View source for NSD-NRC-97-5452, Forwards Responses to Questions Re Pressure Isolation Valves & Safety Classification of Portions of Chemical & Vol Control Sys & FSER Open Item 720.429F.Draft Ssar Changes Included.Changes Will Be Included in Ssar Rev 18

{{Adams
| number = ML20202A919
| issue date = 11/21/1997
| title = Forwards Responses to Questions Re Pressure Isolation Valves & Safety Classification of Portions of Chemical & Vol Control Sys & FSER Open Item 720.429F.Draft Ssar Changes Included.Changes Will Be Included in Ssar Rev 18
| author name = Mcintyre B
| author affiliation = WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
| addressee name = Quay T
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05200003
| license number = 
| contact person = 
| document report number = NSD-NRC-97-5452, NUDOCS 9712030021
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 41
}}

=Text=
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      ?1 Westliighouse               Energy Systems                                        85 R 4 g ,p   ,g ,,, g 3 g 333 Electric Corporation DCP/NRCll50 NSD-NRC-97 5452 Docket No.: 52 003 November 21,1997 Document Control Desk U.S. Nuclev Regulatory Commission
             - Washington, DC 20$55 ATiliNT10N: T. R. QUAY SUIDECT:          AP600 RESPONSE TO FSER OPEN ITEM 720.429F AND TO REQUEST FOR ADDITIONAL INFORMATION

==Dear Mr. Quay:==

==Subject:==
Responses to Questions Related to Pressure isolation Valves and CVS Classituation Attached are responses to questions related to pressure isolation valves (PlVs) and the safety classification of portions of the chemical and volume control system (CVS). These questions were included in letters from the NRC dated August 25,1997 and October 16,1997. Included with the response are draft SSAR changes. These changes will be included in SSAR Revision 18.
These item will be statused as Action N or Confirm W pending inclusion in a SSAR revision as noted below.
OITS #      DSER/RAI #         Status
                $716        ---..            Action N 6039        230.140F         Confirm W 6040        250.30F          Confirm W Action N                                                                      I 6041        250.31F 6042 6043 250.32F 250.33F Action N Confirm W
{@
l          - These responses include a request for exemption '.om requirements in 10 CFR 50. The fonnal request
'-            will be transmitted under separate cover, K0            3
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IXTiNRCl150
                                                              ;NTD-NRC-97 5452                                                         - - 2                                                                    November 21,1997 4            4
_ Please contact Donald A. Lindgren at (412) 374-4856 w ith any questions.                                  _
C firian A. McIntyre, Manag i                                                             Advanced Phnt Safety and Licensing                                                                                                                                                                                 !
jml Attachment cc: J. M. Sebrosky, NRC (w/Attac;iment) -
N. A Liparulo, Westinghouse (w/o Attachment)                                                                                                                                                              .
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NRCTELEPHONE CONFERENCE OPEN ITEM OITS #5716 slC Letter dated August 25,1997 documenting telephone conference request -
Nestinghouse should explain how the CVS Classification complies with 10CFR50.55a for RCPB classification, including which valves are credited for automatic isolation of the CVS and how those valves are qualified, tested, and subjected to 'riodic surveillances which ensure the safety function and the leak tightness of these valves and otner pressure isolation valves is maintained throughout the plant life, in addition, Westinghouse will n, 'd to justify why RO l.26 was not followed to make the CVS piping ASME Section Ill, Clas. 2, or (under some limited circumstances) Class 3.
Response:                                                                                    .
De response to FSER Open Item 230.140F provides a justification of a noasafety related classi0 cation for the purification subsystem of the chemical and volume control system (CVS) ne request ior exemptions from regulation previously submitted with letter DCP/NRC1029, dated September 12,1997 will be updated to include a request for exemption from the definition of reactor coolant pressure boundary in 10CFR50.2 for the AP600 chemical and volume control system.
SSAR Revision:
See the response for FSER Open item 230.140F
[ W85tingh00$8

NRC FSER Open hem FSER Open item 230.140F Per the definition of Reactor Coolant Pressure Boundary (RCPB) as defined in 10 CFR 50.2, the staff believes that most of the AP600 Chemical and Volume Control System (CVS) should be defined as RCPB piping. Although the CVS RCPB piping meets the exclusion requirements of 10 CFR 50.55a(cX2), NRC Regulatory Guide 1.26, Revision 3, would recommend that the CVS piping be constructed as ASME Code, Section 111, Class 2. In addition,10 CFR 50, Appendix A General Design Criteria 14,30, and 32 emphasize that the reactor coolant pressure boundary components be designed, fabricated, erected, and tested to the highest quality standards practical. In a letter to Westinghouse dated August 25,1997, the staff identified its concern relative to the quality group classification of the portion of the CVS inside containment. In a {{letter dated|date=September 11, 1997|text=letter dated September 11,1997}}, Westinghouse provided justification for its classification of the CVS. In a telecon with Westinghouse on October 1,1997, the staff stated that the justification provided by the {{letter dated|date=September 11, 1997|text=September 11,1997, letter}} was insufficient. Westinghouse committed to reexamine the design classification of the CVS piping and determine if additional design or testing features could be included to resolve the classification issue. Pending acceptable resolution of the CVS piping classification, the sutif considers this an FSER Open item.
Responset The design classification of the chemical and volume control system purification loop has been examined in consideration of the NRC comments, in response to resolving this classification issue, a            ,
modification in the chemical and volume control system purification loop design was implemented and a request for exemption to the definition of the reactor coolant pressure boundary is proposed. With the design modifications and the exemption to 10CFR50.55a, the AP600 chemical and volume control system classification will be consictent with Regulatory Guide 1.26.
As illustrated in Figure 230.140F 1, a third isolation valve was added to the chemical and volume control system purification loop downstream of the two safety related motor opeated purification isolation valves. His third valve was added to meet Regulatory Guide 1.26 guidance on class transitioning, ne two safety related normally open remotely operated gate valves, which automatic.tlly close on a low pressuriier level signal, establish the class transition from class A to class C. De thstd valve is a safety related remotely operated glohe valve and also closes on a low pressurizer level signal. His third isolation valve defines the transition from class C to class D and defines the reactor coolant pressure boundary.
The purification retum to the RCS includes three series check valves. The first check valve downstream of the regenerative heat exchanger is redesignated from a class D to a class C valve as illustrated in Figure 230.140F 1, his valve defines the reactor coolant pressure boundary on the purification return line to the reactor coolant system.
i 230,140F-1

