ML20247B873
| ML20247B873 | |
| Person / Time | |
|---|---|
| Issue date: | 03/22/1989 |
| From: | Long W Office of Nuclear Reactor Regulation |
| To: | Kintner E ALWR UTILITY STEERING COMMITTEE, GENERAL PUBLIC UTILITIES CORP. |
| References | |
| PROJECT-669A, RTR-REGGD-01.070, RTR-REGGD-1.070 NUDOCS 8903300064 | |
| Download: ML20247B873 (10) | |
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March 22, 1989
,g Project No. 669 Mr, E. E. Kintner, Chairman ALWR Utility Steering Committee GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054
Dear Mr. Kintner:
SUBJECT:
REQUEST FOR ADDITIONAL'INFORMATION RELATING TO ALWR REQUIREMENTS DOCUMENT CHAPTERS 8, 9, 12, & 13 In the course of our review of the ALWR Utility Requirements Document we have determined that additional information is needed.
The Enclosures provide additional questions and comments to which we request the Steering Committee's g
responses. These questions and coments are being forwarded verbatim as received from our staff reviewers who are attempting to determine the extent to which the Requirements Document complies with the Standard Review Plan.
Many of the questions request that you provide information of a level of detail consistent with Regulatory Guide 1.70 for a Safety Analysis Report. We acknowledge that such level of detail may be beyond the scope and intent of the Requirements Document.
Please provide your responses within 60 days. Our reviewers are available to meet with your personnel or to discuss the issues by telephone.
If you wish such contact please call me at (301) 492-1103.
Sincerely,
/s/
89033 g' y' B903pn William 0. Long, Sr. Project Manager Standardization and Non-Power Reactor h
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Project Directorate Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation As Stated cc:
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March 22, 1989 Project No. 669 Mr. E. E. Kintner, Chairman ALWR Utility Steering Committee GPU Nuclear Corporation 100 Interpace Parkway l
Parsippany, New Jersey 07054
Dear Mr. Kintner:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATING TO ALWR REQUIREMENTS DOCUMENT CHAPTERS 8, 9, 12, & 13 In the course of our review of the ALWR Utility Requirements Document we have determined that additional information is needed. The Enclosures provide additional questions and comments to which we request the Steering Committee's responses. These questions and comments are being forwarded verbatim as received from our staff reviewers who are attempting to determine the extent to which the Requirements Document complies with the Standard Review Plan.
Many of the questions request that you provide information of a level of detail consistent with Regulatory Guide 1.70 for a Safety-Analysis Report. We acknowledge that such level of detail may be beyond the scope and intent of the Requirements Document.
Please provide your responses within 60 days. Our reviewers are available to meet with your personnel or to discuss the issues by telephone.
If you wish such contact please call me at (301) 492-1103.
d Sincerely,
)
William O. Long, Sr. Project Manager Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects III, IV, Y and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
As Stated cc:
J. DeVine Electric Power Research Institute l
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O Enclosure PLANT SYSTEMS BRANCH REQUEST FOR ADDITIONAL INFORMATION I
EPRI ALWR CHAPTER 5 8 AI4D 9 Chapter.8 l
8.1 With respect to component cooling water systems (CCWS) and service water systems (SWS), provide the following information:
a)
GeneralDesignCriterion(GDC)2,relatestostructureshousing the system and the system itself being capable of withstanding the l
effects of earthquakes. Regulatory Guide (RG) 1.29 provides the guidance.to meet the requirements of GDC 2.
Discuss how the CCWS I
and SWS comply with the guidelines of RG 1.29.
b)
Discuss how the CCWS and SWS design will comply with the requirements
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in GDC 4 related to the effects of missiles, pipe whip, jets and i
environmental conditions resulting from high and moderate energy line breaks and dynamic effects associated with flow instabilities and loads (e.g., water hammer) during normal plant operation as well j
as during upset or accident conditions.
c)
Discuss how the effects of the failure of non-seismic Category I equipment, structures or components on safety-related portions of the CCWS and SWS are considered.
