NSD-NRC-97-5263, Forwards W Responses to Comments on AP600 TS Re Containment Sys.Response to Question 68 Re TS 3.6.9 for Ph Adjustment, Is Still in Progress W/Completion Scheduled for 970825
| ML20210P284 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 08/19/1997 |
| From: | Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210P291 | List: |
| References | |
| NSD-NRC-97-5263, NUDOCS 9708270048 | |
| Download: ML20210P284 (103) | |
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ns wspaaa m30 03n DCP/NRC0981 NSD-NRC-97-5263 Docket No.: 52-003 August 19,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 70555 NITENTION: T. R. QUAY SUDJECT:
RESPONSE TO NRC SCSD COMMENTS ON CONTAINMENT SYSTEMS TECilNICAL SPECIFICATIONS
Reference:
Letter from NRC to Westinghouse, " Comments on the AP600 Technical Specifications (TS) Related to Containment Systems", dated May 15, 1997.
Dear Mr. Quay:
Attached are the Westinghouse responses to all but one of the referenced letter comments on the AP600 Technical SpeciGcations. The attachment includes a comment index, the comments and responses, and a markup of affected Technical Specifications to renect the responses. The response to question 68, related to TS 3.6.9 for pil adjustment, is still in progress with completion scheduled for August 25.
With this submittal, the Westinghouse status for Open item Tracking System item 5357 remains
" Action W" to respond to question 68 with the understanding that it is NRC's action to review and respond to the attached responses.
If you have any questions regarding this submittal or the AP600 Technical Specifications, please contact Robin K. Nydes at 412474-4125.
r h. ' f Brian A. McIntyre, Manager i
Advm.ced Plant Safety and Licensing
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W. C. IlufTman, NRC (w/ Attachment)
N. J. Liparulo, Westinghouse (w/o Attachment) um wn jggjl.
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'4, 9-CONTAINMENT AND SEVERE ACCIDENT BRANCH COMMENTS CONCERNING
- WESTINGHOUSE AP600 TECHNICAL SPECIFICATIONS
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (1) 3.3.2-ESFAS Instrumentation, Applicable Modes, Action, Setpoint (2)-
3.6.1 Containment, Applicability (3) 3.6.1 Coutalement, BASES LCO (4) 3.6.1 Containment, Purge valves are metal seated (5)
. 3.6.1 Containment, Option B (6) 3.6.1 Containment, BASES (7) 3.6.2 Air Locks, LCO Actions Note #1 (8) 3.6.2 Air Locks, Required Action A.1 and A.2 (9) 3.6.2 Air Locks, Condition B r
(10) 3.6.2 Air Locks, Applicability (11) 3.6.2 Air Locks, SR 3.6.2.1 (12) 3.6.2 Air Locks, SR 3.6.2.1, Note #1 (13) 3.6.2 Air Locks, SR 3.6.2.2 (14) 3.6.2 Air Locks BASES SR 3.6.2.1 (15) 3.6.2 Air Locks BASES SR 3.6.2.1 (16) 3.6.2 Air Locks BASES, References (17) 3.6.3 Containment Isolation Valves, LCO Actions Note #3
-(18) 3.6.3 Containment Isolation Valves, Note 4 (19) 3.6.3 Containment Isolation Valves, Condition A (20) 3.6.3 Containment Isolation Valves, Required Action A.2 (21) 3.6.3 Containment Isolation Valves, Required Action C.1 (22) _ 3.6.3 Containment Isolation Valves, Condition D (23) 3.6.3 Containment Isolation Valves, SR 3.6.3.1 (24) 3.6.3 Containment Isolation Valves, Surveillance Requirements (25) 3.6.3 Containment Isolation Valves, Surveillance Requirements (20) 3.6.3 Containment Isolation Valves, BASES, References (27) 3.6.4 Containment Pressure, LCO (28) 3.6.4 Containment Pressure, Condition B (29) 3.6.4 Containment Pressure, BASES, Applicable Safety Analyses (30) 3.6.5 Containment Air Temperature, LCO Statement (31) 3.6.5 Containment Air Temperature, Condition B (32) 3.6.5 Containment Air Temperature, BASES, Applicable Safety Analyses (33) 3.6.6 Passive Containment Cooling System (PCS). Operating, Condition A (34) 3.6.6 Passive Containment Cooling System (PCS). Operating (35) 3.6.6 Passive Containment Cooling System (PCS) - Operating, Condition C (36) 3.6.6 Passive Containment Cooling System (PCS) Operating, Additional Features (a)
Bucket (b)
Weirs (c)
Inorganic zine paint (d)
Makeup to the spent fuel pool (e) -
Post 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> designs changes (O
PCS air flow path (g)
Surveillance of the annulus drains (h)
Freezing
AP600 TECHNICAL SP50CIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
._.m_.
(37) 3.6.6 Passive Contalriment Cooling System (PCS) Operating, Condition C (38) 3.6.6 Passive Containment Cooling System (PCS) Operating, Condition D (39) 3.6.6 Passive Containment Cooling System (PCS) Operating, SR 3.6.6.1 (40) 3.6.6 Passive Containment Coollag System (PCS) Operating, SR 0.6.6.3 (41)'
3.6.6 Passive Containment Cooling System (PCS) Operating, SR 3.6.6.4 (42) 3.6.6 Passive Containn ent Cooling System (PCS) Operating, SR 3.6.6.5 (43) 3.6.6 Passive Containment Cooling System (PCS) Operating, Bases,
Background
(44) 3.6.6 Passive Containment Cooling System (PCS) Operating, BASES -
Applicable Safety Analyses (45) 3.6.6 Passive Containment Cooling System (PCS) - Operating, BASES.
Applicable Safety Analyses (46) 3.6.6 Passive Containment Cooling System (PCS) Operating, BASES, Action B.1 (47) 3.6.6 Passive Containment Cooling System (PCS) Operating, SR 3.6.6.6 (a)
PCCWST drain lines (b)
Flow test (c) 10 year surveillance period (48) 3.6.7 Passive Containment Cooling System (PCS) Shutdown (49) 3.6.7 Passive Containment Cooling System (PCS) Shutdowm, BASES, Applicability (50) 3.6.7 Passive Containment Cooling System (PCS) Shutdown, BASES, Background and Applicable Safety Analyses (51) 3.6.7 Passive Containment Cooling System (PCS) Shutdown, Condition D?
(52) 3.6.7 Passive Containment Cooling System (PCS) Shutdown, References (53) 3.6.8 Containment Penetrations, Justification for this LCO (54) 3.6.8 Containment Penetrations, Closure capability (55) 3.6.8 Containment Penetrations, Bases, Applicable Safety Analyses (56) 3.6.8 Containment Penetrations, BASES LCO (57) 3.6.8 Containment Penetrations, Time After Shutdown (58) 3.6.8 Containment Penetrations, Fuel handling accident (59) 3.6.8 Containment Penetrations, LCO Statement b (60) 3.6.8 Containment Penetrations, LCO Statement d.2 (61) 3.6.8 Containment Penetrations, Condition B (62) 3.6.8 Containment Penetrations, SR 3.6.8.3 (63) 3.6.8 Containment Penetrations, No SRs for air locks, spare penetrations, or equipmentis properly staged.
(64) 3.6.8 Containment Penetrations, Bases, Background
' AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (65) 3.6.9 pN AWustment, SR 3.6.9.1 (66) 3.6.9 pH Adjustment, Condition B (67) 3.6.9 pH A4ustment, Condition B (68) 3.6.9 pH Adjustment, Chemical quality (69) 3.6.9 pH Adjustment, References (70) 3.6.9 pH Adjustment, BASES (71) 3.6.9 pH Adjustment, Completion times (72) 3.6.10 Hydrogen Recombiners, Bases (73) 3.6.10 Hydrogen Recombiners, APPLICABLE SAFETY ANALYSES (74) 3.6.10 Hydrogen Recombiners, Steam line break (75) 3.6.10 Hydrogen Recombiners, SR 3.6.10.2 (76) 3.6.10 Hydrogen Recombiners, Surveillance frequency
' (77)
Missing NUREG 1431 LCOs, Hydrogen Ignition System (STS LCO 3.6.10)
- (78)
Vacuum Relief System (STS LCO 3.6.12), Justification for deletion (79)
Shield Hullding (STS LCO 3.6.19), Justification for deletion (80) 5.5 Programs and Manuals, PCS surveillance program w
AP600 TECIINICAL SPECIFICATIONS WESTINGIIOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
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(1) 3.3.2 ESFAS Instrumentation NUREG 1431 c,ontains an LCO 3.3.6, " Containment Purge and Exhaust isolation Instrumentation," which has been moved to LCO 3.3.2, "ESFAS Instrumentation," in the AP600 TSs. The TS was moved because the instrumentation is not separate from ESFAS as in operating Westinghouse plants. LCO 3.3.6 of NUREG 1431 is applicable during Modes 1,2,3, and 4, during core alterations, and during movement ofirradiated fuel assemblies within containment. The BASES for LCO 3.3.6 state that the containment porge and exhaust isolation radiation monitors act as backup to the SI signal to ensure closure of the purge and exhaust valves. The radiation monitors are also the primary means for automatically isolating containment in the event of a fuel handling accident during shutdown.
Function 19, " Containment Air Filtration System Isolation," of Table 3.3.21, of the AP600 TS addresses isolation of the Containment Air filtration System upon receipt of a high containment radioactivity signal. This isolation capability is covered by LCO 3.3.6 in NUREG 1431. Function 19 is only applicable in Modes 1,2,3 as opposed to Modes 1 through 4 and during fuel movement in LCO 3.3.6. Function 19 requires 3 out of 4 channels operable and, with one required channel inoperable, returning r.n inoperable channel to operable in 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />. LCO 3.3.6 requires a f
gaseous, - particulate, an iodine and an area containment radiation monitor to be operable and, with one of the four channels inoperable, returning an inoperable channel to operable within four hours. The Nominal Trip Setpoints and Completion Times, between the two LCOs, are also different. LCO 3.3.6 is twice background while Table 3.3.21 is less than or equal to 2 R/hr. SCSB does not believe that LCO 3.3.6 of NUREG 1431 has been adequately reflected in the AP600 TSs. The ditTerences identified above need to be justified.
Response
Applicable Modes Comment ' Function 19 is only applicable in Modes 1,2,3 as opposed to Modes 1 through 4 and during fuel movement in LCO 3.3.6.*
AP600 accident analyses only take credit for containment air filtration system isolation for events occurring in MODES 1,2, and 3. In contrast to plants represented by the STS requirements, no credit for air filtration system isolation is taken for AP600 events in MODE 4 or during fuel movement.
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APC00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS 3.3.2 ESF' S Instrumentation (Response continued)
A (1)
Action for one Channel Inoperable Comment 'LCO 3.3.6 requires a gaseous, a particulate, an iodine and an area containment radiation monitor to be operable and, with one of the four channels inoperable, returning an inoperable channel to operable within four hours'.
The STS (NUREG 1431 Rev.1) Bases for LCO 3.3.6 Action A.1 (one channel inoperable) state that " failure of a single channel may result in loss of the radiation monitoring Function for certa 5 events". Therefore, the STS requirements apply to a design for which all four radiation (gaseous, particulate, iodine and area) channels must be operable, without a single failure, to perform the safety function assumed.
The IP600 design provides four identical radiation monitorang channels. With only twc operable channels, the AP600 design is fully capable of maintaining the assumed radiation monitoring function for all events even with a single failure.
The STS LCO 3.3.6 precedents do not apply to AP600 due to design differences.
Scipoint Comment 'The Nominal Trip Setpoints and Completion Times, between the two LCOs, are also different. LCO 3.3.6 is twice background while Table 3.3.2 1 is less than or equal to 2 Rlhr'.
The bracketed typical value listed in STS Table 3.3.21 is not applicable to AP600.
The setpoint value listed for AP600 Function 19.a, Containment Radioactivity -
High 1, is the value assumed in safety analyses for isolation of the Containment Air Filtration System. As stated in the AP600 Table 3 3 21 reviewer notes, the actual AP600 setpoint will be calculated using an approved methodology, taking into account the as built equipment and conditions.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
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(2) 3.6.1 Containment Westinghouse bas renamed " HOT STANDBY" as " SAFE SHUTDOWN" and changed the temperature range from 200 350 'F to 200-420 'F. The proposed TS 3.6.1 is confusing. It requires that the containment be operable in Mode 4, but ifit isn't, the required ACTION is to go to Mode 4. This makes no sense! The applicability of this TS in Mode 4 needs to be clarified. Ifit is not applicable in Mode 4, it needs to be analytically justified.