NRC FSER Open item pp q He reactor coolant pressure boundary for the AP600 chemical and volume control system purification loop is Ofined by the third isolation valve on the purification lines which directly interface with the reactor coolant system. His reactor coolant pressure boe: dary is located inside containment. By defining the reactor coolant pressure boundary for the AP600 chemical and volume control system inside containment, the reactor coolant pressure boundary as defined in 10CFR50.55a is not explicitly met. Herefore, an exemption to the reactor coolant pressure boundary definition in 10CFR50.55a, is requested.
nc Reactor Coulant Pressure Boundary is defined in the NRC Code of Federal Regulations, Section 10CFR 50.2 as "Lil those pressure-containing components of boiling and pressurized water-cooled nuclear power reactors, such as pressure vessels, piping, pumps, and valves, which are:
(1)      Part of the reactor coolant system, or (2)      Connected to the reactor coolant system, up to and including any and all of the following:
(i) De outermost containment isolation valve in system piping which penetrates primary containment, (ii) The second of two valves normally closed during normal reactor operation in system piping which does not penetrate primary reactor containment, (iii) The reactor coolant system safety and relief valves."
The NRC Code of Federal Regulations, Section 10CFR50.55a requires the Reactor Coolant Pressure Boundary be class A (ASME Boiler and Pressure Vessel Code Section LI, Class 1). According to 10CFR$0.55a, components which are conr.ected to the RCPB that can be isolated from the RCS by two valves in series (both closed, both open, or one closed and the other open) with automatic actuation to close can be classified as class C (ASME Section III, class 3). Regulatory Guide 1.26 classification guidance for the reactor coolant pressure boundary is in agreemerit with 10CFR50.55a.
Westinghouse is requesting an exemption to the definition of reactor coolant pressure boundary to end the reactor coolant pressure boundary inside containment. He reactor coolant pressure boundary would end at the third isolation valve between the reactor coolant system and the chemical and volume control system. De justification for this exemption is based on the difference between the AP600 and plants in use or under consideration at the time the definition for reactor coolant pressure boundary was written.
The enteria for exemptions in 10CFR50.12 have been reviewed for applimbility to a change in the definition of reactor coolant pressure boundary, This exemption request satisfies three of the criteria.
The applicable criteria are addressed below.
230.140F '2

1 NRC FSER Open item y e];l
                                                                                                                                                                                 ~
(a) (2) (ii) Application of the regulation in the panicular citumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule;

===Response===
The definition of reactor coolant pressure boundary was added to 10 CFR 50.2 in conjunction with the addition of 50.55a that requires use of the ASME Code for systems and component important to safety. (Federal Register Volume 36, Number 114, JuM 12,1971, pp.ll423-11428.) General Design Criterion 1 is cited in the discussion in the Federal Register. GDC I 4
requires that structures, systems, and components of nuclear power plants which are important to safety be designed, fabricated, erected, and tested to quality standards that ie0cct the importance of the safety functions to be performed. De term important to safety is not defined in either General Design Criterion I or the Federal Register discussion. Rather, a definition of reactor coolant pressure boundary was created that would capture many of the systems and components thM are important to safety in a plant with active safety systems that are located outside containment. His dennition of the RCPB is appropriate in cases where a line is connected to the RCS and leaves the containment where that line has to function to petform a safety function such as decay heat removal or safety injection. He chemical and volume control system designs in such operating plants were required to use the letdown lines to allow boration for cold shutdowns and thus were important to safety. In addition, these operating plants circulated radioactive water (unpurified reactor coolant) outside containment and as a result needed class C equipment to prevent the release of radioactivity from leaks or high energy line breaks.
De AP600 chemical and volume control system does not have a safety related function to allow boration of the reactor to support safe shutdown. Safety-related core makeup tanks provide boration of the AP600 to szpport safe shutdov~. He AP600 does not circulate reactor coolant outside containment. 'There ve limited times when cooled, purified reactor coolant is diverted
                      .from the chemical and volume control system to the waste processing system. This line is a moderate energy line and leaks from it would not exceed allowable dose limits. In addition, there are three isolation valves and a now restricting orince between the chemical and volume control system purification loop inside containment and the liquid radwaste system outside containment. Two of these valves are saf-ty related containment isolation valves. These valves close on a containment isolation signal as well as a low pressurizer level signal.
The termination of the reactor coolant pressure boundary is provided by three valves located in the line between the reactor coolant system and the chemical and volume control system. These safety-related valves are designed, qualified, inspected, and tested to provide for their isolation function. The third valve is also provided in a class C section of line. Rese valves all receive a signal to close to isolate the reactor coolant system on a low pressurizer level to prevent a W westinghouse

NRC FSER Open item y y break of a high energy, nonsafety related line in the chemical and volume control system purification loop from becoming a potential loss-of-coolant-accident. He chemical and volume control system purification subsystem is located inside the containment and thus a leak or break would be contained within the rextor containment.
(a)(2) (iv) ne exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption;

===Response===
De current AP600 chemical and volume control system design incorporates design features that result in a benefit to public health and safety over operating chemical and volume control system designs. He AP600 chemical and volume control system perification loop is located entirely inside the reactor containment. His reduces the number of pountial leak paths from equipment and interconnections that are traditionally locatea outside containment. As illustrated in Figure 230.140F-1, the Westinghouse chemical and volume control system design provides isolation capability beyond that which is implemented in current operating plants. There are five safety-related, active, remotely operated valves and one nonsafety-related valve which are designed to close to protect the containment integrity between the reactor coolant system and the chemical and volume control system letdown line outside of contunment. Additionally, the use of nonsafety related components relaxes the inspection requirements compared to components constructed and inspected to ASME Section III, Class 2 requirements and thus reduces the occupational radiation exposure and generation of low level radioactive waste.
The only potential reduction in public safety could be the possibility that a seismic event might have a greater chance of causing a break of a chemical and volume control system line and releasing activity from the plant. Since the nonsafety related purification loop is located inside containment and is isolated by three isolation valves (one of which is diverse), the probability of release of activity from such an event is insignificant.
(a) (2) (vi) Rere is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. If such condition is relied on exclusively for satisfying paragraph (a)(2) of this section, the exemption may not be granted until the Executive Director for Operations has consulted with the Commission.
230.140F-4 i
l

NRC FSER Open item
        -                                                                                                     i      i