Chapter 9 9.1 GDC 60, " Control of Releases of Radioactive Materials to the Environment,"
j requires that the nuclear power unit design shall include means to control.
q the release of radioactive materials in gaseous and liquid effluents and I
to handle radioactive solid wastes produced during normal reactor operation,
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including anticipated operational occurrences. Sufficient holdup capacity shall be provided for retention of gaseous and liquid effluents containing radioactive materials, particularly where unfavorable site environmental conditions can be expected to impose unusual operational limitations upon the release of sech effluents to the environment.
SRP 9.4.3, " Auxiliary and Radwaste Area Ventilation System," provides the guidance for the design of the HVAC systems to meet requirements of GDC 60.
Discuss how the HVAC systems for the ALWR-RD radiological access control building, radwaste facility and hot machine shop will conform with each of the guidelines of SRP Sections 9.4.3 and 11.3.
9.2 With regard to the general requirements for HVAC systems which related to SRP Section 7.3 and in accordance with SRP Section 6.5.1, describe how appropriate instruments should be provided to indicate fan operating status, isolation damper positions, filter pressure drop, chilled watt flow, loss of air flow to essential equipment, etc.
9.3 Discuss how the turbine building ventilation system will satisfy each of the guidelines described in SRP Section 9.4.4, " Turbine Area i
i ventilation System."
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~2-9.4 EPR'I specifies that the PWR reactor containment, control rod drive mechanism,
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and reactor cavity cooling ventilation. systems shall be designed as non-safety related and non-seismic Category I systems. During the plant specific licensing process, we will require the applicants for plants referencing the ALWR-RD design to provide analysis to demonstrate that the failure of these systems will-not effect safety-related equipment.
Address the generic implications of these classifications and provide an interface requirement which addresses them.
9.5 With regard to containment purge system, discuss how each of the guidelines as described in the Branch Technical Position, CSB 6-4,
" Containment Purging During Normal Plant Operation," will be satisfied.
9.6 Provide justifications for not providing charcoal adsorbers and down-stream HEPA filters in accordance with RGs 1.52 and 1.140, or provide requirements for having these components in accordance with SRP Sections 6.5.1, 9.4.1, 9.4.2, 9.4.3, 9.4.4, 9.4.5, and 11.3.
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ENCLOSURE-f REQUEST FOR' ADDITIONAL INFORMATION EPRI-ALWR. CHAPTER 9 SITE SUPPORT SYSTEMS, ADVANCED LIGHT. WATER REACTOR REQUIREMENTS DOCUMENT l
471.12 Paragraph 2.2.4, " Radiation. Exposure" should also describe the need
' for the' selection of radiation-damage-resistant materials for use-in high radiation areas as it can reduce the need for frequent replace-ment and thereby reduce personnel radiation exposure.
l 471.13 The need for radiation zoning and access control during plant operation, refueling and accident conditions should be stated in accordance with the guidelines of Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable."
The EPRI-ALWR Requirements Documents should also describe following subjects:
471.14 Area and airborne radioactivity monitoring instrumentation requirements in accordance with the guidelines of Regulatory-Guide 8.8.
471.15 TMI Action Plan Requirements in accordance with NUREG-0737. Item II.B.2 t
471.16 Compliance with 10 CFR 20 " Standards For Protection Against Radiation," and if exception (s) are contemplated acceptable alterna-tivemethod(s)shouldbeproposed.
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ENCLOSURE PLANT SYSTEMS BRANCH REQUEST FOR ADDITIONAL INFORMATION EPRI ALWR REQUIREMENTS DOCUMENT CHAPTER 12 RADIOACTIVE WASTE PROCESSING SYSTEM 12.1 (Chapter 12, General) SRP Sections 11.2, 11.3 and 11.4 provide as acceptance criteria the use of the regulatory positions of RG 1.143 as it relates to the seismic design and quality group classification of components in the liquid, gaseous, and solid radioactive waste processing systems and structures housing these systems and provisions to control leakages.