Response
AP600 Actions for LCOs 3.6.1, 3.6.2, 3.6.3, 3.6.4, 3.6.5, 3.6.6, and 3.6.9, which are applicable in Modes 1 4, will be revised to specify Mode 5 as the Action end state.
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AP600 TECHNICAL BPECIFICATIONS l
WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (3)- 3.6.1 Containment 4
BASES 3.6.1, LCO, first paragraph: The text " leakage testing" was not incorporated as detailed in accordance with the Appendix J, Option B Model STS.
i
Response
The text " leakage test" will be added in accordance with the proposed Option B model changes to NUREG 1431, Revision 1, included in Standard Technical Specification Change Traveler, TSTF-52. The revised paragraph will read as follows:
Containment OPERABILITY is maintained by limiting leakage to s 1.0 L,
except prior to the first startup after performing a required Containment
- Leakage Rate Testing Program leakage test. At this time, the applicable leakage limits must be met.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (4) 3.6.1 Cont'ainment According to the P&ID (SSAR Fig 9.4.71, Note 11) for the Containment Air Filtra-tion System the purge valves t te metal-seated. Thus there is no need to refer to resilient-seated purge valvea '.) BASES SR 3.6.1.1. Westinghouse should explain the reason for the reference to resilient seat valves in the 3.6.1 LCO BASIS.
Response
The last paragraph in the LCO section of the Bases will be revised to eliminate the reference to purge valves with resilient seals and to incorporate the proposed Option B model changes to NUREG 1431, Revision 1, included in Standard Technical Specification Change Traveler, TSTF 52. The revised paragraph will read as follows:
Individual leakage rates specified for the containment air lock (LCO 3.6.2) are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J, Option i
B. Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0 L,.
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AP600 TECHNICAL SPECIFICATIONS l-
_ WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (5) 3.6.1 Cont'alnment SSAR 6.2.5.1, Design Basis (for Containment Lenk Rate Test System), states "The system design accommodates the test methods and frequencies consistent with requirements of 10 CFR Part 50 Appendix J, Option A or B". The NUREG 1431 is developed based upon Option A only. There is a Model STS for converting only to the Option B method. There are no STS models for accommodating Option A and B, concurrently. Most recent licensee technical specification amendments are proposing to convert to the Option B. The AP600 STS should also be developed accordingly.
Westinghouse has been asked to reconsider the Exemptions List of Table 6.2.5-1, It is the NRC position that Appendix J Exemptions will have to bo specifically requested by COL applicants they should not be written into the Design Certifica.
tion Rule.
Response
SSAR section 6.2.5 will'oe revised to indicate the selected Option B testing per Appendix J Containment Leakrate testing.
The AP600 Technical Specifications will continue to specify Option B requirements.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (6) 3.6.1 Cont'ainment The BASES text indicates a 4.5 foot annulus space. There is a bame in the annulus that creates the air ilow path (-3 ft between shield building and bame, the downcomer, and -1 % ft between bame and containment vertical shell, the riser). The bame is sectional and removable for inspection of the steel shell and dome. Based on the description provided,it could appear that the bame is a ilow obstruction.
Response
The LCO 3.6.1 Bases, Background section does not discuss the containment cooling flow path or the bame. The Bases discussion is limited to a general description of the containment design with emphasis on features related to containment leakage.
The containment cooling flow path and bame are described in the Bases for LCO 3.6.0, Passive Containment Cooling System - Operating. The LCO 3.6.6 Bases clearly describe the bame as a functioning part of the design, not a flow obstruction.
The LCO 3.6.1 Bases are adequate as is, i
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (7)- 3.6.2 Air Locks LCO Actions N,ote #1: This word change from "on" to "of" does not appear to clarify the intent of the Action Note. Westinghouse has not justified this change. For the sake of consistency, please retain the wording preference of NUREG 1431.
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Response
"Of" will be changed to "on" consistent with NUREG 1431, Revision 1.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC. QUESTIONS AND COMMENTS (8) 3.6.2 Air Locks Required Actio.n A.1 and A.2: This appears to be a typo. The Logical Connector M is missing between Required Action A.1 and A.2.
Response
The Logical Connector M will be added between Required Action A.1 and A.2.
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l AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (9) 3.6.2 Al'r tecks Condition B: There are four proposed changes in wording which do not appear to
- clarify the intent of this Condition. Westinghouse has not justified any of these changes. For the sake of consistency, please retain the wording preference of NUREG 1431, 1
Response
i The wording differences will be revised as follows to be consistent with NUREG.
1431, Rev.1:
1.
Required Actions B.1, B.2, and B.3 are not applicable if both doors in the same air lock are inoperable and Condition C is entered.
B.2 Lock an OPERABLE door closed in each the affected air lock.
B.3 Verify an OPERABLE door is locked closed in eeeh the afTected air lock.
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AP600 TECHNICAL SPECIFICATIONS
- WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
- (10)- 3.6.2 Air iocks
)
i Consistent _with comment (2) above, the General Design Criteria (GDC), and the containment safety function, containment integrity should be required for all plant conditions for_which a LOCA is postulated. Westinghouse will either need to change the required action end stato for this LCO to Mode 5 or justify why it is not applicable in Mode 4.
Response
- AP600 Actions for LCOs 3.6.1, 3.6.2, 3.6.3, 3.6.4, 3.6.5, 3.6.6, and 3.6.9, which are applicable in Modes 1 4, will be revised to specify Mode 5 as the Action end state, i
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d AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (11) 3.6.2 Air Iecks SR 3.6.2.1: Th,1,s Frequency Note stating "3.0.2 is not applicable" is a legitimate requirement. : Ira accordance with the Appendix J, Option B Model STS, this note has been relocated to Section 5.0 as a part of the description of the Containment Leakage Rate Te: ting Program. See Section 5.5.9. Also,in Note #2,in accordance with the Option B Model STS,"of' must be replaced with " applicable to".
Response
The SR 3.0.2 Frequency Note will be deleted and Note 2 will be revised in accordance with the proposed Option B model changes to NUREG 1431, Revision 1, included in Standard Technical Specification Change Traveler, TSTF.52. Note 2 will be revised as follows:
2.
Results shall be evaluated against acceptance criteria of applicable to SR 3.6.1.1.
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AP600 TECHNICAL SPECIFICATIONS WESTINGnOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (12) 3.6.2 Air locks SR 3.6.2.1, Note #1: A new word " associated" has been inserted to describe the overall air lock ~ leakage test. The addition of" associated" does not improve the wording of this note. The BASES do not explain this change. This change has not j
been justified by Westinghouse. There appears no reason to change the current NUREG-1431 text.
1
Response
i Note 1 will be revised to be consistent with NUREG 1431, Revision 1 and with tho proposed Option B model changes to NUREG 1431, Revisicii 1, included in Standard
)
Technical Specification Change Traveler, TSTF 52. Note 1 will be revised as follows:
1.
An inoperable air lock door does not invalidate the previous successful performance of the aseeeiated overall air lock leakage test.
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AP600 TECIINICAI, SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (13) 3.6.2 Air Locks SR 3.6.2.2, Note: This appears to be a typo, " Air lock" is two words,
Response
" Air lock" in the SR 3.6.2.2 Note will be corrected as follows:
Only required to be performed upon entry or exit through the containment air lock.'
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (14) 3.6.2 Air iacks Bast,5 5R 3.6,2.1, first paragraph: 'In the second sentence, the word " rate" has been deleted and " regard" has been substituted for " respect". 'Also, the third sentence has been deleted. For the sake of consistency with the NUREG 1431 and tha Appendix J, Option B, Model STS, please retain the STS text.
BASES SR 3.6.2.1, first paragraph: 81n the third sentence, the text deletions and additions have changed the meaning so that it implies the airlock has a higher allowed leakage rate than the STS allows. This is not acceptable. Please retain the requirement as is written in NUREG 1431, T
BASES SR 3.6.2.1, first paragraph: 'In accordance with the Appendix J, Option B Model STS, in the fourth sentence, the words " Appendix J" and "as specified in" should be removed. 'Also, the fifth sentence should be removed to be in accordance with the Appendix J, Option B Model STS.
Response
The Bases SR 3.6.2.1, first paragraph requested AP600 changes will be made as follows:
1.
This SR reflects the leakage rate testing requirements with regard regeet to air lock leakage (Type B leakage tests).
?..
The acceptance criteria were established during initial air lock and containment OPERABILITY testing.
3.
The periodic testing requirements verify that the air lock leakage does not result in cNeeeding exceed the allowed fraction of the overall containment leakage rate.
4.
The Frequency is as required by Appendi J, ac apecified... the Containment Leakage Rate Testing Program.
5.
Thua, SR 3.0.2 Pe hich a!!cre Frequency c:tencianabdcen act apply.
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AP600 TECHNICAL SPECIFICATIONS -
WESTINGHOU8E RESPONSES TO NRC QUESTIONS AND COMMENTS (15) 3.6.2 - Air iocks BASES SR 3.631, second paragraph: The SR 3.6.2.1 refers to "the" and not to "an" overall air lock test. There is no justification for this change. Please retain the text as intended by the NUREG 1431.
BASES SR 3.6.2.1, second paragraph: The changes required to Noto #2 were not incorporated as required to be in accordance with the Appendix J, Option B Model STS. Please change this text.
Response
The Bases SR 3.6.2.1, second paragraph requested AP600 changes will be made as follows:
Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of an the overall air lock leakage test.
Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of applicable to SR 3.6.1.1.
This ensures that air lock leakage is properly accounted for in determining the overaH combined Type B and C containment leakage rate.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (16)- 3.6.2 Al'r Locks BASES,
References:
In accordance with the Appendix J, Option B Model STS, the
" Option B" is identified with Appendix J.
Response
Bases 3.6.2, Reference 1 will be changed to specify Option B as follows:
1, 10 CFR 50, Appendix J, Option B, " Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors, Performance Based Requirements."
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (17)- 3.6.3 Conialraent Isolation Valves l
LCO Actions N.ote #3: The addition of the word " supported" appears to limit the
)
number of systems which have to be declared inoperable. - This is not discussed in j
the BASES. This is not justified by Westinghouse. There uppears to be no basis for j
this change. Please retain the text as written in NUREG 143L j
Response
LCO 3.6.3, Actions Note 3 will be revised as requested:
3.
Enter applicable Conditions and Required Actions for supported systems made inoperable by containment isolation valves.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (18) 3.6.3 Con'tainment Isolation Valves Note 4, The words " acceptance criteria" should be added to the end of this Note for consistency with NUREG 1431 and terminology used in the Containment Leakage Rate Testing Program and applicable SRs. Also, the Note #3 of LCO 3.6.2 should be mado equally consistent.
Response
LCO 3.6.3, Actions Note 4 and LCO 3.6.2, Actions Note 3 will be revised es requested:
Enter applicable Conditions and Required Actions of LCO 3.6.1, " Containment,".
when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.
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AP600 TECHNIC AL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
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(19) 3.6.3 Containment Isolation Valves Ccadition A, Note: The word "those" has been added but there is no Westinghouse justification for this change. Please leave text as is written in NUREG 1431.
Response
LCO 3.6.3, Condition A Note will be revised as requested:
Only applicable to these penetration flow paths wjth two containment isolation valves.
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AP600 TECHNICAL SPECIFICATIONS WESYINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
- (20) 3.6.3 Containment Isolation Valves Required Action A.2: The word "each" is proposed to be substituted for "the" This change is redundant and unnecessary because Actions Note #2 explicitly states this action is for each affected flow path. There is no Westinghouse technical basis provided for this change. Therefore, please leave text as is written in NUREG 1431.
Response
LCO 3.G.3, Required Action A.2 will be revised as requested:
Verify each the affected penetration flow path is isolated.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIOh8 AND COMMENTS
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'(21) 3,6.3 Containment Isolation Valves
~
Required Actiop C.1: It is assumed this is a typo because most other locations this word is hyphenated which is the preference of the NRC STS Style Guide.
Response
LCO 3.6.3, Required Action C.1 will be revised to include the hyphen:
Isolate the affected penetration flow path by use of at least one closed and de activated automatic valve, closed manual valve, or blind flange.
- we 22 f
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (22) 3.6.3 Containment Isolation Valves For Condition D of this LCO, Westinghouse must either go to Mode 5 or justify why the LCO is not applicable in Mode 4 similar to comment (2) above.
Response
AP600 Actions for LCOs 3.6.1, 3.6.2, 3.6.3, 3.6.4, 3.6.5, 3.6.6, and 3.6.9, which are applicable in Modes 1 4, will be revised to specify Mode 5 as the Action end state.