===Response===
ne regulation was written to renect the requirements for designs in operation and under review at the time. There is an presupposition of designs with active safety systems located outside containment.
De requirements for qualification, and inspection, and testing of all active safety-related valves has become much rnore extensive in recent years than was required for even containment isolation valves at the time the definition was ver;tten. The isolatio.. valves between the reactor coolant system and chemical and volume control system are designed and qualified for design conditions that include closing against blowdown flow with full system differential pressure.
Rese valves are qualified for adverse seismic and environmental conditions. The valves are subject to inservice testing including operability testing. The operability testing is a diagnostic test against operating flow and differential pressure.
Supporting Technical Justification ne portion of the AP600 chemical and volume control system purification loop which is designated as reactor coolant pressure boundary meets the requirements of 10CFR50, Appendix A General Design Criteria 14,30, and 32. Based on the limited exemption to the definition of the reactor coolant pressure boundary as discussed above, the AP600 puri6 cation loop is not considered to be part of the reactor coolant system pressure boundary.
Although the AP600 chemical and volume control system is not a safety-related system it is a reliable system, using high quality industry standards. ANSI B31.1 and ASME Code, Section VIII are used for the construction of the piping, valves, and components. Experience with these standards has shown that there is signincant margin for seismic loads. De chemical and volume control system components are located inside the containment which is a seismic Category I structure.
High energy piping is evaluated as part of the pipe break hazards evaluation. He potential for subcompartment pressurization, pipe whip, jet impingement, and Gooding is considered as required for breaks in the nonsafety-related potions of the chemical and volume control system piping. The chemical and volume control system is located away from safety-related systems and compor.ents in a separate room which minimizes the impact of postulated chemical and volume control system pipe breaks.
n: chemical and volume control system inside containment is rated at 3100 psig. His pressure exceeds the reacer coolant system desil n pressure. Therefore, overpressurization of the chemical and volume control system ptaif.cdon loop is not a concern as a result of isolating the puriGcation loop and exposing the piping and components to full reactor coolant system pressure. Intersystem loss-of-
[ W85tingh00S8

NRC FSER Open item
          -                                                                                                                                                                           g=  iig coolant accident is precluded. Chemical and volume control systems (or equivalent) that are operating                                                                               s in many of the operating nuclear power plants include a portion of the system inside containment with a design pressure considerably lower than the reactor coolant system operating pressure. This includes                                                                              y portions of the system that are considered to be reactor coolant pressure boundary. Rese systems include a safety valve set at the lower pressure to protect the system from rupture if a containment isolation valve closes. As a result, closure of the containment isolation valves in an operating piant will not stop the now of reactor coolant unless one of the upstream isolation valves also close.
Because of the higher design pressure, the AP600 chemical and volume control system does not rely on safety valves to provide overpressure protection.
Chemical and volume control system leakage inside containment is detectable by the reactor coolant leak detection function as potential reactor coolant pressure bondary leakage. His leakage must be identified before the reactor coolant leak limit is reached. He nonsafety-related classification of the system does not impact the need to identify the source of a leak inside containment. De leak detection capability of the AP600 chemical and volume control system is enhanced relative to that of operating plants where the chemical and volume control system purincation equipment is located in the auxiliary building The AP600 purification loop is in operation during normal ope. on whenever the reactor coolant pumps are operating. He containment isolation valves on the chemical and volume control system letdown line are closed dunng normal operation. These containment isolation valves are open for brief periods to letdown to the liquid radwaste system. In contrast, the containment isolation valves in operating plants are open during normal chemical and volume control system operation.
Comparison of Altcmate System Desiens Figure 230.140F-2 illustrates a comparison between Westinghouse operating plants and the proposed AP600 design.
Westinghouse operating plants use a chemical and volume control system design that cools ani depressurizes the reactor coolant prior to purification. In these designs, the chemical and volume control system purification equipment is located outside the containment boundary. The class transition from class A to class B is accomplished through two normally open remotely operated valves at the chemical and volume control system interface with the reactor coolant system. The containment isolation valves serve as the class transition from class B to class C. The chemical and volume control system purification equipment located outside containment is designated as class C because of containment of radioactivity during normal operation and to support safe shutdown.
230.140F-6 1
l

a   .
NRC FSER Open item                                                                                                  ,
The limited exemption to 10CFR50.55a is justified by the higher degree of safety exhibited by the AP600 design when compared to operating plants or attemate designs meeting the requirements of 10CFR50.55a.
Conclusion The requested limited exemption from the definition of reactor coo! ant pressure boundary' and the design of the AP600 with a nonsafety related purification subsystem satisfies the purpose of 10 CFR 50.55a the criterion given in 10CFR Appendix A and the definition of reactor coolant pressure boundary that structures, systems, and components of nuclear power plants which are important to safety be designed, fabricated, erected, and tested to quality standards that reDect the importance of the safety functions t6 be performed. The AP600 design with isolation valves at the interface between the reactor coolant system and chemical and volume control system which are qualified, inspected, and tested, a tighter containment, and the purification loop located inside containment satisfies the objective of preserving (L reactor coolant pressure boundary better than operating plant designs that are licensed to the current regulatory requirements.
Summary of Exemption
: 1. For the AP600 chemical and volume control system, the reactor coolant pressure boundary. ends at the third of three valves capable of automatic closure.
: 2. The third valve provides an increase in the probability of achieving reactor coolant pressure boundary isolation and is consistent with regulatory guidance, specifically Regulatory Guidel.26, on transitioning from class C to class D.
: 3. Remotely operated valves that provide reactor coolant pressure boundary isoiation between the reactor coolant system and the chemical and volume control system will be subject to inservice testing which will include operability testing to verify their ability to isolate the reactor coolant system. The operability testing will be conducted using nonintrusive techniques to access valve operability under operating flow and differential pressure test conditions.
230.140F-7

NRC FSER Open item
       .                                                                                              :e ami g g :.              ;;
AP600 Current 1  AUX IRC ,   ggg A 0                _            _
{S                                                                o ,             , o CVS PURIRCATION        ,1,
                                                                     'l' 1     A           1             gg HX DEMIN. FLT            V3    V4      l   V5 RCS                      ,
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L_                _j                            siz iso RCS PB AP600 Revised AUX IRC     BLDC A C    C D           _            _
CS                                                               D 9             8 D V1     V2 A C V3 (1)      CVS PURinCATION         ,3,  1 A           k HX, DEMIN. ftT     'l' y4 RCS Cl0                                          V5          V6 RCP                           i                       .
SUCT.                         L                      J                        stoo iso RCS PB Notes (1) Fiow over sect.
Figure 230.140F-1 Revised AP600 CVS Design 230.140F-8

