requires the submittal of written reports within 30 days after discovery of the event.-
Prompt notification (within 1-hour or 4-hours, depending upon the event) of the event is required by 10 CFR Part 50.72 The other changes proposed for Item-1 appear acceptable.
Item 2 - HPC Response:
i Definition of shutdown margin is being revised to be consistent with NUREG-0452.
Evaluation:
Although the affected pages were not received for review, the commitment to revise this definition is acceptable. PAEC should verify that the appropriate change is accomplished.
Item 3 NPC Response:
Item 3 is under review and resolution and will be provided by the first week of March 1985.
Evaluation:
No evaluation was performed since a response was not provided for review.
Item 4 - NPC Response:
Tables 2.2-1 and 4.3-1 are being revised as indicated in attached affected pages 16.2-7, 16.2-14, 16.2-15, 16.2-16 and 16.3/4.3-11.
Further, pages 16.3/3.3-12 and 13 are being revised consistent with the PAEC comment.
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Evalua tion:
On page 16.2-14, the Allowable Value for Functional Unit 1.d.
(Pressurizer front of it. Pressure - Low) should have the symbol ">" inserted in
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On page 16.2-14, "NA" should be entered in each of the five columns for Functional Unit 3.a.3 (Automatic Actuation Logic).
On page 16.2-15, appropriate values should be entered in each of the five columns for Functional Unit 3.c.2 (Containment Radioactivity-High .
On page 16.2-16, "NA" should be entered in each of the five columns for Functional Unit 6.f (Station Blackout Starts Motor-Driven Pumps) .
On page 16.3/4.3-10.
notation (9) was added to the S and M surveillance requirements appropriate forNUREG-0452,
- see Functional Unit Rev.6,4this addition does not appear On page 16.3/4.3-11, notation (9) on the M was chan notation (10) does not exist Table 4,3-1 and those on pages(see page .
The16.3/4.3-14)ged notations for t made consistent with NUREG-0452, 16.3/4.3-13 Rev. 4. and 16.3/4.3-14 should be Item 5 - NPC Response:
Action statements for paragraphs 3.1.1.1 and 3.1.1.2, pages 16.3/4.1.1 and 16.3/4.1-3 are being revised for equivalent boration rates.
Evaluation:
No evaluation was performed since a response was not provided for review.
Item 6 - NPC Response:
This is to confirm that the SI pumps are capable of being lined up to deliver water from the RWST to RCS.
approximately 2,200 psi, which allows theShutoff head of these pumps is at a slightly lower than nominal pressure. pumps Thus,to discharge to the specification RCS 3.1.2.2 I
on page 16.3/4.1-11 should remain as written.
Evaluation:
The applicant's above response is at best marginal and probably should be considered unacceptable. The RCS normal operating pressure is 2 2,200 psia (see Table 3.2-1 on page 16.3/4.2-22) and since the SI pumps have a shutoff head of approximately 2,200 psi (see applicant's above response), these pumps probably could not inject borated water for reactivity control at operating pressure, i
t Item 7 - NPC Response:
Item 7 is under review and resolution and will be provided by the first week of March 1985.
Evaluation:
No evaluation was performed since a response was not provided for review.
Item 8 - NPC Response:
Applicable specification referring to RWST freezing point will be deleted. Attached affected pages 16.3/4.1-16, 16.3/4.1-17, 16.3/4.1-18 and 16.3/4.5-14 are being corrected.
Evaluation:
Response appears acceptable.
Item 9 - NPC Response:
Action statements under paragraph 3.1.3.1, page 16.3/4.1-20 are being revised in line with the recommended changes associated with Shutdown Margin.
Evaluation:
No evaluation was performed rince a response was not provided for review.
Item 10 - NPC Response:
Item 10 is under review and resolution and will be provided by the first week of March 1985 Evaluation:
No evaluation was performed since a response was not provided for review.
Item 11 - NPC Response:
Table 3.3-4 notations on attached affected page 16.3/4.3-28 will be revised to delete contents of Note 6 Evaluation:
Response appears acceptable.