Identify and justify all deviations from these acceptance criteria; otherwise, provide for design in compliance with the RG 1.143 position (s).
12.2 (Chapter 12, Section 1.5) SRP Sections 11.2 and 11.3 provide specific acceptance criteria regarding the inclusion in the radwaste treatment systems of all items of reasonably demonstrated technology that can reduce population doses for a favorable cost-benefit ratio.
Identify and justify all deviations from these criteria; otherwise provide for compliance with these criteria.
12.3 (Chapter 12, Section 1.5) Justify inconsistencies and deviations of Table 12.1-1 and relevant text from the source term methodology provided in NUREG-0016, NUREG-0017 (Revision 1), BTP ETSB 11-5 of SRP Section 11.3, and SRP Section 15.7.3.
Clarify the respective meanings of the terms "radwaste and shielding" and "systen operational performance evaluation" used as headings in the table. Clarify whether the BTP ETSB 11-5 releases are intended to be included in the meaning of the heading "FSAR Chapter 15."
12.4 (Chapter 12, Sections 3.1.1,3.1.2.4,3.1.2.5,andB.I.2.3)SRPSec-tion 11.3. II.A.4 provides as an acceptance criterion that the gaseous radioactive waste treatment system design meets the requirements of GDC 60 as it relates to the radioactive waste managemnt systems being designed to control releases of radioactive materials to the environ-ment. RG 1.140 provides that consideration should be given to the installation of HEPA filter banks downstream of carbon adsorbers to retain carbon fines from the adsorber.
In Sections 3.1.1, 3.1.2.4, and 3.1.2.5 it is stated, respectively, that the gaseous radioactive waste processing system (GRWPS), the BWR turbine steam seal off-gas system, and the BWR mechanical vacuum pump off-gas system discharges are transferred to a plant vent which is part of the HVAC system described in Chapter 9 of the EPRI ALWR Requirements Document.
Furthermore, in Section B.1.2.3 it is stated that HEPA exhaust filters are eliminated from the GRWPS to reduce the volume of radioactive wastes. Chapter 9, however, does not list (Section 8.1.3) the items above as primary interfaces of the HVAC, whereas other Chapter 12
-2 systems are listed, i.e. radwaste drain system and non-radioactive waste drain system.
Furthermore, these interfaces are not identified -
in Section 8.2.1 (of Chapter 9), which describes.the various HVAC systems. Clarify how these gaseous radioactive wastes are transferred to the plant vent via appropriate HVAC systems and.how HEPA filtration is provided prior to discharge; otherwise, justify not providing HEPA filtration for-the reasons stated in RG. 1.140.
12.5 (Chapter 12, Sections 3.2.3.1 and 3.4.1.1, Table 12.3-1) SRP Section 11.3.II.B.6 provides specific acceptance criteria regarding protection; to gaseous waste handling.and treatment systems from the effects of an-
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explosion of hydrogen and oxygen (GDC 3).
Identify and justify all deviations from these specific acceptance criteria; otherwise provide i
for compliance with these criteria.
1 12.6 (Chapter 12, Sections 3.3.1 and 3.3.2): SRP Section 11.3.II.A.4 provides as an acceptance criteria that the gaseous radioactive waste treatment system design meets the requirements of GDC 60 as it relates to the radioactive waste management systems being designed to control releases of radioactive materials to the environment.
In Section 3.3.1.5 it is stated that, for the BWR system, multiple charcoal adsorber beds shall be arranged so that they can all be bypassed via a bypass bed. This t
permits bypassing in the event of process upsets. However, in Section
'1 3.3.2.3 it is stated that, for the PWR system, a minimum of two charcoal adsorber beds, in addition to a guard bed, shall be provided with inter-connections to bypass any bed. This provides operational flexibility to permit continued operation.in the event of operational upsets..