NRC FSER Open hem
                                                                                                  ;.-   tg 1
West. Operating Plants iRC 080 m
                                                 -4ll b            jh    PRT A B RCS CL      w  .v2
[Nl             llM  y3                  v4           v5 o.m$n, nt.
neo.a.
                                                 -ill Lg                               RCS P9 2500 600 Revised AP600 AUX IRC  BLLC A C     C D        ---
RCS a       w   v2      vs                            j o e         e o
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NRC FSER Open item
                                                                                                                                               + =ma
:'      in SSAR Revisions:
Add the following 2 valves to Table 3.2 3 Tag Number          Description                  AP600      Seismic    Principal Con- Comments Class      Category struction Code Chemical and Volume Control System (CVS) Location: Containment, Auxiliary Building, and Annex Building CVSiPINV00)         RC11%ifisitisn'St6p           C          1          XSMdIld CVS PIEVQ80        .RCS'M5hsifsoIR'oisn(Ifish C              1          XSMIOlid ChicicVilvo Add the following 2 valves to Table 3.9-12 Valve No.            Description                                                                                                 Function (*)
Chemical and Volume Control System CVS$V003              Riscl6st66fiit'Syded'MddhBb'dfinh':                                                                         1 CYpl%y0N             Rse'cid/ Cf6fioi3pitshiMdi&itih6'ReMid DhslCilchffitf 6                                                     (
Revise Table 3.916 to add the two valves and a note 32 to apply to the isolation valves between the RCS and CVS. (attached)
Revise Figure 3E 5 to include an additional isolation valve.                                                                                       .
Revise the third paragraph of Section 5.2 to include a revised definition of reactor coolant pressure boundary as follows:
The term reactor coolant system, as used in this section, is defined in Section 5.1. "' hen $c term-ThshP60Q reactor coolant pressure bound          is used in $i: docu:ncn:, i:: definitica is consistc6sMiti(lthat of 10 CFR 50.2;'6ichs'tidA       M66da63663E6f ibEffii'rd is'6failon'filYe betWeen'the fe$cilibsofEs'ysthm'5hithdIciieihih51'aist'v'ohhhsdntr61'$y'slisi. Sc6tibNY fd N6'vides'th'eQ65tificAti66'f6ka limit'e' d 'oiesspt(6n'to th6'de5nitidi{'of th6'ieici6Ed561sdfM654uie bo6slary9x -
Add subsection 5.2.1.3 to address the exemption from the definition of Reactor coolant pressure boundary as follows:
230.140F-10

               . NRC FSER Open item -
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                       .-.                 a for~e, thettoo:requtremcots'.
isola <n . afet. activo,n Revise Table 5.4-16 to add a valve as follows:
1 Normal AP (PSIG)(a)                                           Design AP (PSIG)
                                                                               .e l
OPEN                      CLOSE                            OPEN                       CLOSE CVS P68fdadd5'L-in Isolation                                                 2235                         2235                          2485                           2485 l                Vahes (CVS-PL V001, V002;-003)                          '
l 230.140F-11 W
Westinghouse I
1 l

NRC FSER Open item
                               ~
Revise 9.3.6.3.7 to delete the reference to gate valves for use as purification stop valves as follows:
Purification Stop Vaha These normally open, motor operatedevalves are located inside containment and close automatically on a loWpressurizer level signal from the protection and safety monitoring system to preserve reactor coolant pressure boundary and to prevent uncovering of the heater elements in the pressurizer. The valves fail "as is" on loss of power and manual control (open/ auto /close) is provided in the main control room and at the remote shutdown workstation.
Revise Figure 9.3.6-1 to show additional valve and revised classifcation boundary (attached). Add note 16 as follows:
: 16. Valve is installed with flow over the seat.
ITAAC Revision:
Revise Table 2.3.2-1 l
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. l,. #
    .       - 3. Design of Structures, Components, Equipment, and Systems Table 3.916 (Sheet VALVE INSERVICE TEST l Valve Tag                                                             Valve    Safety Related Number                                 Description UI                Type        Missions            Safet)
Instrument Air Supply Outside Containment Isolation   Remote    Maintain Close      Active-to-CAS-PL V014 Transfer Close      Containm<
Safety Sea Remote P/
Instrument Air Supply Inside Containment isolation    Check     Maintain Close      Active CAS-PL-VOIS Transfer Close      Containmc
                                                                                                                  - Safety Sc '
Service Air Supply Outside Containment isolation      Manual    Maintain Close      Contain CAS-PL V204 Safety Sea Service Air Supply Inside Containment Isolation       Check     Maintain Close      Containmc CAS-PL V205 Safety Sei CCS PL Y200      CCS Containment Isolation Valve - inkt Line ORC        Remote    Maintain Close      Active Transfer Close      Containmq Safety Sea Remote k CCS-PL V201       CCS Containment Isclation Valve - Inlet Line IRC      Check     Maintain Close      Active Transfer Close      ContainmW Safety Sed CCS PL V207      CCS Contdnment Isolation Valve Outlet Line IRC         Remote    Maintain Close      Active Transfer Close      Containmg Safety Sea Remote Pi CCS PL V208      CCS Containment isolation Valve - Outlet Line ORC      Remote    Maintain Close      Active Transfer Close      Containmi Safety Sea Remote q
        -l    CVS-PL-V001       RCS Purification Stop                                 Remo:e    Maintain Close      Active Transfar Close      RCS Presi Remote Pi l CVS PL V002         RCS Purification Stop                                  Remote    Maintain Close      Active Transfer Close      RCS Pres:
Remote Pi l CVS-PL V003          RCS Purification Stop                                 Remote    Maintain Close      Active l                                                                                      Transfer Close      RCS Press l                                                                                                          Remote Pi Resin Flush IRC isolation           !                 Manual    Maintain Close      Containmq CVS-PL-V040 Safety Sea MillglI0llSe N