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AP600 TECHNICAL SPECI."lCATIONS WESTINGHOUSE RESPONSE 3 TO NRC QUESTIONS AND COMMENTS (23) 3.6.3 Containment Isolation Valves Sit 3.0.3.1: This SR has been edited in a way which changes the meaning and is different from the BASES. After "ALARA", the "or" was deleted and a " comma" was inserted, it was intended that ALARA was to be joined to the " considerations for personnel entry" and not separated, as is created by this change. Please retain the wording of the NUREG 1431.
SR 3.0.3.1: NUREG 1431 SR 3.0.3.1 was deleted without Westinghnuse justification.
The AP600 standard design contains provisions for these large purge and supply valves. The APG00 purge valves are metal. seated with special sealing and testing provisions built into them. The NUREG.1431 surveillance requirement SR 3.6.3.1 1
should be retained so as to require a periodic verification that the valves are lenktight.
Response
The requested AP600 SR 3.0.3.1 change will be made as follows:
SR 3.0.3.1 Verify each (16 inch) containment purge valve is closed, except when the 116 inch) containment purge valves are open for pressare control, ALARA or air quality considerations for nereonnel containment entry, or for Surveillances which require le valves to be open.
The AP600 design coes ani include large purge valves, in the event it is determined from operating experience that large purge and supply valves are required, the AP000 design provides 3G inch penetrations which may be backfitted with the large valves. This design change would require appropriate imalyses, SSAR revisions and NRC approved Technical Specification changes. NUREG 1431 SR 3.6.3.1 would be added to the plant Technical Specifications at the time of the addition of the large purge and supply valves.
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APs00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
]
(24) 3.6.3 Con'ainment Isolation Valves t
NUREG 1431 SR 3.6.3.6 and SR 3.6.3.9: The STS contains two surveillance require-ments, SRs 3.6 3.6 and 3.6.3.9, for the weight or spring loaded check valves tested during operation and then at refueling. Westinghouse has not provided justifications to explain these deletions. Please explain this deletion?
Response
These surveillances are bracketed in NUREG 1431, indicating that they may not apply to all plants. The NUREG 1431 Bases (SR 3.6.3.6 and SR 3.6.3.9) note that the weight or spring loaded check valves are necessary in subatmospheric containment designs to provida positive closure in the direction of flow to ensure that the check valves will remain closed when the inside containment atmosphere returns to subatmospheric conditions following a DBA. These suneillances do not apply to AP600, since there are no containment isolation weight or spring loaded check valves.
44 8 aus u u 25
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NHC QUESTIONS AND COMMENTS
=... -
(25) 3.6.3 Con'tainment Isolation Valves NUREG 1431 SR 3.6.3.7: This STS surveillance requirement has been deleted from the AP600 TS. If the COL applicant selects purge valves designs or any other containment isolation valves which have resilient seals, then this SR 3.0.3.7 will apply. Westinghouse has not provided justifleations to explain these deletions.
Westinghouse should explain the NUREG 1431 deletion. Metal. seated valves that rely on inflatable seals for leaktightness should be included in TSs similarly to resil.
lently seated.
Hesponse Purge Valves This surveillance is bracketed in NUREG 1431, indicating that it may not apply to all plants. The AP600 design does not include purge valves with resilient or inflatable seals. The AP600 purge valves are metal seated valves typical of the valves described in the attached information.
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.0+ year design life Designed for severe service L
i
- Jidirectional tight shutoff Low maintenance Metal-to-metal seating Torque seated The permanent solution for butterfly valve problems.
1 M Low Pressure Industry Problems...
= ueu ermur.
W High Pressure l 99@
High Velocity Media Marine Induced Damage Seat Deformation Seat erosson and ht! out.
High refurbish costs frequent seat replacement.
@G@
Seat Deflection Elastomer Limitation Unpredictable Leakage m
l Position Seated Seat in Flow Path Factory Pepair Crewe corrosion cavities.
Costly marntenancG Retum to factory required.
l
_ _ _ _. _ _ - _ _, _ _. - ~ _
l TH E SOLUTION...
PERMASEAT 4 l O ANSI class VI Bidirectional Shutoff LARGE SEALING AREA
~
TRIPLE OFFSET
- 1..
CAMMING ACTION J
3
- Eliminates high seat
,4 f:
wear I
TORQUE SEATED Xir f,
I a Repeatable shutott f'I a Tolerent to temperature 4
j
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i SEAT Advanced Seat Technology RETAINED LAMINATED SS AND GRAPHITE S5AT RING i
. Crushes marine life
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- Seat wear compensating h,
. No schedukd maintenanco LAMINATED
\\
- No elastomors GRAPHITE
\\
j Extended EO life
& SS SEAT l
RING y
N SEAT RETAINED IN DODY
\\
+ Reduced seat errosion y
i
. Servicable on site
- Large sealing surfaces OVERSIZED, SINGLE PIECE SHAFT
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Ease of Maintenance I
ACCESSIBLE PACKING ACCESSIDLE SEAT
. In line serviceable
- j
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- No factory return S
i t
s
. No seat indexing
,\\
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a No disc or shaft removal i
l Year D.esign Life Valves SEALED OVERSlZED BEARINGS N
/
N/
GRAPHITE PACKING s
!N PRECISION MACHINED '
REGISTER DIAMETER
- Positive actuator abgnment 1
Tl I,a ACTUATION AVAILABLE:
~
PNEUMATIC, ELECTRO HYDRAULIC, ELECTRIC OR MANUAL l
PERMASEAT Standards and Codes Design, Fabrication, Testing Quality Assurance
. ASME Section ill Class 1,2,3
. ASME Section lit NCA 4000; N stamped
- ANSI B31.1, ANSI B16.34 ANSI /ASME NOA 1
. AWWA C504 face to face dimensions, 10 CFR Appendix B when specified.
PERMASEAT rotary disc shutoff valves are manufactured by Enertech under hcense froin Adams Armaturen.
i i
e m
r:..h, b Technical Data N
cm Flanged Style Valves L
ANSI pressure class:
150.300.600 900 g
C rp Size range:
3" to 48' i
C, (12* 150# esample)- 4810 gig Temperature range:
385: F to 10000 F 1
A _. _
Body materials:
Standard stainless steet. carbon steet A 2 14 Optional monel, titanium. hastelloy i
m Dise matenal.
Standard stainless steel
[ g[/
t Optional monel, titanium hastelloy
)
/
Seat ring matenal:
Standard - stainless steel, graphite faminate 3
Optional monet, titanium j
j i
Optional end connection: Butt weld or custom b
Wafer Style Valves ANSI pressure class:
150,300,600 Size range:
3" to 48' 3
,Ls C, (12" 150# example): 4810 1
/
Temperature range:
385' F to 1000' F h '$
Body matenals:
Standard stainless steel, carbon steel l
3,-
Optional monel, titanium. hastelloy l
Disc material:
Standard stainless steel l
Optional monel, t:1anium. hastelloy Seat ring matenal:
Standard stainless steel, graphite lam!nate Optional monel, titanium Optional end connection Butt weld or custom I
Double Flanged, High Temp. Style Valves
$)
ANSI pressure class:
150,300,600,900 4
l Size range:
6" to 120" C, (12* 150# example): 3730 I
yM Temperature range:
385' F to 1750' F l
1
.eW
- Body matenals:
Standard stainless steel, carbon steel
- ~
s Optional monel, titanium, hastelloy Disc matenal:
Standard stainless steel g,
s Optional monel, titanium hastelloy i s-Seat nng matenal:
Standard stainless steel, graphite laminate Or' Optional monel, titanium Optional end mnnection Butt weki or custom l
l A Tvolcal Solution..
G H. Betts actuators A leading east coast utmty were chosen to Q'
operate the l
solved its saltwater service h:'&
valves on saltwater stainless steeland erosion and corrosion problems monelPERMASEAT with the onstallation of 24 l
PERMASEA T valves with
[~p seryce.
n stainless steelbodies, monel l
d:scs and shafts.
.D r,C-
/
N. ;
hI i,
l Solutions for Today... Standards of Tomorrow v
7 - ' 7 T C T'l?" ~ 2950 Birch Street
- Brea, CaMornia 92621 U.S.A.
Call 714/528 2301
'993 ENERTECH f
Z 2
~ A FAX 714'528 0128 AL 5.,L A!G, HTS AESEM EC r - m
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4 PERMASEAT 8
Principles of Operation,,
I s
Tieple Offset Design i
~ '
The triple offset (design is a Iorque sealenq system whit h develf>ps a h
repeatable hidiec< tional ANSI Class Vi shutoff and near Int tionless seating I agure t illustrates thgemple ( amming at tion re3piteng in the dist hfling off the seat West between the seating elements is vitiually chmmated by
'C the ihr kne angles and elliptical seating system f igure ? ellustrates the i onet al dist edge and the disc in< tone angle SEAT N
CONE o
f egure 3 ellystrates the rammenq action
~
,I,,c, f ogur' 3 s
e
~
Cammeng arteon 4, e i.i: cfm cifge T'toical Acclications Optional Bldirectional Leak Verification LLRT Applications (10CFR 50, Appendix J) ft seated ut fly valves
{l
\\\\
F
' Gate valves Containment boundanes
- Purgelsolation Service water systems
- Salt /nver water
. High/ low pressure safety
(
u/
\\\\
L(
injection systems
- Component cooling
- Decay heat removal Condenser cooling water isolation low pressure steam isolation a
Suppression system isolation "N{#Q
+
SEM op q Extraction steam isolation EME O
Heat exchange isolation Rapid Leak Verification l
High temperature butterfly Preferred and Reverse
' p#cu$y, s
valve replacement Flow Directions s
Throttling apotications
PERMASEAT Principles of Operation lls Triple Of tsel Design
.L j-
~4 The triple ottset (d sign is a Iorque seating system what h develops a t
repeatable bidire< tional ANSI ClassNI shutott and near tric tionless seating 6
l ogure 1 ellusttales the simple ( amming at tion resulting m the dist lifting off the seat Weas between the seating elements is vitiually chmitwted by
'C the int line angles and elliptet al seatmgjystem a
f igure ? illust les the ( onical dest. edge and the dist int line an i e E
l Vm I ogure 3 ellusteates the ( amming at tion
~
f -. t i,
m
' fogure 3 Cammmg action A t ', w.,,a d~ ed ;c
~ ]ptional Bidirectional Leak Verification Tvolcal AccilCations LLRT Apphcations (10cFR 50, Appendix J) it seated ut fly valves
. Gate valves 1
\\\\
[{
- Containment boundaries
. Purgelsolation
. Service water systems
. Salt /nver water
. High/ low pressure safety injection systems
/
\\
- Component cooling I
\\\\
L
- Decay heat removal Condenser cooling water isolation Low pressure steam isolation
- Suppression system isolation o,gy4 sEn Extraction steam isolation EME O
- Heat exchange isolation Rapid Leak Verification l
,g
- High temperature butterfly Preferred and Reverse
,ge,r>cc$oy valve replacement Flow Directions
- Throttling acobcations
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Features Benefits Technical Data
. Metal-to metalseat
. Lesswear PressureClass.
ANSl150f,300f, & 600f
. Torque seated
..Not poshion sensh Size Range 6* through 120*
. Laminatedgraphite and C,(12'1500 example) 3730 l
SS seatring Broadservice range TemperWurs Range 385Tto 17507 i
l
. Triple offsetdaign
.. Throttling servios Body M.,94 Sabins stw(
Sandard
. Disc camming adion Frictionless seatirg
- " ""I
. One piece thaft
..No disc separation
. Overstred shaft
..No shaft deflection
~
anium, hastelloy
. Bdradonal LLRTapsbay Testablein line Disc Materials Standard
~
aninius Steel optonal Monel,ttanium, hastelloy Ring Seat Materials Standard Qualifications mainius geel Quality Amaurance Program
& graphitelaminate ASME Sealon lil-NCA 4000, ANSl/ASME NOA 1,
- w.,
.:Qgood 10CFR50 Appendix B,and 10CFR21 Monel, titanium or as req.
w Manufacturing Op00ns M vees are mandadued b anders wth the latmhg-N61 B31.1, ASE Sedon s Class 1,2,3,'tf samped Manual, pnarnde elsdotpade and eledm moty.
i
___..---___.__.________,..-__.__._____-.____.-__.____.____________________.__l
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'HVAC Fast cbsing & LLRT requirements
- ESWS Essential Service Water System O
CondenserCooiins iterisoiation w'
- Low Pressure Steam isolation
- Suppression System Isolation
- Extraction Steam Isolation 4
- Component Cooling Water
' High Temperature Butterfly Valve Replacement
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (26) 3.6.3 Con'ininment Isolation Valves BASES, Referepces: In accordance with the Appendix J Option il Model STS, a i
reference is to be added so " Option B"is identified with "10 CFR Part 50, Appendix i
J, Option II."