Figure 12.3-2 is a schematic diagram of this PWR system. Clarify differences between the description of the PWR system and the system described in the figure. Justify, for the PWR system, the design to provide bypass via no bed; otherwise, provide for bypass via a bypass bed as with the BWR system.
12.7 (Chapter 12, Sections 5.2.2.5.1 and 5.3.2.4) SRP Section 11.4 provides as an acceptance criterion-that the solid radioactive waste treatment i
system design meet the' requirements of 10 CFR Part 71 as it relates to radioactive material packaging.
In Sections 5.2.2.5.1 and 5.3.2.4 it is stated that the wet and dry (respectively) solid waste processing systems shall be capable of producing a product that satisfies the i
product form requirements of 10 CFR Part 61, pertinent state regulations, and disposal site requirements. Provides design requirements for meeting the requirements of 10 CFR Part 71.
12.8 (Chapter 12, Section 5.2.2.5.3) SRP Section 11.4, BTP ETSP 11-3.11.1 provides that, for solidification or dewatering as appropriate, the equipment, procedures, solidification agents, and potential wet waste constituents should be tested to provide assurance that the appropriate waste form requirements can be met.
In Section 5.2.2.5.3 it is stated 1
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the plant designer shall define a test program for new process equip-ment and different waste forms. However, the designer may substitute a definition of the results of operating experience for performance l
testing where the process equipment and waste types are identical to
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I that employed at operating plants. Justify not testing potential waste constituents for each batch of waste prior to processing, or provide this requirement consistent with SRP Section 11.4.
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4 ENCLOSURE i
REQUEST FOR ADDITIONAL INFORMATION EPRI ALWR CHAPTER 13 MAIN TURBINE - GENERATOR SYSTEMS MATERIALS ENGINEERING BRANCH DIVISION OF ENGINEERING AND SYSTEM 5 TECHNOLOGY
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Paragraph 3.3.1.1.1.11 discusses the design of turbine disk rotors. EPRI should follow SRP 10.2.3, " Turbine Disk Integrity". which provides specific guidelines on fracture toughness, material selection, inservice and preservice inspections, and design of the low pressure turbine disk rotors.
Paragraph 3.3.1.1.1.14 states that " turbine orientation and placement shall be such that low trajectory missiles resulting from turbine failures will not damage essential plant systems". The staff has specific failure probability require-ments on turbine missile generation and turbine orientation. The following failure probability requirements should be included in the EPRI-ALWR Requirements Document:
Regulatory Guide 1.115, " Protection Against Low-Trajectory Turbine Missi -
l les," states that the probability of unacceptable damage to safety-related, systems and components due to turbine missiles should be'less than 10-7 per year.
In recent years the staff has placed review emphasis on preven-1 tion of the turbine missile generation from the failure of the low pres-sure turbine disks. The applicant should demonstrate that the failure probability of missile generation from a favorably oriented turbine is-less than 10~4 per reactor year and for an unfavorably oriented turbine, 10-5 per reactor. year. A turbine is favorably oriented if any plane perpendicular to the turbine-generator axis is not intersect with the primary containment structure. EPRI has committed to a favorable turbine orientation as described in Paragraph 4.5.2.3, Chapter 6, of the Require-ments Document. Aside from Regulatory Guide 1.115, EPRI should also follow guidelines in SRP 3.5.1.2 and 3.5.1.3.
1 Paragraph 3.3.1.2 discusses maintenance of the main turbine and its related systems.
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The staff requires the applicant to do the following to assure the integrity of the low pressure turbine disk rotors:
a) submit for NRC. approval, within three years of obtaining an operating.
license, a turbine system maintenance program based on the manufacturer's calculations of missile generation probabilities, or b) volumetrically inspect all low pressure turbine rotors at the second refuel-ing outage and every other (alternate) refueling outage thereafter until a maintenance program is approved by the staff; and conduct turbine steam valve maintenance, (following initiation of power output) in accordance with present NRC recommendations as stated in SRP 10.2.3.
Paragraph 3.3.1.2 should include the above two requirements in the Requirements Document.
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