r-            N of 19)
LEQUIREMENTS ASME IST Functions t21 Category                                                       Inservice Testing Type and Frequency   IST Notes A        Remote Position Indication, Exercise /2 Years                                              13,27,30, ailed Containment Isolation Leak Test (See N(tes)                                                      31 it isolation Leak:ge                          Exercise Full Stroke / Refueling Shutdown
 -ition
 .                                  Operability Test /See Notes Containment isolation Leak Test (See Notes)                                                    18,27 AC it Isol: tion                      Check Exercise / Refueling Shutdown Le:k:ge 27 it isolation              A       Containment Isolation Leak Test (See Notes)                                                                  bp.-t      a
                                                                                                                                                       *J E lb Leakrge it isol: tion            AC       Containment isolation Leak Test (See Notes)                                                      27        M E!'J E E Letkage                                                                                                                                          {pg A        Remote Position Indication, Exercise /2 Years                                              14,27,30, it Isolation                      Containment isolation Leak Test (See Notes)                                                      31       Also Availablo on Leakage                         Exercise Full Stroke / Cold Shutdown                                                                        Aporture Card sition                            Operability Test /See Notes Containment isolation Leak Test (See N>tes)                                                    14,27 AC at isolation                      Check Exercise / Cold Shutdown Leakage Remote Position Indication, Exercise /2. Years                                            14, 27, 30.31 A
nt isolation                      Containment isolation Leak Test (See Notes)
   . Leakage                         Exercise Full Stroke / Cold Shutdown sition                           Operability Test /See Notes Remote Position Indication, Exercise /2 Years                                            14, 27, 30,31 A
nt Isoir. tion                    Containment Isolation Leak Test (See Notes) iLeakage                          Exercise Full Stroke / Cold Shutdown sition                           Operability Test /See Notes B        Remote Position Indication, Exercise /2 Years                                                6,32 M are Boundary                     Exercise Full Stroke / Cold Shutdown sition                           Operability Test /See Note B       Remote Position Indication, Exercise /2 Years                                                6,32 at are Boundary                     Exercise Full Stroke / Cold Shutdown sition                          Operability Test /See Note B        Iwmote Position Indication, Exercis:/2 Years                                                   6,32 are Boundary                      Exercise Full Stroke /CoM Shutdown sition                           Operability Test /See Note A        Containment isolation Leak Test (See Ifotes)                                                     27 nt isolition t Leakage Revision: 18 l              _
Draft,1997           4 3.9-131 i                                                                              l l
                                                                                                                                                          /

1 s **
,         3. Design of Structures, Components, Equipment, and Systems i
Table 3.916 (Sheet VALVE INSERVICE TEST Valve Tag                                                  Valve    Safety Related Number                                 Descriptionm        Type       Missions           Safety Ilush Line Containment Isolation Relief    Relief    Maintain Close     Active CVS PL V042 Transfer Open      Containme; Transfer Close     Safety Sea Letdown Containment isolation IRC          Remote    Maintain Close     Active-to-P CVS-PL V045 -
Transfer Close     Containmei Safety Seat Remote Po!
Letdown Containment Isolation ORC          Remote    Mainutin Close     Active-to-F CVS-PL V047 Transfer Close     Containmes Safety Seat Remote Po:
Check     Maintain Close     Active l CVS-PL-V080        RCS Purification Return Line Check Valve Transfer Close     RCS Pressi l
RCS Purification Return Line Stop Valve    Check     Maintain Close     Active CVS.PL-V081 Transfer Close     RCS Pressi RCS Purification Return Line Check Valve   Check     Maintain Close     Active CVS-PL-V082 Transfer Close     RCS Pressi CVS PL-V084       Auxiliary Pre .urizer Spray Line Isolation Rernote   Maintain Close     Active-toJ Transfer Close     RCS Press Remote Po-CVS-PL-V085       Auxiliary Pressurizer Spray Line           Check     Maintain Close     Active Transfer Close     RCS Pressi CVS PL V090       Makeup Line Containment Isolation          Remote    Maintain Close     Active Transfer Close     Containmei Safety Seal Remote Po CVS-PL-V091       Makeup Line Containment Isolation          Remote    Maintain Close     Active Transfer Close     Containmei Safety Seu Remote Po CVS-PL-V092       Hydrogen Addition Containment Isolation    Remote    Maintain Close     Active-to-F Transfer Close     Containmei Safety Seat Remote Po
     ~x

N, L
of 19) lEQUIREMENTS ASME IST Functi:ns(2)        Category                inservice Testing Type and Frequency                       IST Notes AC     Containment Isolation Leak Test (See Notes)                                    27 lt isolation                 Class 2/3 Relief Valve Tests /10 Years and 20% in 4 Years Leakage A    Remote Position Indication, Exercise /2 Years                                27,31 tiled t isolation                 Containment isolation Leak Test (See Nc.tes)
Leak:ge                     Exercise Full Stroke / Quarterly ition                      Operability Test /See Note A    Remote Position Indication, Exercise /2 Years                                27,31 tiled t isol tion Le:kage Containment isolation Leak Test (See Notes)
Exercise Full Stroke / Quarterly MMEC ition                      Operability Test /See Note                                                                APERTURE BC     Check ExerciseJCold Shutdown                                                    6             CARD re Boundary BC    Check Exercise / Cold Shutdown 6, 8      Also Available on re Boundary                                                                                                          APerturo Card BC    Check Exercise / Cold Shutdown                                                  6 re Boundary B    Remote Position Indication, Exercise /2 Years                              22,30,31 tiled re Boundary                Exercise Full Stroke / Cold Shutdown ition                     Operability Test /See Notes BC    Check Exercise / Cold Shutdown                                                  22 re Boundary A     Remote Position Indication, Exercise /2 Years                               27,31 t isolation               Containment Isolation Leak Test (See Notes)
Leekage                   Exercise Full Stroke / Quarterly ition                     Operability Test /Sce Note A    Remote Position Indication, Exercise /2 Years                               27,31
    .t Isoir. tion             Containment isolation Leak Test (See Nctes)
Leakage                  Exercise Full Stroke / Quarterly
     .ition                    Operability Test /See Note A    Remote Position Indication, Exercise /2 Years                               27,31 ailed
     ,t Isolation              Containment Isolation Leak Test (See Nctes)
Leakage                 Exercise Full Stroke / Quarterly Operation
      .ition                   Operability Test /See Note Revision: 18 Draft,1997
                                                           .l                                       -                   3.9-133 l
                                                                                                                                 /       j