Hesponse 10 CFR Part 50, Appendix J is nnt referenced by the LCO 3.6.3 llases included in the Option B Model STS or the AP600 LCO 3.6.3 Bases. Therefore, no change is needed.
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I AP900 TECHNICAL SPECIFICAYlONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS j
m (27) 3.6.4 Cont'ainment Pressure LCO Statement: The containment pressures are r.ot bracketed.
Response
The upper pressure limit, + 1.0 psig,is not bracketed, since the value is assumed as an !nitial condition in SSAR Chapter 15 analyses and is a final value (i.e., not subject to plant or equipment specific conditions).
The lower pressure limit, 0.2 psig,is bracketed, since the limit is only required for plant site locations for which the lowest possible ambient temperature is approximately + 20'F. The potential need for the lower limit is explained in the Reviewer Note at the bottom of Technical Specification page 3.612.
.u w w 28
I AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUE8'llONS AND COMMENTS (28) 3.8.4 Cont'alnment Pressure For Condition B of this LCO, Westinghouse must either go to hiode 5 or justify why the LCO is not applicable in hiode 4 similar to comment (2) above.
Hesponse Al'600 Actions for LCOs 3.6.1, 3.0.2, 3.0.3, 3.0.4, 3.6.5, 3.0.6, and 3.0.9, which are applicable in hiodes 1 4, will be revised to specify hiode 5 as the Action end state.
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AP600 TECHNICAL 8PECIFICATIONS
. WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENT 8 m___
(29) 3.6.4 Cont'ainment Pressure BASES, Appliepble Safety Analyses: The results of the safety analyses are not included in the BASES. It only states that results are within the design capability.
Please provide reference values as are in NUREG 1431.
Response
A new Bases 3.0.4 Applicable Safety Analyses section has been prepared to replace the current APG00 section. The NUREG 1431 section has been modified to specify the AP600 results. Some of the resulta discussed fra the NUREG 1431 section are not available for AP600 and have been replaced with comparable AP600 discussion or deleted.
The NUHEG 1431 Applicable Safety Analyses section, as revised to be AP600-specific, is provided below:
Containment internal pressure is an initial condition used in the DBA analyses tc establish the maximum peak containment internal pressure. The limiting DBAs considered, relative to containment pressure, are the LOCA and SLB, which are analyzed using computer pressure transients. The worst case LOGA SLB generates larger mass and energy release than the worst case SIR LOCA. Thus, the LOCA SIB event bounds the SIS LOCA event from th3 containment peak pressure itandpoint (itef.1).
The initial pressure condition used in the containment analysis was 15.7 psia (1.0 psig).
This resulted in a the maximum peak pressure from a LOCA eH634-teig as toficated in irference !. The containment analysis (Ref,1) shows that the maximum peak calculated containment pressure, P., results from the limiting LOCA SLB. The maximum containment pressure resulting from the worst case LOCA or SLB i (44r1Heigi does not exceed the containment design pressure,45 psig.
The containment was also designed for an external pressure load equivalent to 3.0 psig.
The i--dvtWenetu:Wn-44he-Centn!- :nt S; ray-Syoke-wa*+nalysed4e dek rmine th: ::∈; : d::t'-- in-senssinewspeceesee, The limiting negative prrssure transient is a loss of all AC power sources coincident with extreme cold weather conditions which cools the external surface of the containment vessel. The initial pressure condition used in this analysis was 0.2 psig. This resulted in a minimum pressure inside containment 4 ! 2.0) p:!;;, as illustrated in nference 1, which is less than the design load. Other external pressure load events evaluated include:
Failed fan cooler control Malfunction of containment purge system inadvertent incontainment Refueling Water Storage Tank (IRWST) drain inadvertent Passive Containment Cooling System (PCS) actuation mwnw 30 n-.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
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(29) 3.6.4 Cont'ainment Pressure (Response continued)
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10CFM,0rAPpendia-K4kG3h Containment pressure satisfies Criterion 2 of the NRC Policy Statement.
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4 AIM TECHNICAL SPECIFICATIONS WENTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (30) 3.6.5 Cont'ainment Air Temperature LCO Statemen,t: The containment temperatere is not bracketed.
Response
The containment temperature limit,120'F,is not bracketed, since the value is assumed as an initial condition in SSAR Chapter 15 analyses and is a final value C.e., not subject to plant or equipment specific conditions).
When actual AP600 valuen are available, the values are specified in the Technical Specificattu.s and the brackets removed, indicating that the values are final.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (31) 3.6.5 Cont'alument Air Temperature For Condition B of this LCO, Westinghouse must either go to Mode 5 or justify why the LCO is not* applicable in Mode 4 similar to comment (2) above.
Hesponse AP000 Actions for LCOs 3.6.1, 3.6.2, 3.6.3, 3.0.4, 3.0.5, 3.6.0, and 3.0.9, which are applicable in Modes 1 4, will be revised to specify Mode 5 as the Action end state,
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ape 00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENT 8 gg-(32) 3.8.8 Cont'ainment Air Temperature HASES, Applic,able Safety Analyses: The results of the safety analyses are not included in the BASES. It only states that results are within the design capability or are acceptable. Please provide reference values as are in NUREG 1431.
Response
A new Bases 3.6.5 Applicable Safety Analyses section has been prepared to replace the current AP600 section. The NUREG 1431 section has been modified to specify the AP600 results. Some of the results discussed in the NUREG 1431 section are not available for AP600 and have been replaced with comparable AP600 discussion or deleted.
The NUREG 1431 Applicable Safety Analyses section, as revised to be AP600 specific,is provided below:
Containment average air temperature is an initial condition used in the DBA analyses that establishes the containment environmental qualification operating envelope for both pressure and temperature. The limit for containment average air temperature ensures that operation is maintained within the assumptions used in the DBA analyses for containment (Ref.1).
The limiting DBAs considered relative to containment OPERABILITY are the LOCA and SLB. The DBA LOCA and SLB are analyzed using computer codes designed to predict the resultant containment pressure transients. No two DBAs are assumed to occur simultaneously or consecutively. The postulated DBAs are analyzed with regard to Engineered Safety Feature (ESP) systems, assuming the loss of one ESF bus, which is the worst case single active failure, resulting in one train of the Containment Cooling System being rendered inoperable.
The limiting DBAs for the maximum peak containment air temperature ie-an are large-break LOCA and SLB. The initial containment average air temperature assumed in the design basis analyses (Ref.1)is 11201'F. This resulted in a maximum containment air temperature of42844PF as illustrated in reference 1. The d=ip k=p ::t== is
- 930FF, The temperature limit is used to establish the environmental qualification operating envelope for containment. The maximum peak containment air temperature-was
"=d S:t i ti=: !:k= ! d -ing wh!:h Se = tin::at :!: temp =turweeeded i: :-t !rm=t d=ip t =p=t== ::: d:-t ::::;h S:t de equi;==t :::'aee temp ='. =:== !=d he! - 60 d=ip t^=p='u=, Enf=:, it i: ::::! ded int the : !=!:kd t = int x Sirmert ie t:=pnter i:.x:;t:b!: fr-6: DBA SLB; o,.m 34
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NHC QUESTIONS AND COMMENTS (32t 3.6.5 Cont'alament Air Temperature (Response ccatinued)
The temperature limit is also used in the depressurization analyses to ensure that the minimum pressure limit is maintained following an i-deerter.t :::::'ian44he C=-t& :=t S;=ay-W loss of all AC power coincident with extreme cold weather conditions, which cools and depressurizes containment tref.1).
The containment pressure transient is sensitive to the initial air mass in containment and, therefore, to the initial containment air temperature. The limiting DBA for establishing the maximum peak containment internal pressure is a LOGA SIB. The temperature limit is used in this analysis to ensure that in the event of an accident the maximum containment internal pressure will not be exceeded.
Containment average air temperature satisfies Criterion of the NRC Policy Statement.
- , m w 35
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (33) 3.6.6 Passive Containment Cooling System (PCS). Operating Condition A: The BASES description of what constitutes an operable flow path requires more explanation. In the LCO description, a degraded system configuratica is presented as an operable flow path. The air operated valve is " administratively d
held open while the motor-operated valve is relied upon to automatically release PCS water. This is an inoperable flow path and Condition A should be entered.
Response
A flow path is operable when one isolation valve is open and the other isolation valve is capable of automatically opening. This configuration requires the least number of active valves to actuate to initiate PCS flow. Within each flow path, either the air-operated or motor-operated may be open. Since these configurations are both acceptable, the Bases LCO statement will be revised to delete
" administratively", as follows:
An OPERABLE flow path consists of either the normally closed air operated valve capable of automatically opening or the air operated valve ain!a!
atively open and the motor operated valve closed and capable of automatically opening.
The current surveillances, SR 3.6.6.3 and SR 3.6.6.4, require verification that valves are in their correct position or are capable of actuation. These surveillances verify that the flow paths are operable and permit either valve configuration. No other changes are needed.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS m,
(34) 3.6.6 Passive Containment Cooling System (PCS). Operating Since the PCS, system has no specific counterpart in standard technical specifica.
tions, Westinghouse will need to provide detailed justification for the completion times and surveillance frequencies chosen.
Response
Since there are no NRC acceptance criteria for selection of Completion Times and Surveillance Frequencies applicable to new system designs, detailed justification is not possible. To the extent that the PCS is modeled in the PRA, the times are acceptable, based on the acceptability of the overall PRA results (see Westinghouse letter, " Westinghouse Response to RAI 630.10", NSD.NRC 97 4939, dateil January 14, 1997).
The times selected are based on NUREG 1431 precedents for similar systems and equipment. The basis for the times is discussed in the LCO 3,0.6 Bases in the same level of detail as similar discussion in the NUREG 1431 Bases.
Westinghouse letter," Response to NRC Letter Regarding AP600 Technical Specification Completion Tin,,:s and Surveillance Frequencies", NSD NRC 97 5156, dated June 6,1997, Enclosure 1, includes a markup of the AP600 Technical Specifications specifying times which are consistent with NUREG 1431 precedents.
The markup includes references to the NUREG 1431 precedents where available.
.u,== w 37
AP600 TECHNICAL SPECIFICATIONS WESTINOHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (35) 3.6.6 Passive Containment Cooling System (PCS). Operating
)
A new "Conditi.on C" should be considered which states "PCS is inoperable for reasons other than Conditions A or B". This Condition means PCS water is capable of flowing; however, the PCS support systems may not be able to maintain the water within the conditions needed to achieve the desired flow limits. Such as, a condition when the PCS storage tank is inoperable due the inoperability of the recirculation pump, the heaters or the chemical addition tank. SSAR 6.2.2.2.3, third paragraph, states PCS operability is dependent upon the recirculation loop. Also, there is no mention in the BASES of the recirculation loop.
This new Condition "C" would also replace the Condition D Oli statement of"LCO not met for reasons other than A, B, or C." which is really another basis for entry into LCO 3.0.3. This QB statement should be deleted because it is redundant to LCO 3.0.3. There is no specific justification for this 011 statement addition in the Westinghouse justification document or in the BASES.
Hesponse Currently in LCO 3.6.6 the second part of Condition D includes the following requirement:
"LCO not met for reasons other than A, B, or C."
This requirement is equivalent to the requested Condition (PCS is inoperable for reasons other than Conditions A or B), since the LCO specifies that the PCS shall be operable. The current condition would be entered for all of the same inoperabilities as the requested condition.
The referenced SSAR (Rev.13) paragraph (6.2.2.2.3) states:
"The tank also has redundant level measurement channels and alarms for monitoring the tank water level and redundant temperature measurement channels to monitor and alarm for potential freezing. To maintain system operability, a recirculation loop that provides chemistry and temperature control is connected to the tank.
The function of each of these features is also included in SSAR paragraph 6.2.2.2.3:
" Chemical Addition Tank The chemical addition tank is a small, vertical, cylindrical tank that is sized to inject a solution of hydrogen peroxide to maintain a passive containment cooling water storage tank concentration for control of algae growth.
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APs00 TECHNICAL SPECIFICATIONS 1
WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (35) 3.6.6 Passive Containment Cooling System (PCS). Operating (Hesponse continued)
Heelrculiition Pumps Each recirculation pump is a 100 percent capacity centrifugal pump with wetted components made of austenitic stainless steel.
The pump is sited to recirculate the entire volume of PCCWST water once overy week.