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Item 12 - NPC Response:
. ' numbers Attached 1.c,affected 1.d, Table 3.3-6 1.f. 1.g, andis1.h.
being revised to delete entries under gnluation:
Response appears acceptable.
Item 13 - NPC Response:
Action 30 of Table 3.3-6 is being revised as shown in attached affected page 16.3/4.3-42.
Evaluation:
Action 30 should be revised to read:
"With the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirement, either restore the in- i operable Channel (s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or: ~
(1)
Initiate the preplanned alternate method of monitoring the appropriate parameter (s), and (2) Prepare and submit a Special Report to the Consnission pursuant to Specification 6.9.2 within 14' days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status."
Item 14 - NPC. Response:
Tables 3.3-9 and 4.3-6 include all instruments which are provided and needed to monitor reactor shutdown from the Remote Panels.
Likewise, Tables 3.3-10 and 4.3-7. include these instruments.
Therefore, no changes are required.
Evaluation:
Tables 3.3-10 and 4.3-7 in the PNPP-1 proposed technical specifications are ccpies of those same tables in NUREG-0452, Rev. 4 (including the notation tre at the topOnly").
"Illustrational of each of the tables stating that the listings Tables 3.3-10 and 4.3-7 in the PNPP-1 proposed technical specifications should be reviewed to verify that they accurately list the PNPP-1 accident monitoring instrumentation.
Item 15 - NPC Response:
Entries in Table 3.3-11 pages 16.3/4.3-62 thru 16.3/4.3-62E will be changed from all to the specific number of instruments.
Evaluation:
No evaluation was performed since a response was not provided for review. PAEC should review the specific number of fire detection instruments listed in the revised Table 3.3-11 and verify that. the -
listed numbers of instruments is consistent-with the number (and types) of instruments assumed in the Fire Hazards Analysis for PNPP-1.
Item 16 - NPC Response:
Attached affected page 16.3/4.3-64, item (a) will be revised to reflect surveillance once per 31 days.
Evaluation "
Response appears acceptable.
Item 17 - NPC Response:
- This is to confirm that 3.4.1.2.b is correct and therefore no change is' required. The minimum safety analysis requirement for Mode 3 is that at least one loop be operating. A second operable loop satisfies single failure criteria.
Evaluation:
Response appears acceptable.
-Item 18 - NPC Response:
Attached affected pages 16.3/4.4-20 and 16.3/4.4-21 are being revised to correct paragraphs 3.4.6.1(a) and 4.4.6.1(a).
Evaluation:
Action Statement on page 16.3/4.4-20 should be revised to read: i "With only two of the above required leakage detection systems OPERABLE, operation may continue for up to 30 days provided grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required gaseous l or particulate radioactive monitoring system is inoperable; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> j
and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
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l Item 19 - NPC: Response:
The assumption of.one charging pump which is manually operated to deliver' additonal flow to the RCS is to conservatively maximize doses and do not explicitely model operator actions or response- of the plant.
In actuality, in the event that a charging pump is running and an SI signal occurs concurrent with a blackout ~ condition _(which-is the assumption considered in the SGTR accident presented in-the FSAR),
the charging pump will trip and is locked-out.
- Thus, we'see no basis for making a change in 3.4.6.2 and 4.4.6.2 of i the Plant Technical Specifications.
Evaluation: I My original comment on this technical specification was in error. The applicant's, response appears- acceptable.
l Item 20 - NPC Response:-
The maximum RWST. volume in spray and final containment. sump pH was
- I 100% of tank volume. In the determination of the minimum post-accident pH limit, a RWST volume at the tank overflow elevation to the tank out-let elevation was assumed for conservatism. Thus, there is no need to include in the Tech Specs a maximum volume limitation.
Evaluation:
Response appears acceptable.
Item 21 - NPC Response
- I Paragraph 3.6.1.2(a) on attached affected page 16.3/4.6A-3 is being deleted. References to L in other parts of the Tech 4pecs are also T
being deleted.
Evaluation:
Response appears acceptable. !