s' RW u
       -       ne valves are closed when the plant is in modes above hot shutdown
: 17. Normal residual heat removal system containment penetration relief valve (RNS-V021) and containment isolation motor-operated valve (RNS V023 pre subjected to containment leak testing by pressurizing the lines in the reverse direction to the flow which accompanies a containment leak in this path.
: 18. His note applies to the CAS instrument air containment isolation valves (CAS-V014. V015). It is not practical to exercise these valves during power operadon or cold shutdowns. Exercising the valves during these condidons may result in some air-operated valves inadvertently opening or closing, resulting in plant or system transients. These valves are exercised during refueling conditions when systetr . nd plant transients would not occur.
: 19. Primary sampling system containment isoladon check valve (PSS V024)is located inside containment an? considerable effort is required to install test equipment and cap the discharge line. Exercise testing is not performed during cold shutdown operations for the same reasons. Dese valves are exercised during refueling conditions when the radiation levels are reduced.
: 20. This note applies to the main steam isolation valves and main feedwater isoladon valves (SGS-V040A/B, V057A/B). He valves are not full stroke tested quarterly at power since full valve stroking will result in a plant transient during normal power operation. Retefore, these valves will be partially stroked on a quarterly basis and will be full stroke tested on a cold shutdown frequency basis, ne full stroke testing will be a full " slow" closure operation. De large size and fast stroking nature of the valve makes it advantageous to limit the number of fast closure operations which the valve experiences. He timed slow closure verifies the valves operability status and that the valve is not mechanically bound.
: 21. post 72 hour check valves that require temporary connections for inservice-testing are exercised every refueling outage. Dese valves require transport and installation of temporary test equipment and pressure / fluid supplies. Since the valves are normally used very infrequently, constructed of stainless steel, maintained in controlled environments, and of a simple design, there is little benefit in testing them more frequently, For example, valve PCS V039A is a simple valve that is opened to provide the addition of water to the PCS post-72 hour from a temporary water supply. To exercise the valve, a temporary pump and water supply is connected using temporary pipe and fittings, and the flow rate is observed using a temporary flow measuring device to confirm valve operation.
: 22. Exercise tes'.ing of the auxiliary spray isolation valve (CVS V084, J085) will result in an undesirable temperature transient on the pressurizer due to the actuadon of auxiliary spray flow. Hertfore, quarterly exercise testing will not be performed.
Exercise testing will be performed during cold shutdowns.
I l
: 23. Dermal relief check valves in the normal residual heat removal suedon Sne (RNS-V003A/B) and the Chemical and Volume l
Control System makeup line (CVS-V100) are located inside containment. To exercise test these valves, entry to the containment is required and temporary connections made to gas supplies. Because of the radiadon exposure and effort required, this test is not conducted during power operation or during cold shutdowns. Exercise testing is performed during refueling shutdowns.
: 24. Normal residual heat removal system reactor coolant isolation check valves (RNS-V015 A/B, V017A/B) are not exercise tested quarterly. During normal power operation these valves isolate the high pressure RCS from the low pressure RNS. Opening during normal operadon would require a pressure greater than the RCS normal pressure, which is not available. It would also subject the RCS connection to undesirable transients. These valves will be exercised during cold shutdowt s.
: 25. This note applies to the main feedwater control valves (SGS-V250A/B), moisture separator reheater steam control valve (MSS-V020), turbine control valves (MTS V002A/B, V004A/B). The valves are not quarterly stroke tested since full stroke testing T Westingh0use m

                                                                                                                                      'N 3, Design cf Structures, Components, Equipment, and Systems would result in a plant transient during power operation. Normal feedwater and turbine control operation provides a partial stroke confirmation of valve operability. De valves will be full stroke tested during cold shutdowns.
: 26. His note applies to containmrnt compartment tirain line check valves (WLS V071 A/B/C, V072A/B/C). Dese check valves are located inside containment and require tem [orary connections for exercise testing. Because of the radiation esposure and effort required, these valves are not dercised d m ,; power operativo or during cold shutdowns. The valves will be exercised during refuelings.
: 27. Containment isolation valves leakage test frequ mcy will be conducte.1 in accordance with the " Primary Containment Leakage Rate Test Program' in accordance with 10 CFR 50 Appendix J. Refer to SSAR subsection 6.2.5.
: 28. His note applies to the chilled water system containment isolation valves (VWS-V058,V062, V082 and V036). Closing any of these valves stops the water flow to the containment fan coolers. His water now may be necessary to maintain the containment air temperature within Technical Specif' canon lim a. As a result, quarterly exercise testing will be deferred when plant operatmg conditions and site climatic conditions would cause the containment air temperature to exceed this limit during testing.
: 29. Ex:rcise testing of the turbine bypass control valses (MSS-V001, V002, V003, V004)) will result in an undesirable temperature transient on the turbine, condenser and other portions of the turbine bypass due to the actuation of bypass now.
Ther: fore, quarterly exercise testing will not be performed. Exercise testing will be performed during cold shutdowns.
: 30. Dese valves are required to operate with low differential pressure, ne Combined License applicant will provide an zvtluation based on test data to venfy that the valves have adequate margin and operability testing is not required. He test dats may include data from type tests. See sutisection 3.0.8.4 for the Combined Licena applicant informatior, item.
31 Dese valves may be subject to operability testing. See subsection 3.9.6.2.2 for the faw: ors to be considered in the evaluation of operability testing and subsection 3.9.8.4 for the Combined License information item. The specified frequency for operability testing is a maximum of once every 10 years. De test ircquency is the longer of ever" 3 refueling cycles or 5 years until sufficient data exists to determine a longer test frequency is appropriate in accordance with Generic Letter 96-05.
Some of the valves will be tested the first time after a shorter peried to provide for trending information.
: 32. Rese valves are subject to operabihty testing. De operability testing will be conducted using nonintrusive techniques to assess valve operability under flow and differential pressure test coriditions. The test frequency is the longer of every 3 refueling cycles or 5 years ANST"C APER             9 y     C li Also AvAu on Aperture Card 1           Revision: 18 raft,1997 l
f                                           l 3.9-172 J                                                      -
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l NRC FSEP Open item y(  Yi FSER Open ! tem 250.30F T6 be consistent with SECY 93-087 intersystem LOCA concerns, Westinghouse should apply the following criteria for identifying AP600 PIVs which should be leak tested and included in technical speci0 cations (TSs): (1) any ponion of the connected low pressure systems outside containment not mee4ing the ISLOCA acceptaace criteria, i.e., a component having the ultimate rupture strength less than the RCS vgrat ng   i pressua, or (2) the connected low pressure system is an engineered safety feature for mitigation of DBAs Westinghouse should list all PlVs meeting the inclusion criteria and requise technical specification (TS) operability conditions.