Recirculation lleater The recirculation heater is provided for freeze protection. The heater is sized based on heat loss from the passive cooling water storage tank and recirculation piping at the minimum site temperature, as defined in Section 2.3."
The recirculation loop maintains the operable status of the PCS, but is not required for artisfactory performance of the PCS. Inoperability ot :hese systems will not prevent the PCS from performing its safety function as assumed in the safety analyses. SR 3.0.6.2 is included in the specification to verify that the water temperature is within acceptable limits (240'F ard 5120*F).
The Background Bases discussion will be expanded to address the potential for algae accumulation. The System Level Inservice Testing Program, discussed in response to NRC Comment #47 will aamure adequate system water distribution performance.
Algae growth is not expected within the PCCWST; however, to assure water clarity in maintained, a prevailing concentration of hydrogen peroxide is maintained at 50 ppm.
- =w w 39
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AP600 TECIENICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (36) 3.6.6 Passive Containment Cooling System (PCS). Operating In addition to $e PCS description shortfall noted in comment (35)(recirculation loop and pumps, chemical control, and heaters), the PCS has additional features which need to be considered both for operability and for surveillance requirements:
(a) llucket: there is a bucket suspended from the shield building just above the containment dome apex. The bucket is used to assure uniform distribution of the PCS water. The delivery pipes are located somewhere below the operating water level of the bucket (SSAR 6.2.2.2 3). The bucket must be operable (in place). If the bucket can fill with rain water, or condensation, and subsequently freeze, the PCS water flow path will be closed.
(b) Weirs: there are two sets of weirs on the containment dorr.e. The weirs are used to assure uniform distribution of the PCS water. The weirs must be operable (in place).
Hesponse - (a) & (b)
The bucket and weirs are permanently attached to the shield building and containment dome, respectively, and can not be easily dismantled. While there is no direct precedent in the STS, the bucket and weirs can be compared to a piping flow orifice. in both cases their function is verified by functional tests and their continued operability is assured by plant procedures which do not permit their removal. Existing NUREG 1431 surveillance requirements do not require verification of similar components.
mi.x w 40
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
=
(36) 3.6.6 Passive Containment Cooling System (PCS) Operating (continued)
(c)
The PCS will not perform its design function if there is a degradation of the inorganic zine paint on either the exterior or the interior of the containment shell and dome region. The effects of environmental pollutants needs to be addressed (for example, so@ from a fire or organic residues from industrial works), at least for sumillance. As a first-of a-kind (FOAK), there may be the need for an applicant to commit to perform inspections on the surface wetability during the first few refueling outages before any extended surveillance period can be considered orjustified. The surveillance interval needs to be reconsidered.
Response - (c)
Periodic inspections of the containment surface will be required by the Reliability Assurance Program (RAP) to assure that pollutants have not accumulated to an extent which could interfere with surface wetebility and film formation.
In order to assure that surface wetability and film formation are considered a prerequisite for operability, the LCO 3.6.6 Bases will be resised to add the following to the Background section:
The monitoring of the containment surface through the Reliability Assurance Program (RAP) and the Inservice Testing Program assures surface contamination does not unacceptably degrade containment heat removal performance. Contamination can be removed by PCS actuation or by using coating vendor cleaning procedures.
Additionally, SSAR Table 3.917 will be revised to include testing of system performance including uniformity of flow around the vessel circumference.
The System Level Inservice testing Program, which will be the utility responsibility will require documentation of test methods, and associated acceptance criteria. The methods and acceptance criteria must assure the system performance assumed in the safety analyses.
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l a.ww w 41 i
AP600 TECHNICAL SPECIFICATIONS WESTINGIIOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (36) 3.6.6 Passive Containment Cooling System (PCS). Operating (continued)
(d) The passive containment cooling water storage tank (PCCWST)is also used for makeup t6 the spent fuel pool. Since this could occur during reactor operations, an LCO needs to be developed.
Response - (d)
New LCO 3.9.5 has been added to added to specify the requirements for the water storage tank when required for spent fuel pool makeup. The new LCO is included in the enclosed Technical Specification markups. Additionally, the LCO 3.6.7 Bases have been marked up to reference the new LCO.
. <w,.x w 42
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (36) 3.6.6 Passive Containment Cooling System (PCS). Operating (continued)
(e) The post 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> designs changes need to be considered. The increased PCCWST* volume and the on grade auxiliary storage tank need to be consid-cred. The auxiliary tank level (volume), temperature, and chemical control need to be considered (operability and surveillance). The recirculation pumps, which provided post 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> makeup to the PCCWST (for up to 7 days) need to be considered (operability and surveillance).
Response - (e)
SR 3.6.6.2 will be revised to specify the increased PCCWST volume. The LCO 3.6.6 requirements apply to the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of PCS operation, as assumed in the SSAR Chapter 15 accident analysis.
Requirements similar to the Technical Specifications applicable to the on grade ancillary tank and recirculation pump are being incorporated into the Investment Protection Short Term Availability Controls contained in SSAR section 16.3. The SSAR requirements will address the post 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requirements for continued PCS operation for up to 7 days using the ancillary tank and recirculation pumps.
9 me,w w 43
l AP600 TECHNICAL SPECIFICATIONS
-WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS i
(36) 3.6.6 Passive Containment Cooling System (PCS) Operating (continued)
(O The PCS air flow pt ih is not described in sumcient detail to determine surveillance requirements and or possible failure modes: the air inlets with their (heated) screens, the baflie which creates the downcomer and riser sections, the flow turning (curved) vanes, and the chimney with its screens (heated).
Response - (O The existing Bases Background discussion of the PCS air flow path, while not detailed,is adequate to describe the basic layout and function. The SSAR PCS description may be consulted for additional details.
Bases Reference 4, SSAR Section 6.2, " Containment Systems", will be added to the end of the fourth Background paragraph to provide the location of additional descriptive information.
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AP600 TECHNICAI, SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (36) 3.6.6 Passive Containment Cooling System (PCS). Operating (continued)
(g) The drain.s in the uppoi annulus region need to be clear from obstructions to maintain the air flow path. In Section 40 of the probabilistic risk assessment (PRA)(Revision 8. September 30,1996), it is stated that weekly surveillance of the drains is performed to preclude blockage of the air path as a failure mode.
Response - (g)
No anticipated blockage mechanisms have been identified to justify additional surveillance of the drains, considering the potential sources of blockage materials, small mesh size of the air path screens, and large drain size, in order to assure that clear drains are considered a prerequisite for operability, the LCO 3.6.6 Bases will be revised to add the following to the Background section:
The drains in the upper annulus region must be clear to prevent water from blocking the air flow path.
- c=x w 45
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RF.SPONSES TO NRC QUESTIONS AND COMMENTS (36) 3.6.6 Passive Containment Cooling System (PCS) Operating (continued)
(h) From the.SSAR description it is not clear if part of the PCCWST discharge-piping (to the bucket) will be outside the heated valve room. Loss of heating may result in freezing of the line. There is no LCO or surveillance on the valve room or piping temperatures or heater availability.
Response - (h)
Monitoring of the storage tank, valve room and outside temperatures will indicate when freezing of the discharge flow path is possible. Since the lines beyond the isolation valves (out side the valve room) will ant be filled with water (sloped to discharge) freezing of that section of the flow path is not possible.
In order to address the potential for pipe freezing, the LCO 3.6.6 Bases will be revised to add the following to the Background section:
The PCS valve room temperature must not be below freezing for an extended period to assure the water flow path to the containment shellis available.
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AP600 TECHNICAL SPECIFICATIONS WESTINGIIOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS a_ _
(37) 3.6.6 Passive Containment Cooling System (PCS). Operating Current Condition C: When two PCS flow paths are inoperable, then LCO 3.0.3 should be entered immediately. This is a loss of function. The proposed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is inconsistent the STS practice for loss of both trains of an engineered safety feature.
There should be no additional time needed to evaluate this condition and the comple.
tion time should be immediate entry to LCO 3.0.3.
Response
Condition C will be deleted.
I AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (38) 3.6,6 Passive Containment Cooling System (PCS) Operating For Condition D of this LCO, Westinghouse mest either go to Mode 5 or justify why
~
the LCO is not applicable in Mode 4 similar to comment (2) above.
Response
AP600 Actions for LCOs 3.6.1, 3.6.2, 3.6.3, 3.6.4, 3.6.5, 3.6.6, and 3.6.9, which are applicable in Modes 1 4, will be revised to specify Mode 5 as the Action end state.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (39) 3.6.6 Passive Containment Cooling System (PCS) Operating SR 3.6.6.1: Upper and lower external temperature limits have been added to the performance of this SR. Please explain the appropriateness of these temperatures to the analysis initial condition limits specified in SSAR Table 6.2.1.13. Where is the air temperature measured? Analytically, this would be the temperature of the air as it enters the shield building. It could be from 40 *F to 115 *F. Since the air temperature is one of the variables that impacts the pressure calculation, why is there no LCO on its value?
Response
SR 3.6.6.1 Tank Temperature SR 3.6.6.1 specifies that the water storage innh temperature shall be between 40'F and 120'F. The lower limit could be violated during extended cold weather,if the tank were not heated. The upper limit could be exceeded during hot weather in combination with inadvertent oper9 tion of the tank heaters.
The SSAR Table, Initial Conditions, does not list the water storage tank temperature or specify conditions which limit the tank temperature. Therefore, the tank temperatura limits are appropriate, considering the Table initial conditions are not related.
The initial conditions listed in SSAR Table 6.2.1.1-2, Initial Conditions ( 3 specifies Results of Postulated Accidents), are as follows:
Internal Temperature ('F) 120 Pressure (psia) 15.7 Relative Humidity (%)
0 Net Free Volume (ft')
1.7 E+06 External Temperature ('F) 115 dry bulb 80 wet bulb Air Temperature Air temperafure limits are not specified in the LCO or surveillances. The containment cooling analysis takes into consideration the full range of possible external air temperatures permitted by the site criteria in SSAR Table 21 (-40*F to 115'F dry bulb coincident with 80'F wet bulb) such that no external air temperature limits are needed for LCO 3.6.6.
www 49
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (40) 3.6.6 Passive Containment Cooling System (PCS). Operating SR 3.6.6.3: The performance of this SR is questioned because the BASES imply it is i
dependent upon the availability of a control room indication. If the indication is not available, what is done? Also, what if the indication becomes inoperable? The J
NUREG 1431 requires direct inspection every 31 days. Has this been deleted? If so, explain why?
l
Response
Until recently, all AP600 surveillances which could be performed with ccatrol room instrumentation were being specified with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency, since performance of the surveillance would be easy. The AP600 standardized Frequencies have been rejected (NRC letter " Optimized Completion Times and Surveillance Frequencies -
AP600 Technical Specifications", dated March 27,1997) and STS times will be specified for AP600. The SR 3.6.6.3 Frequency will be changed to 31 days consistent with the NUREG 1431 SR 3.6.6A.I.
Additionally, the SR 3.6.6.3 Bases will be revised to delete the discussion of the control room indication as a basis for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency as follows:
SR 3.6.6.3 Verifying the correct alignment of power operated, and automatic valves, excluding check valves, in the Passive Containment Cooling System provides assurance that the proper flow paths exist for system operation. This SR does not apply t( valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct positions prior to being secured.
The 24 haar-Frequcacy in haced ca the availability of centrol reem iactru:ncatatica t= vc-ify.alyc pccitica. This SR does not require any testing or valve manipulation. Rather, it involves verification, through control room instrumentation or a system walkdown, that valves capable ofpotentially being mispositioned are in the correct position.
4 wu w 50
AP600 TECMICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS m-(41) 3.6.6 Passive Containment Cooling System (PCS). Operating SR 3.6.6.4: Verification of that valves are not locked, sealed or secured and will correctly position on an automatic signal are not part of the ASME Section XI Inservice Testing Program. Westinghouse should specify a specific frequency for this surveillance as currently done in NUREG 1431. This comment is also applica-ble to SR 3.6.3.5 for containment isolation valves.
Response
The Frequency will be changed to 24 months, to be consistent with NUREG 1431 SR 3.6.3.8 and SR 3.6.6A.5 wl.ich specify [18] months which is the assumed refueling cycle period, which for AP600 is 24 months.
The associated Bases will also be revised to address the 24 month Frequency.
a.mau 51
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (42) 3.6.6 Passive Containment Cooling System (PCS) Operating SR 3.6.6.5: SSAR 6.2.2.2.4, fifth paragraph, implies that the air bame in the shield building annulus is removable. Are the removable sections the inspection ports? It would seem appropriate that inspection that all potentially removable bame sections should also be added to the SR to verify that they are in place, prior to startup.