Item 22 - NPC Response:
LC0 and SR from page 3/4.6-11d of NllREG-0452 are being added to the-Tech Specs.
I Evaluation:
I Response appears acceptable, l j
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9 Item 23 - NPC' Response:
Attached affected page 16.3/4.6A-12 will be revised to correct paragraph 3.6.1.6. Action statement and additional paragraph 4.6.1.6.3 for Surveillance Requirements will be added as shown in attached affected page.
Evaluation:
Proposed Surveillance Requirement 4.6.1.6.3 should be revised to read:
" Determine the number of hours which the reactor building purge isolation valves have been open at least once per 7 days."
It is not considered necessary to measure the leakage rate of these valves every 7 days.
The Action statement for LC0 3.6.1.6 should be revised to read:
"With one reactor building purge supply and/or one exhaust isolation valve open for more than 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days, .
close the open valve (s) within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
It is important to restrict the opening of both the supply and exhaust isolation valves since either penetration would permit excessive leakage from the containment.
Item 24 - NPC Response:
Attached affected page 16.3/4.6A-19 is being revised to periodically demonstrate flow through the entire Na0H path.
Evaluation:
Response appears acceptable.
Item 25 - NPC Response:
Surveillance requirements for charcoal and HEPA filter systems are i
revised per USNRC Generic Letter 83-13 as noted on attached revised pages 16.3/4.6A-30,16.3/4.6A-31,16.3/4.7-17,16.3/4.7-18,16.3/4.7-19, 16.3/4.g-17,16.3/4.9-18,and16.3/4.9-19.
A Evaluation:
Response appears acceptable.
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Item 26 - NPC Response- )
As recommended, contents of Table 3.7-4a and 3.7-4b' are being deleted l
in their and entirety.'
4.7 'are References also being deleted. to these tables in Specifications 3.7 Evaluation:
Response appears acceptable.
Item 27 - NPC Response:
FSARAffected 84-15. Sectionspages3.8.1.1 and 4.8.1.1 are amended to address new Table 4.8-1A are attached.16.3/4.8-1 to 16.3/4.8-5 and 16.
Evaluation:
Generic Letter 84-15 was issued to reduce the number of cold, fast starts of diesel generators and to seek licensees connents on (but not adopt) the example technical specifications attached to Generic Letter 84-15.
Therefore, the PNPP-1 proposed technical specifications should be revised to read according to the attached marked up copy of the PNPP-1 proposed technical specifications. (Adopt footnote on pages I and 2 of Typical Technical Specifications attached to Generic Letter 84-15.)
- Item 28 - NPC Response:
Paragraph 4.8.2.3.b on page 16.3/4.8-18 as previously written implied that or the test overcharge. outlined was to be conducted only after a battery discharg This paragraph was revised to clearly indicate.that the test are to be performed at least once per 92 days regardless of a battery discharge of overcharge occurrence.
We conclude that the Surveillance Requirements is appropriate as currently written.
Evaluation:
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It was intended that the tests specified in proposed technical ~
specification 4.8.2.3.b be performed after a battery discharge or overcharge and at least once per 92 discharge oRyercharge occurrence. days regardless of a battery Therefore, proposed technical specification 4.8.2.3.6.b should be revised to read:
"At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110-volts, or battery by overcharge verifying that:" with battery terminal voltage above 150-volts,
O.
Item 29 - HPC Response:
The functions, composition, responsibilities and authority of the Independent Safety Engineering Group is being added in the Plant Technical Specifications.
Evaluation:
Response appears acceptable.
Item 30 - NPC Response:
Attached affected page 16.6-5 is being revised to include in Table 6.2-1 to note that overtime limits apply to key maintenance personnel.
Evaluation:
Response appears acceptable.
Item 31 - NPC Response:
Attached affected pages 16.6-13 and 16.6-14 are being revised to change audit frequencies to once per 12 months.
Evaluation:
Response appears acceptable.
Item 32 - NPC Response:
Attached affected page 16.6-15 is being revised to specify in "
6.5.2.10.aresponsible President to c that these recordsPower.
for Nuclear are forwarded to the Vice-Evaluation:
Response appears acceptable.