===Response===
The suggested modification of the criteria to include all valves that isolate the reactor coolant pressure boundary to a low pressure system is too broad and would potentially capture vala: that do not contribute to the risk of an ISLOCA due to other design features and would not otherwie t>e captured by this Techrical Specification. Although it remains the Westinghouse position that the significant impiovements in the design of the AP600 with respect to ISLOCA criteria should allow for the relaxation of Technical Specifications on the Normal Residual Heat Removal System valves that have been historically included under the PlV Leakage Technical Specification, Westinghouse agrees to include these vahes in the Yechnical Specification. Westinghouse will add Table 3.918 to the SSAR to include those valves designa.ed as Pressure Isolation Valves subject to the requirements imposed by Technical Specification 3.4.16. This is done in accordance with the Standard Technical Specifications and is the approach taken by the NRC app oved CESSAR System 80+ Technical Speci0 cations. This '
table will be referenced in the Bact; ground to Technical Specification 3.4.16.
SSAR Revisions:
Revise the fourth paragraph undcr Valve Leakage Inservice Tests in subsection 3.9.6.2.2 as follows:
The AP600 h= nc specified-maximum leakage requirement for pressure isolation valves that provide isolation between high and low pressure systems N niciu'did'ih!tfid sucGeeti66hileysfreis66ti for!Teclinfiafs6esificatiod 3sdC                                 uirn ac !c h ge tema cf hez v !vn Thehessme isolanon vstves tfiat%quirs'                                   '"n'teitiig sre ta6bkl6,Tabh9fl8 T Westinghouse

NRC: 'SER Open item
            -Add Table 3.918 as follows:
Table 3.918 AP600 Pressure Isolation Valves Valve Number               Description
             - PXS V028A                 Accumulator Discharge Check Valves PXS V028B -
PXS V029A-PXS V029B RNS V001 A                 RNS Hot Leg Suction Isolation Valves -
RNS V001B                                                                                           ,
RNS V002A RNS V002B RNS V015A                  RNS Discharge RCS Pressure Boundary RNS-V015B RNS V017A RNS V017B See the response to FSER Open item 250.33F for revisions to Technical Specification 3.4.16.
T 250.30F-2 9

a NRC FSER Open item t=    . .:
::     y I
FSER Open Item 250.31F Westinghouse states in the AP600 TS bases (pg. B 3.4-69) that the normal residual heat removal system (RNS) PIVs should be excluded from TSs because the RNS ultimate rupture strength is designed to be not less than the RCS operating pressure. The NRC staff does not agree that the RNS design fully complies with the SECY 93 087 criteria that low pressure systems interfacing with the RCS have an URS exceeding the RCS operating pressure. Specifically, the RNS pump seal is not designed to meet this URS criterion. Because the RNS pump seal is not designed to the RCS URS, failure of the RNS PIVs could result in the failure of RNS seals, which could result in a LOL.\
outside containment. 'Therefore, the RNS PIVs should be included in the set of PIVs identified in TSs.

===Response===
As discussed in the response to FSER Opren Item 250.30F, the RNS isolation valves are included in the set of PIVs identified in the Technical Specification.
SSAR Revisions: NONE See the response to FSER Open Item 250.30F.
[ W95tlligh00S8

4 NRC FSER Open item
                                                                                                                              ;g eq id FSER Open Iten 250.32F Unlike conventional operating reactor charging systems, the AP600 CVS charging system operates only intermittently and is normally not mnning. The staff notes that there is only one check valve (V064) which is normally closed and separates the reactor coolant pressure boundary from the CVS charging system outside of containment. Although there a e both check valves and discharge isolation valves on the CVS charging line outside of containment, this is not a conventional arrangement for PlVs (since PlVs are normally within the reactor coolant pressure boundary). Westinghouse should consider the need for another check valve within containment on the charging system. The staff believes that Westinghouse will need to designate PlVs for the CVS charging line since the charging pump suction does not meet the ISLOCA criteria of SECY-93-087.

===Response===
The CVS makeup pumps are isolated from the reactor coolant system pressure boundary by multiple sets of valves including the reactor coolant pressure boundary valves and containment isolation valves.
         'These valves are safety related and designed to close against full reactor coolant system pressure, Moreover, the containment isolation valves that isolate the makeup pump suction line must meet the leakage requirements for containment isolation valves. See the response to FSER Open Iteu 230.140 for a related discussion on design changes that have been incorporated to address the AP600 chemical and volume control system.
SSAR Revisions: NONE See the response to FSFR Open item 250.30F.
3 W6Silfigh00S8

c .
NRC FSER Open item FSER Open item 250.33F AP600 TS 3.4.16, "RCS Pressure isolation Valve (PIV) Integrity," appears to be dencient to the staff.
The TS should be improved to andress the following concerns:
(a) Condition A in TS 3.4.16 is defined as one or more RCS PlVs being inoperable. How is the inope. ability of PlV defined here? TS Bases page B3.4.71 states that the purpose of this LCO is to verify the PlVs have not suffered gross failures and that the operability tests specined in the inservice test program (IST) implies that an acceptable method of determining valve integrity is the ability of the PIVs to transition from open to closed. How does this operabiUty condition ensure PIV leak tightness at expected differential pressure across the valves? This appqars to be inconsistent with the leakage LCO of Standard Technical Specifications which specifies a leakage limit at the expected differential pressure across the PIV. SR 3.4.16.1 (note typo in surveillance numbering) requires verification of operability of each PIV in accordance with the IST r.ogram.
How is the PIV operability defined in the IST program? Section 3.9.6 of SSAR indicates that the valve leakage inservice testing is performed only for the containment isolation valves in accordance with Appendix J. How is the PlV leakage tested under the IST program with the RCS pressure?
(b) The LCO 3.4.16 applicability MODES are limited to MODES 1 and 2, and MODES 3 and 4 with pressurizer pressure greater than 1000 psig. Is this limitation of P > 1000 psig based on Westinghouse's conclusion that the accumulator discharge check valves are the only PIVs required to be included in the TS? The applicability MODES should not be limited to Pressurizer P > 100d '
psig. When Required Action A.I is not met, B.2 requires the pressurizer pressure to be reduced to less than 1000 psig within 12 hours. This is not acceptable. B.2 should require the plant to be in MODE 5 within 36 hours.
(c) The staff believes that the AP600 PlV TS should be modeled after the standard TS for PIVs.
However, the staff is willing to forego the need for PIV leak testing within 24 hours of any automatic or manual actu< tion of a PlV. He staff would be satis 6ed if the PlVs are leak tested in accordance with the IST program schedule and prior to entering MODE 2 if the unit has been in MODE 5 for more than 7 days and the PIVs have not been tested in the previous 9 months.
(d) De TS 3.4.16 BAStiS Background section addresses the irlationship between reactor coolant pressure boundary valves (RCPB) and PIVs. The staff dxs not believe that Westinghouse has defined the RCPB consistent with the dennition of 10 CFR 50.2. Westinghouse should revise the Bases appropriately.
l
                                                                                                                -  j 250.33F-1 i W Westinghouss                                                                                           j l
1