Response
SR 3.6.6.5 will be revised to address removable bame sections as follows:
S R 3.6.6.5 Verify the air flow path from the shield building annulus inlet to the exit is unobstructed and that all air bame sections are in place.
Bases revision:
SR 3.6.6.5 This SR requires verification that the air flow path from the shield building annulus inlet to the exit is unobstructed. Additionally, the SR requires verification that removable sections of the air bame are in place to maintain the heat removal capability. Although there are no anticipated mechanisms which would cause air flow path obstruction and the effect of u missing air bame section is small, it is considered prudent to verify this capability every 24 months.
meum 52
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (43) 3.6.6 Passive Containment Cooling System (PCS) Operating Bases, Background, fifth paragraph & Applicable Safety Analyses, third paragraph:
This states that PCS is automatically actuated by a Containment High 1 pressure l
signal. SSAR 6.2.2.1, Table 6.22 3 and Figure 7.21 all indicate it should be a Containment High 2 pressure signal. Also, the dual separate switches of Figure 7.2-1 for manual initiation are not adequately discussed. The SSAR 6.2.2.1 states that PCS cooling water is designed to flow for at least three days. Please add this specific requirement rather than just "until tank is empty".
Response
The Bases will be revised to specify actuation on a Containment High 2 pressure signal.
The Bases will be revised to address the provisions for manual initiation as follows:
The manual containment cooling actuation consists of four momentary controls, if two associated controls are operated simultaneously actuation will occur in all divisions.
The LCO 3.6.6 Bases Background discussion will be revised as follows to specify cooling water flow for at least ihree days.
The PCS is actuat3d either automatically, by a centainment High-2 pressure signal, or manually. Automatic actuation opens the cooling water tank discharge valves, allowing gravity flow of the cooling water onto the containment shell. A manual actuation of the PCS requires the operator to actuate two separate switches on the main control board to begin the sequence.
The discharge continues until the eccling-wat.ee-tank-ia c:r.pty. for at least three days.
s.muu 53
AP600 TECHNICAL SPECIFICATIONS.
WESTINufiOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS n
(44) 3.6.6 Passive Containment Cooling System (PCS). Operating BASES, Applicable Safety Analyses second paragraph: The results of this analyses a l report that they meet design limits without stating what the specific results are.
l 1%sse add bracketed representative values.
Response
A new Bases 3.6.6 Applicable Safety Analyses section has been prepared to replace the current AP600 section. The NUREG 1431 Bases 3.6.6A, Containment Spray and Cooling Systems, Applicable Safety Analyses section has been modified to specify the AP600 results. Some of the results discussed in the NUREG 1431 section are not available for AP600 and have been replaced with comparable AP600 discussion or deleted.
The NUREG 1431 Applicable Safety Analyses section, as revised to be AP600-specific,is provided below:
The Containment S;:: y Sycte: and Passive Containment Cooling System limits the temperature and pressure that could be experienced following a DBA. The limiting DBAs considered are the loss of coolant accident (LOCA) and the steam line break (SLBL The LOCA and SLB are analyzed using computer codes designed to predict the resultant containment pressure and temperature transients. No DBAs are assumed to occur simultaneously cr consecutively. The postulated DBAs are analyzed with regard to containment ESF systems, assuming the loss of one ESF bue Class JE Engineered Safety Features Actuatmn Cabinet (ESFAC) Division, which is the worst case single active failure and results in one train of the Containment Spray Syste: and Containment-Cooling System being rendered PCS gow path being inoperable.
The analysis and evaluation show that under the worst case scenario, the highest peak containment pressure is-H44] peig ( :perienced during : LOCA) as indicated in refennce 4 occurs during a SLB and is less than containment design pressure. The analysis shows that the peak containment temperature is l3St51*F ( :p rienced du-ing an4hl4 as indicated in reference 4 also occurs during a SLB. Both results meet the intent of the design basis. (See the Bases for LCO 3.6.4, " Containment Pressure " and LCO 3.6.5 for a detailed discussion.) The analyses and evaluations assume a unit specific power level of H00f41933 MWt, cae ecatair ent spray trai:. and one passive containment cooling train Bow path operating, and initial (pre-accident) containment conditions of 120'F and 1.0 psig. The analyses also assume a response time delayed initiation to provide conservative peak calculated containment pressure and temperature responses. The total response time includes actuation time plus the time required to achieve full flow to the containment shell.
swuu 54
AP600 TECHNICAL CPECIFICATIONS WESTINGHOUSE MESPONSES TO NRC QUESTIONS AND COMMENTS (44) 3.6.6 Passive Containment Cooling System (PCS). Operating (Response continued) p,_ _. a _ : _... a _.,.r.. _ _ :.. eee.,~_...
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The modeled Passive Containment Cooling System actuation response time from the containment analysis is based upon a response time associated with exceeding the containment High4 2 pressure setpoint to opening ofisolation valves. ::h!:ving full C...'-:-.."..-".o,"".-....:....'.'.".."...,d---^"...-."-. a...-. ' " '. ~ -
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aen 55
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (45) 3.6.6 Passive Containment Cooling System (PCS). Operating BASES, Applicable Safety Analyses, second and third paragraph: The last sentence of the second paragraph and the third paragraph appears to be the same subject for the assumed response time delay. Please clarify.
Response
Clarification has been added to the subject section to specify total delay includes time for 1) signal generation and valve actuation and 2) development of full flow to the containment shell.
These changes are included in the revisions to the 3.6.6 Bases, Applicable Safety Analyses section provided in response to Commet;*. #44.
.ur, w 56
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (46) 3.6.6 Passive Containment Cooling System (PCS) Operating BASES, Action,B.1: The last part of this paragraph is not developed enough to provide adequate justification for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time. Credit cannot be given to water sources which are not subject to TS control.
Response
The Completion Time for Action B.1 will be changed to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
f wwww 57
AP600 TECHNICAL SPECIFICATIONS WES1TNGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (47) 3.6.6 Passive Containment Cooling System (PCS) Operating SR 3.6.6.6: The proposed inservice testing program (ITP)is not in accordance with ASME Section XI. It is the staffs understanding that this refers to AP600 SSAR Table 3 917, "PCS." This is unacceptable. The test and frequency should be placed in the TSn. In addition, the following questions related to the test described in SSAR Table 3.917.
Response
SR 3.6.6.6 and the associated Bases will be revised to specify testing in accordance i
with the System Level Inservice Testing Program at a 10 year Frequency.
em w 58
7-b AP600 TECHNICAL GPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (47) 3.6.6 Pacsive Containment Cooling System (PCS) Operating (continued)
(a) What are the PCCWST drain lines? Are these the discharge lines discussed in the technical specitications? Are they the delivery lines discussed in the SSAR (6.2.2.2.3)? Or are these the upper annulus drains?
Response
The discharge lines discussed in the LCO 3.6.6 Bases run from the storage tank to the air-operated and motor-operated isolation valves and on to the water distribution bucket.
.u,um tw 59
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (47) 3.6.6 Passive Containment Cooling System (PCS) Operating (continued)
(b) The test does not address the three flow stages (each line has its own flow orifice and measuring desico not a single flow as indicated in Note 2 of Table 3.917), the uniformity of the flow around the vessel circamference or the water area coverage fraction for each flow phase. Measurements of all three is necessary to assess degradation of the er.terior surface.
Response
SSAR Table 3.917 currently commits to verifying the PCS flow rate from etch PCS drain line. This test will confirm the cooling water flow profile with time remains consistent with the accident analyses. An additional test has been added to the System Level Inservice Testing Program to confirm the wetted water coverage of the containment shell ie equal to or greater than the amount predicted by the wetting coverage methodology used in the safety analysis.
4.e,w w _
60
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (47) 3.6.6 Passive Coatainment Cooling System (PCS)- Operating (continued)
(c)
There is rto justification for the 10 year surveillance period. As a FOAK, there may be the need for an applicant to commit to perform inspections on the surface wetability during the first few refueling outages before any extended surveillance period can be considered or justified. The surveillance interval nceds to be reconsidered.
Response
The performance of the installed coatings is monitored. The coatings performance monitoring program includes periodic inspections of the coatings on the containment vessel during planned outages.
A discussion of coating wetability with time and contamination is provided in the "WGOTHIC" Application to AP600" report (Section 7A of WCAP 14407, Revision 0).
The conclusions of the WCAP would support an imorovement of wetability with time and a limited impact due to potential contamination thus a surveillance frequency of 10 years is justified for the coatings performance monitoring program. Testing of wetting coverage is addressed in the System Level Inservice Testing Program discussed in the response to NRC comment #47(b), above.
%*w 61
AP600 TECHNICAL SPECIFICATIONS
- WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (48) 3.6l1 Passive Containment Cooling System (PCS). Shutdown Most of the comment for LCO 3.6.6 above are valid for this LCO as well.
Response
Since LCO 3.6.7 refers to LCO 3.6.6 for surveillance requirements and most Bases discussion, no additional changes to LCO 3.6.7 or the associated Bases are required.
menu 62
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
- (49) 3.6.7 Passive Containment Cooling System (PCS) Shutdown BASES, Applicability: Why does the maintenance of the storage tank and water delivery systeni have to do with the Applicability? Why permit any maintenance before the end of the Applicability of this LCO for the PCS? There is more discussion of what happens after the 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> rather than justification for why the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> limit is appropriate for the Applicability as proposed. For example, the bases appears to imply that limited work on the air bafIles could begin before the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> time limit. However, if maintenance of the air flow path or baflie begins prior to the end of the Applicability of this PCS, then SR 3.6.6.5 can not be met.
Response
The first paragreph of LCO 3.6,7 Bases Applicability will be replaced with the following, completely eliminating discussion of maintenance considerations:
OPERABILITY of the PCS is required in MODES 5 and 6 with the reactor shutdown and the calculated reactor decay heat greater than 6 MWt for heat removal in the event of a loss of nonsafety decay heat removal capabilities.
With the decay heat less than 6 MWt, the decay and sensible heat can be easily removed from containment with air cooling alone, i
s *G
- www 63
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (50) 3.6.7 Paasive Containment Cooling System (PCS) Shutdown BASES, Background and Applicable Safety Analyses: Please expand these sections for Shutdown.
a)
Please identify what accidents are afTected by the loss of containment decay heat removal.
b)
Where are and what are the results of these analyses discussea in the SSAR?
c)
Also, discuss the reasons for the 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> limit, d)
An analysis to support the air cooling only capability of the PCS during shutdown needs to be performed and documented as part of the bases.
Response
a)
The LCO 3.6.7 Bases identify the accidents which rely on PCS heat removal as follows:
The limiting DBAs considered during shutdown are the loss of decay heat removal and loss of shutdown margin events, b)
The LCO 3.6.7 Bases state that the loss of decay heat and loss of shutdown margin events are bounded by MODE 1 - 4 events, c)
The 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> limit has been changed to reflect the actual requirement related to PCS capability to remove decay heat with air cooling alone. At a decay heat level ofless than 6 MWt, the evaporative cooling provided by the water stored within the PCCWST is no longer required, since air cooling alone will provide adequate heat removal, d)
Formal analysis is underway to demonstrate air cooling alone is sufficient to remove the 6 MWt heat load.
- waw 64
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (51) 3.6.7 Passive Containment Cooling System (PCS) Shutdown Where are the analyses which support the required actions for Condition D?
Response
The Condition D requirements are based on placing the pir_nt in the safest condition, considering that the potential events are loss of decay heat removal and loss of shutdown margin. Maximizing the RCS inventory, maintaining RCS temperature low and maintaining shutdown margin are the Actions available which can minimize the need for or delay PCS actuation. No analyses are needed to support the Condition D Actions.
- ww 65
. AP600 TECHNICAL SPECIFICATIONS l
WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (52) 3.6.7 Pa'ssive Containment Cooling System (PCS) Shutdows Why are there no references in the bases?
Response
The 3.6.7 Bases Background and Applicable Safety Analyses sections refer to the LCO 3.6.6 Bases which include the appropriate references. Also, reference 1, SSAR Section 6.3, has been added the 3.6.7 Bases LCO section.
a.mu w 66
L a
AP600 TECHNICAL SPECIFICATIOFS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS
_(53) 3.8.8 Containment Ponetrations LCO 3.6.8: The Westinghouse justification document does not provide any reasons for this LCO. This is a new LCO which is similar to NUREG 1431 LCO 3.9.4 (to which it is compared) but the reasons for including this LCO are different.
Westinghouse should clarify in the BASES why this LCO is now applicable in Modes 5 and 6 rather than simply refueling operations as in NUREG 1431.