Item 33 - NPC Response: i i
Attached affected pages 16.6-15 and 16.6-19 are being revised per Generic Letter 83-43.
Evaluation: I I
Response appears acceptable.
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Item 34 - NPC Response:
Attached affected page 16.6-16 is being revised to include item (e) that states that critical operation of the unit shall not be rettmed until authorized by PAEC.
Evaluation:
Response appears acceptable.
Item 35 - NPC Response:
Attached affected page 16.6-19 is being revised to include 6.8.4.d and e of the W - STS.
Evaluation:
Response appears acceptable.
Item 36 - NPC Response:
Listings of various Special Reports are being deleted from pages 16.6-22 to 16.6-26. l Evaluation:
Response appears acceptable.
Item 37 - NPC Response:
l The attached revised pages; 16.3/4.7-15, 16.3/4.7-16, 16.3/4.7-17 and 16.3/4.7-41 are amended to reflect the as-built plant of PNPP-1.
- 1) On the subject of ultimate heat sink level, attached FSAR page 16.3/4.7-15 changes the definad minimum water level.
- 2) Attached revised pages 16.3/4.7-16 and -17 reflect actions related to the MCR air conditioning systems.
- 3) Attached revised page 16.3/4.7-41 reflect resolution of comment concerning low pressure CO 2 systems. The installed CO2 is high pressure only.
Evaluation: i I
Response appears acceptable.
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MORG AN, LEWIS & BOCKlUS WAS HI NG TON COU NS cLORS AT LAW PHILADELPHIA A NEw Yonx Los ANGELES 18 0 0 M ST nt cT, N. W.
SAN DIEGO
- WAS Ht N GTO N, D. C. Boo 36 HannisSURG TCLEPHONE:(2021467 7000
' CAsLC ADomtss:MOR LEBOC K Tt t tx : 89-627 TE LE fax:(202) d 67-7176 March 1, 1989 FREEDOM OF lUTEM'4T!0,1 ACT RMUEST Mr. Donnie Grimsley Mail Stop P370 [d,M ~/f.- f [
Nuclear Regulatory Commission Washington, D.C. 20555 80h[ -[
Re: FOIA Reauest
Dear Mr. Grimsley:
Pursuant to the Freedom of Information Act, 5 U.S.C.
Section 552, I hereby request access to and copies of iny documents or data of any kind with regard to the technical review support services provided by the Nuclear Regulatory Commission concerning the Philippines Nuclear Power Plant. i In addition to any other materials regarding the NRC's (
support to the subject project, I am interested particularly in the documentation involved in the following events:
- 1. In 1978 and 1979 the NRR determined that certain components (e.g., tanks) did not require an NRC f export license.
- 2. In 1978 the NRC staff of_ Region II assisted in the International Atomic Energy Agency's (IAEA) safety review.
- 3. In 1979 the NRR along with the OPE and consultant technical support performed a review of site geological concerns.
- 4. In 1984 the NRR technical review staff provided consultation to Philippines authorities on a broad f
range of subjects. For example, the NRR staff answered questions regarding the FSAR (Final 'f l
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MORGAN, Lewis & Bocxius 1
Safety Analysis Report) and provided training to {
Philippines reviewers.
- 5. In !!ovember, 1984, Mr. Donald Brinkman, a staff reviewer, served as an IAEA expert and conducted a two-week review of plant proposed Technical Specifications.
If any document or portion of a document identified in reponse to the above request is believed exempt from disclosure, please identify the specific basic for exemption.
In accordance with 5 U.S.C. Section 552 (b), if a portion of any requested document is exempt, please provide the requested document after deletion of the exempt portion.
I am willing to pay an appropriate fee required for locating and copying the documents. I will accept partial releases of the requested material as it becomes available to you.
Please contact me at (202) 467-7108, if you have any questions or wish to discuss this request in any way.
Sincerely, v$ hf s/
Faith Pottschmidt Legal Assistant j
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