Response
The existing LCO 3.6.8 Bases discussion is considered to be extensive and includes the following which addresses each of the above subjects:
Reason for LCO Containment closure is required to maintain within containment the cooling water inventory. Due to the large volume of the IRWST and the reduced sensible heat during shutdown, the loss of some of the water inventory can be accepted. Further, accident analyses have shown that containment closure capability is nnt required to meet offsite dose requirements Mode 5 and 6 Aoplicability In Modes 5 and 6, there is no potential for steam release into the containment immediately following a accident. Pressurization of the containment could only occur after heatup of the IRWST due to PRHR HX operation (MODE 5 with RCS intact) or after heatup of the RCS with direct venting to the containment (MODE 5 with reduced RCS inventory or MODE 6 with the refueling cavity not fully flooded) or after heatup of the RCS and refueling cavity (MODE 6 with refueling cavity fully flooded). The time from loss of normal cooling until steam release to the containment for these different MODES is shown in Figure B 3.6.81 as a function of time after shu'down Because local manual action may ba required to achieve containment closure it is assumed that the containment hatches, air locks and penetrations must be closed prior to steaming into containment.
ww w 67 l
m
AP600 TECHNICAL SPECIFICATIONS WESTINOHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS n _
(54) 3.6.8 Con'tainment Penetrations
" Closure capability" can be directly reasoned for containment penetrations such as the purge system flow paths provided the automatic valve is not blocked open. This
" closure capability" definition assumes each penetration flow path has a removable blockage that must somehow get removed before the flow path can be isolated.
Containment " closure capability"is also defined as dependent upon an unknown number of penetrations which will have to be closed prior to " steaming into containment". As defined,it appears this capability can not be specifically established to determined whether or not it is within the limiting bounds of the proposed DASES Figure 3.6.81. Can closure capability ever be numerically 4
establianed and controlled to provide a reasonable margin prior to steaming into containment?
Response
The concept of containment closure capability is relatively easy for the operator to control in order to comply with the Technical Specification limitations. The limitations are nssentially identical to those presently specified within the STS LCO 3.9.4 associated with establishing containment isolation in Mode 6 during fuel movement.
There are a limited number of containment penetrations to which this LCO applies, similiar to STS LCO 3.9.4:
2 Equipment hatches 2 Air locks 4 Containment spare penetrations 2 Containment recirculation system penetrations (purge valves)
For the equipment hatches the operator would need to confirm the availability of any tools or hatch closure equipment operability. For the air locks and spare penetrations, depending on the operator's administrative limitations, closure capability can be confirmed by establishing the presence of electrical connectors for cables or couplings for hoses which traverse the penetration. For the containment recirculation penetrations the requirements will simply be that for each penetration there is a closed valve or the valves are operable.
w,* w 68
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUME RESPONSES TO NRC QUESTIONS AND COMMENTS
_____n._,--,.__
(55) 3.e.8 Containment Penetrations Bases, Applicable Safety Analyses: Please identify what are the safety analyses performed that have which assumptions or initial conditions that are used as the basis for this LCO. Please identify what are the shutdown events associated with 7
this LCO. Where are the analyses? The References in the BASES refer to "FSAR j
15A.5" but in SSAR 15.4.5 it states this is not applienble for the AP600 design because it is for DWR's. The reference to the Standard Review Plan section 15.7.4 seems inappropriate. In addition,"... Interim..." should be deleted to be consistent with the other Bases sections of TS.
Hesponse The events associated with this LCO are those which lead to a loss of RNS coolin8 WCAP 14837. Revision 1, "AP600 Shutdown Evaluation Report" provides a summary of the limiting events, a sequence erevents, analyses and results. This WCAP will be added as a reference in the Applicable Safety Analyses section.
Reference 2 and 3 are not utilized in the Bases and will be deleted.
I i
urum w 69 f
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ape 00 TECHNICAL FPECIFICATIONS WESTINGHOUSE RESPONSES TO NHC QUESTIONS AND COMMENTS (50) 3.6.8 Conkalnment Penetrations The BASES LCO state this is to limit the loss of cooling water inventory. The i
llackground states some water can be lost. Is it an assumption of the safety analyses that some water will be lost until containment closure is achieved. How is this assumption verified? What if too much water escapes?
Response
Makeup can be provided via the CVS normal charging line or alternatively the IRWST makeup path via the SFS through the makeup connection to the IRWST or the safety related connection within the RNS designed to provide long term containment makeup. A variety ofinstrumentation is available to assess subcooling and important levels. This instrumentation includes:
liot leg level llot leg temperature Pressuriter level IRWST level IRWST temperature Containment sump level Containment pressure Passive RiiR flow Passive RIIR temperature The objective of the containment closure timing requirement is to assure closure prior to the onset of boiling of reactor coolant. The ability to establish closure precludes loss of any significant amount of coolant. This is. very conservative criteria since large amounts of water can be lost without limiting the ability for core cooling. Additionally, a safety related connection is provided for coolant makeup to containment.
wwww 70
AP600 TECHNICAL SPECIFICATIONS i
WESTINGHOUSE RESPONSES TO NHC QUESTIONS AND COMMENTS (57) 3.6.8 Containment Penetrations This LCO appears to facilitate an accelerated or shorten refueling operations period by permitting the rapid entry into containment with an accompanying loss of containment isolation Is this correct or please explain? Also, explain the meaning of" Time After Shutdown" as used in the Background and in the BASES Figure 3.6.81. When exactly is time equal to zero for " Time After Shutdown"?
Hesponse The LCO has been written to specify the conditions required by the SSAR Chapter 15 cceident analyses. Since there ato no events in h! ODES 5 or 6 which require containment isolation (leaktight requirements), it is not required by the AP600 specifications. The rationale for excluding modes 5 and 6 from LCO 3.6.3 is exactly the same as the rationale for limiting the need for containment isolation in the STS to preclude modes 5 and 6. The need for containment closure is a separate issue as discussed in LCO 3.6.8 Bases. Containment closure to prevent excessive cooling water inventory loss is assumed in h! ODES 5 and 6 and is, therefore, specified in LCO 3.6.8.
The AP600 containment closure requirements apply in all of htODES 5 and 6 and are umrs_rn11iclire than the STS requirements which only apply during core alterations and irradiated ruel movement (a portion of h! ODE 6). Therefore, the AP600 requirements do n9L facilitate rapid entry into containment as compared to the STS.
" Time after shutdown"is the time since entry into htODE 3 from htODE 2.
=cem w 71
k AP600 TECHNICAL NPECIFICATIONS WESTINGHOUSE RESPONSES TO NHC QUESTIONS AND COMMENTS (58) 3.6.8 Containment Penetrations a)
What is lutended for the status of Containment OPERABILITY during the movement ofirradiated fuel assemblies in containment and for CORE ALTERATIONS?
b)
How does a fuel handling accident in containment affect containment OPERABILITY?
c)
Was the analyses of SSAR 15.7.4 performed assuming all potential open penetrations in the containment per this LCO or was release assumed only through certain penetrations?
Response
a)
No containment integrity or closure requirements are intended to apply during movement ofirradiated fuel assemblies or during core alterations.
b)
A fuel handling accident can not occur while containment operability is required, since operability is only required in htODES 1 4 (LCO 3.6.1) and fuel handling would only occur in ht0DE 6.
c)
The SSAR 15.7.4 analyses were performed assuming that releases were not mitigated by any portion of the containment.
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ape 00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS i
(59) 3.6.8 Containment Penetrations LCO Statement b: There appears to no need to delete the requirement that one l'ior in each air lock be closed as in NUREO.1431 LCO 3.9.4. It is suggested that the NUREG.1431 LCO 3.9.4 text be kept and include the additionally proposed clause by changing "and" to "or". This is same as LCO Statement "a" where "or" is used when a penetration has to be open.
Response
1 AP600 LCO 3.6.8, item b will be revised to include the option of closing one door in -
each air lock as follows:
b.
One door in cach air lock closed, or the containment air locks shall be clear of obstructions such that they can be closed prior to steaming into the containment.
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ape 00 TECHNICAI, SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (60) 3.6.8 Containment Penetrations LCO Statement d.2: There does not appear to be a " Containment Isolation" signal required to be Dperable for this condition. What signal is this LCO referring to?
Some clarification is needed for the technical specification on this matter.
Hesponse LCO 3.3.2, ESFAS Instrumentation Function 3.a, Manual Initiation of Containment Isolation requires OPERABILITY of the required actuation controls.
The Bases will be revised to clarify the intent of LCO item d.2 by addition of the following before the last sentence in the LCO section:
If direct access penetrations are open, OPERABILITY of the containment isolation instrumentation is required for the open penetrations by LCO 3.3.2, Function 3.a, Containment isolation, Manual Initiation. An OPERABLE Containment isolation Function includes LCO 3.3.2, Function 19 b, Containment Air Filtration System Isolation, Containment Isolation, i
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AP600 TECHNICAL SPECIFICATIONS WESTINOHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (01) 3.6.8 Con'tainment Penetrations Condition B: Would the required actions of Condition B be needed if the Applica-bility is changed to not permit any containment penetration to be open during these i
conditions with short times to " steaming the containment"?
Response
Steaming to containment is not the critical concern for this LCO. It is simply a very conservative criteria for when containment inventory may potentially become a i
concern. There is insufficient justification to limit containment penetration opening in these mHca provided closure is available within limited time frames.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS i
(62) 3.6.8 Cont'alnment Penetrations Sit 3.6.8.3: llow is this covered 1:y the ASME Section XI IST prograrn? The staff believes that this should be defined with its own specific frequency unrelated to IST.
Response
Consistent with NUllEG 1431 precedents (such as SR 3.6.3.8 and SR 3.9,4.2), the
. AP600 SR 3.6.8.3 Frequency will be changed to "24 months".
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NHC QUESTIONS AND COMMENTS
___ __ _ __._,._.__ _ _, _ _ _._ _ m (63) 3.6.8 Containment Penetrations Why are there,no SRs similar to proposed SR 3.G.8.2 for the air locks or for the spare containment penetrationa which opened under this LCO? Air locks and spare penetrations must be capable of being restored prior to steaming. An appropriate SR is to require periodic verification that necessary equipment is properly staged.
Response
No tools, hardware, or power source, other than those which are readily available from a variety of sources, are needed to close the air locks or to close spare penetrations. h air locks and spare penetrations can be closed manually with common equipment and tools such as wrenches.
The equipment hatch surveillance is considered necessary, since a power source and special equipment and tools are needed to close the hatch.
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ape 00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NHC QUESTIONS AND COMMENTS m _
i (64) 3.6.8 Coniainment Penetrations i
Bases,
Background:
There appears to be a typo where " isolable" is met.
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Response
The typo will be corrected.
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l AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (05) 3.6.9 pH Adjustment SR 3.0.9.1 requires only a lower limit; whereas, the BASES state that the volume of trisodium phosiphate (TSP)is to create a containment sump water solution with a pli between 7.0 and 9.5. It is SCSB's understanding that the LOCA radiological consequences analysis takes credit for iodine retention in (Se sump solution based on the water pil being greater than or equal to 7.0. The radionuclide releases from the i
containment atmosphere and the consequences of a LOCA would be increased if the pil of the sump water were not adjusted to 7.0 or above. Therefore, the volume of TSP is only to maintain the pli greater than or equal to 7.0 and there is no requirement to keep it less than 9.5. Condition A, SR 3.0.9.1 and the applicable HASES should be made consistent with the assumptions in the AP000 SSAR
Response
From the perspective ofiodine retention, there is no upper limit on post LOCA cooling solution pil. liowever, from the perspective of materials compatibility with the solution, Branch Technical Position MTEB 01 identifies a pil range of 7.0 to 9.5.
Meeting SR 3.0.0.1 assures that the pil is a 7.0. The design of the TSP baskets does not permit storage of the amount of TSP that would result in the post LOCA solution exceeding a pil of 9.5.
The Bases Hackground will be revised to eliminate discussion of an upper pli limit of 9.5, since accident analyses results only depend on the iodine retention provided by a minimum sump pli of 7.0.
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AP800 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QU{BTIONS AND COMMENTS i
(66) 3.6.9 pH idjustment Condition B: Qelete the Condition B DJi statement of"LCO not met for reasons other than A." which is really another basis for entry into LCO 3.0.3 This QIl statement is redundant to LCO 3.0.3. There is no specific justification for this QIl statement addition in the Westinghouse justification document or in the BASES.
Response
The Condition statement will be revised to delete the QIl statement.
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AP@c TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (67) 3.8.9 pH A4ustanent For Condition p of this 1,00, Westinghouse must either go to Mode 5 or justify why the LCO is not applicable in Mode 4 similar to comment (2) above.
Response
i AP600 Actions for LCOs 3.6.1, 3.6.2, 3.6.3, 3.0,4, 3.6.5, 3.6.0, and 3.6.9, which are l
applicable in Modes 1 4, will be revised to specify Mode 5 as the Action end state, i
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE HESPONSES TO NRC QUESTIONS AND COMMENTS (68) 3.6.9 pH idjustment SCSB believesjhat long term verification of the chemiest quality of the TSP needs to be included in the surveillance requirements by the TSs. An example of an acceptable surveillance would be to take a representative sample of the TSP after exposure to the containmen' environment and submerge it in a specified amount of water. The water would have a specific concentration of boron and the water temperature would be controlled. Without agitation, the solution pli should be raised to greater than or equal to 7.0 within a set amount of time. The BASES should provide a description and location of the TSP baskets.
Response
Later.
The response to this comment is under development and will include Surveillance Hequirements which ensure that the required amount of TSP is available, taking into account the potential for chemical degradation.
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l ape 00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS i
(68) 3.6.9 pH djustment SCSB believes.that long term verification of the chemical quality of tb TSP needs to be included in the surveillance requirements by the TSs. An example of an I
acceptable surveillance would be to take a representative sample of the TSP after exposure to the containment environment and submerge it in a specified amount of water. The water would have a specific concentration of boron and the water temperature would be controlled. Without agitation, the solution pH should be raised to greater than or equal to 7.0 within a set amount of time. The BASES i
sht>uld provide a description and location of the TSP baskets.
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Response
Later.
The response to this comment is under development and will include Surveillance 5-Requirements which ensure that the rquired amount of TSP is available, taking i
into account the potential for chemical degradation, i
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ape 00 TECHNICAL SPECIFICATIONS WESTINOHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (69) 3.6.9 pH Idjustment References for the LCO on pit adjustment are needed. At a minimum, the assump-tions involving the pli adjustment system in Chapter 15 of the AP600 SSAR should be included in the reference section.
Response
The following references will be added to the Bases:
1.
SSAll Section 0.3.2,1.4, Containment pil Control 2.
SSAR Section 0.3.2.2.4, pli Adjustment Baskets.
3.
SSAR Section 15.a.5.3.1, Identification of Cause and Accident Description.
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- AP800 TGCHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (70) 3.8.9 pH idjustment The BASES should call out the dodecahydrate form of TSP because it is hydrated and is less likely to absorb large amounts of water from the humid atmosphere and will undergo less physical and chemical change than the anhydrous form of TSP.
Response
The last sentence of the Ilases llackground will be revised as shown below to clearly stato that hydrated TSP will be used:
The dodecahydrate form of TSP (Na3PO,.1211,0) is initially loaded into the baskets because it is hydrated and will undergo less physical change than would anhydrous Na PO 4.s a result of absorption of humidity inside 3
containment.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUNE RESPONFES TO NRC QUESTIONS AND COMMENTS
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(71) 3.6.9 pH Adjustment The allowed co,mpletion times are not conservative when compared to those approved for pil control systems la evolutionary designs, Hesponse The Completion Times will be revised to be identical to the NUllEG 1431 precedents provided for the same safety function, LCO 3.0.7, Spray Additive System, as summarized below.
CONDITION ACTION COMPLETION TIME A.
System inoperable Ilestore 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 11.
Condition A not met MODE 3 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> MODE 5 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> 1
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ape 00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND ConIMENTS (72) 3,8.10 Hydrogen Recombiners Proposed in Westinghouse Letter dated March 12,1997. The BACKGROUND and REFERENCES sections to B 3.6.10 fails to reference the regulatory requirements for the PARS such as 10 CFR 50.44 and GDC 41.
Response
The Hackground and References will be revised to include 10 CFR 50.44 and GDC 41 as follows:
Per 10 CFR 50,44, " Standards for Combustible Gas Control Systems in Light. Water Cooled Reactors"(Ref.1), and GDC 41, " Containment Atmosphere Cleanup"(Ref. 2), hydrogen recombiners are required to reduce the hydrogen concentration in the containment following a loss of coolant accident (LOCA) or steam line break (SLD). The PARS accomplish this by recombining hydrogen and oxygen to form water vapor The vapor remains in containment, thus eliminating any dischargo to the environment. The PARS are selfinitiated in the presence of hydrogen.
REFERENCES 1.
10 CFR 50, Appendix A, GDC 41, 3.
Regulatory Guide 1.7, Reviaion 2.
4.
AP600 SSAR, Section 6.2.4," Containment flydrogen Control Subsystems".
AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSEt' TO NRC QUESTIONS AND COMMENTS (73) 3.6.10 Hydrogen Recombiners in the APPLICABLE SAFETY ANALYSES, what are the conservative assumptions used to maximize the amount of hydrogen calculated? Is Westinghouse using assumptions other than those recommended in RG 1.7? If so, they should be given or referenced, or RG 1.7 should be mentioned? This is needed to consistent with the
- STS, Hesponse The conservative assumptions utilized in the calculation of hydrogen generation are consistent with the assumptions of Regulatory Guide 1.7, Rev. 2 as described in SSAR, Appendix 1A. The 3.6.10 Bases, Applicable Safety Analyses section will be revised to include the following:
To evaluate the potential for hydrogen accumulation in containment following a LOCA, the hydrogen generation as a function of time following the initiation of the accident is calculated. Conservative assumptions recommended by Rc/crence 3 are used to maximize the amount of hydrogen calculated.
REFERENCES 3.
Regulatory Guide 1.7, Revision 2.
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AP900 TECHNICAL SPECIr!CATIINS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (74) 3,6.10 Hydrogen Recombiners Why has all mention of steam line breaks in the Standard Technical Specifications (STSs) been climinated from the AP600 TSs?
Responso The Bases will be revised to include the possibility that hydrogen can be generated following a steam line break. Addition of SLB discussion is as shown in the enclosed markup.
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ape 00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (75) 3.8.10 Hydrogen RecomL!ners increase to be m,R needs to be revised to support determination of the air tem Either the SSA easured in SR 3.6.10.2 or a COL action item to require development of a bench test to be incorpo ated into SR 3.6.10.2. To be consistent with the STSs, SR 3.6.10.2 should include the air temperature increaso, the composition of the test mixture, and the allowable time to reach the prescribed temperature. This informa-tion is needed because during a test the temperature within a plate will be below and above the specified acceptance temperature depending on the location of the thermocouple. Temperatures within the PAR cartridge can vary greatly and are dependant on a number of factors such as location and mounting of the thermocouple, and the proximity of the thermocouple to the hydrogen source.
Response
SSAR sections 6.2.4 and 3.9.6 have been revised to identify parameters to be measured for the surveillance testing.
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ape 00 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QL ESTIONS AND COMMENTS (76) 3.6.10 Hystrogen Recombiners A specific surveillance frequency, such as 1241 months, should be given for SR 3.6.10.1 and 2. It is inconsistent with the STSs to reference the Inservice Testing Program for the surveillance frequency.
Response
The Frequency will be changed to 24 months, to be consistent with NUREG 1431 SR 3.6.8.1 and SR '3.6.8.2 which specify (18) months which is the assumed refueling cycle period, which for AP600 is 24 months.
The associated Bases will also be revised to address the 24 month Frequency.
These changen are included in the enclosed markup.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QL7ESTIONS AND COMMENTS (77) Miselng N'UREG.1431 LCOs liv'.. wen 'iniVon System (STS LCO 3.6.10): The AP600 TSs do not include the 11;drogen Ignition Subsystem (Ills). Operating experience, specifically tha accident at Three Mile Island, has shown that a system for hydrogen control is important to public health and safety as promulgated by 10 CFR 50.34(f), " Additional TMI.
Related Requirements." The Commission stated,in its statement of considerations for 10 CFR 50.34(0, that the requirements in the new rule are necessary for protection of the public and that their costs are not exorbitant. Westinghouse has used the criteria in the NRC Policy Statement on TS Improvement to identify the systems to be included in the AP600 TSs. Criterion 4 of the polley statement calls out structures, systems and components which operating experience or probabilistic safety assessment has shown to be important to public safety. Based on Criterion 4, the statihas concluded that systems provided to meet the requirements of 10 CFR 50.34(fX2Xix) should be included in the AP600's TSs. The precedent for this decision was made during the evolutionary design certificatinn for the System 80+.
Response
Availability requirements applicable to the AP600 Hydrogen Ignitors have been specifled in SSAR Section 10.3, Investment Protection Short Term Availability Controls.
AP600 TECHNICAL SPECIFICATIONS TESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (78) Vacuum Relief System (STS LCO 3.6.12)
There is no justification for the deletion of this LCO other than a statement that it does not apply. The HASES of LCO 3.6.4 is the only location which implies that the worst negative pressure event for containment is a loss of AC power coupled with an extremely cold outside temperature. This is the only credible event identified which j
could cause sufficient negative pressure inside containment to challenge the steel containment shell. There are no analyses results report in the BASES or the SSAR to confirm the severity of this event. Westinghouse should provide this information and include it in the HASES of LCO 3.6.4 and confirm if thic is the only event.
Response
The following change will be made to the Bases of LCO 3.6.4, Applicable Safety Analyses:
IThe containment was also designed for an external pressure load equivalent to 3.0 psig. The limiting negative pressure transient is a loss of all AC power sources coincident with extreme cold weather conditions which cool the external surface of the containment vessel. The initial pressure condition used in this analysis was 14.5 psia. This resulted in a minimum pressure inside containment which is within the design capability Since the containment design limits can be met by ensuring compliave with the initial pressure condition, NUREG 1431 LCO 3.6.12, Vacuum Relief System is not applicable to the APG00 containment.1 Additional changes have been made to this section of the 3.6.4 Bases to more completely address external pressure events in response to NRC Comment # 29.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS w-_
(79) Shield Huilding (STS LCO 3.8.19)
The deletion of.this LCO requires discussion regarding how the structural integrity, functional spaces and surfaces of the shield building will be inspected. How is NUREG 1431 SR 3.6.19.3 incorporated into LCO 3.6.1 or LCO 3.6.6 as a part of f
structural integrity inspections of the Containment Leak Rate Test Program.
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Response
Tim NUREG 1431 LCO 3.6.10, Shield Building is only needed if shield building operability is necessary to limit radioactive leakage from the containment as assumed in the accident analyses. Since, for AP600, the shield building is not designed to be leaktight and does nat limit radioactive leakage, STS LCO 3.6.19 does not apply.
Surveillance of the structural integrity, functional spaces and surfaces of the shield building is only required to the extent that the shield building forms part of the air flow path inspected in accordance with AP600 surveillance SR 3.6.6.5.
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AP600 TECHNICAL SPECIFICATIONS WESTINGHOUSE RESPONSES TO NRC QUESTIONS AND COMMENTS (80) 5.5 Programs and Manuals A PCS surveillance program should be established. The design basis is predicated on the expected performance of the water distribution system (PCCWST, flow lines, orifices, distribution bucket, and weirs) and the surface conditions on the exterior containment dome and vertical shell (wetability, uniformity and area coverage). The annulus air flow path (air inlets in the shield building, downcomer section, bafIle and turning vanes, riser section, chimney and exhaust) and the upper annulus drains are also key components of the PCS. Unanticipated failure modes and degradation need to be considered in this program. For example:
(a) Monitoring should include the baffle plates and connectors for possible thermal or vibration induced problems.
(b) The alignment of the distribution bucket and the weirs needs to be verified periodically for possible problems resulting from long term settling of the structures.
(c)
The wetability, including uniformity and area coverage, of the exterior surface needs to be monitored periodically and on a case by case basis following unexpected events such as fires or chemical accidents.
(d) Blockage of the PCS air inlete, exhaust or the upper annulus drains, although not expected, from environmentally induced factors such as ice or wind blown debris, or from biological induced factors such as bird or animal nests, needs to be trackable and,if possible, corrective actions taken and documented.
Response
(a)
The baffle plates have been designed to accept the maximum and minimum site parameter temperatures to preclude thermalinduced problems. Wind induced vibrations have been evaluated by Westinghouse and discussed with the staf1'.
(b) Settling of structures and setup tolerances have been considered and accounted for in th design of the water distribution system.
(c)
PCS system level inservice testing, specified in SR 3.6.6.6 and SSAR Table 3.9 17, requires periodic monitoring of containment surface wetability.
(d) SR 3.6.6.5 requires periodic inspection of the PCS air flow path from inlet to outlet.
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