       .1 ;
4; ;                             -
g_                                                                     {
1 NRC FSER Open item                                                                                           .
                 ~         '
s Responset -
Westinghouse proposes to rr dify the PlV_ integrity specification to a PIV Leakage specification modeled after the standard Technical Specifications for PlVs. The following changes to the standard Technical Specifications are proposed on the basis that the AP600 design has been upgraded over                  '
current plants with respect to the ISLOCA issue. This is reflected in the AP600 PRA results, which calculates an overall core damage frequency due to ISLOCA as ~5 E-Il per year.
                    -    The testing frequency will be modified to perform leakage testing every refueling outage (similar
'                        to IST testing as referenced in item (c) of this open item). Testing the valves every time the plant        ,
enters cold shutdcan for more than 7 days adds unnecessaiy test activities, which increases the          -1 occupational radiation exposure to plant personnel.                                                        ,
                    -    Action statement A.2 (from standard technical specifications) is incorporated to allow the plant to substitute a second valve as a PlV, provided it can be shown to meet the PIV leakace limits. A modified approach to this second PlV is taken as discussed below.
The basis for this change is discussed below:
The standard technical specifications cllow for the use of a second valve to be substituted for the inoperable PlV provided that the second valve is shown to meet the PIV leakage limits. However, the standard technical specifications requires the valu to be either a check valve, a closed manual valve or a closed remote valve with power removed. For the RNS discharge PlVs, the containment isolation check valve is a suitable substitute. For the RNS suction isolation valves, the remotely-operated containment isolation valve is a suitable ::ubstitute. However, it is not desirable to remove power to this valve, due to its defense-in-depth functions credited in the PRA.
The valve is closed, and is only opened for brief periods of time to allow for flow testing of the RNS pumps prior to refueling.
For the accumulator check valves, the remotely operated isolation valves could be a suitable substitute for a PlV. However, if these valves are closed, the accumulator become inoperable.
Since leakage into the accumulators is continuously monitored, and if necessary, the remotely-operated accumulator isolation valve can be used to termice leakage into the accumulator, it is acceptable to allow this valve to remain open, and close it only if accumulator leakage increases above the allowable limits.                                                                                 ,
                    -    The PlV allowable leakage is increased from 0.5 gpm/ inch valve size (max 5 gpm) up to 10 gpm.
This leak rate is well within the makeup capability of the AP600 chemical and volume control system makeup pumps. Herefore, if such a leak developed, the plant could be shut down in a J controlled manner without the actustion of the passive safety systems. An increase in the i
!~
t 1
250.33F-2 l
L o
  ~
L                                    -      -_          - - _       _     _-         , . - _ _ . . _     ._

                                                                   . - . ._               - . .         _      . . - ~.   ._ _   . _ _ _ _ _      ..
4 4       .,
e                                                                                                                                    ;
NRC FSER Open item .                                                                                                j r
                                                                                                                                                      +
.                                       all'owable leakage limit will result in lower personnel radiation exposure, and does not reduce the-
                                       . safety of the plant or the risk due to an ISLOCA.
                                      . Operating txperience shows that the requirement to restore a leaking PIV to operable status results in plants being placed in a degraded state to repair the valve. Due to the requi ements of this Technical Specification, plants test their PIVs after a shutdown, prior to entering Mode 2. Due to their location in proximity to the RCS, maintenance on PIVs can require the plant to ge to mid-loop conditions (for accumulator valves), or require the use of temporary isolation devices such as freeze plugs (for the RNS valves). Neither of these ett.matives are desirable, or preferable to-              ,
                                                                                                                                                      ~
                                      - relying on the second P!V to maintain the RCS leakage within allowable limits, Higher allowable limits will increase the probability that the plant will not be forced to perform maintenance on              '
PIVs using te'mporary seals such as freeze plugs. Maintenance procedures will dictate that valve leakage that approaches 1 w allowable limits should be tended to as soon as reasonable, which in this case would be at the next planned refueling outage.
Modify the method to extrapolate PIV leakage, from test conditions to RCS pressure based on
                                      - valve characteristics. The cunent Technical Specifications require the plant to extrapolate the results of the_ leakage test from test conditions g to RCS operating pressure conditions if it can be shown that the valve characteristics are such that higher pressure results in lower leakage due to
                                       ' valve design A benefit to plants would be realized if this requirement is relaxed such that the valve leakage is assumed to be the same at RCS operating pressure as at the lower test pressure, if it can be shown that the valve characteristics are such that the valva leakage decreases with
                                      ' increasing pressure. Many PIVs are designed such that leakage decreases with increasing RCS g                                     - pressure, and therefore if such a valve meets the leakage requirement at low pressure, it is expected to' meet the leakage requirement at high pressure. His change allows the testing to be performed at lower RCS pressures during the refueling outage at a time when repair of a leaking vahe is performed without the need for placing the plant in an undesirable condition as discussed
;                                     - earlier.
Dese proposed modifications to the PlV leakage specification are designed to relax the restrictions that this specification has historically placed on plants due to the design differences of the AP600.
systems. In addition to the PIV leakage testing specified in this Technical Specificatiot., the AP600
!                            - l_nservice Testing Program includes testing of the PlVs. The IST plan includes static testing and l                              . dynamic testing of PIVs in accordance with ASME Section XI as shown in Table 3.916. Based on present plant testing as the result of GL 8910, static testing has been shown to_ verify that a valve will function while providing information of degradation of the operator (bearings, gears, motor etc.).
L                                Static testing can also assess valve degradation (packing loaci changes, structural problems as bent l                                stem, loose bolting, valve control switches are functioning correctly and at the correct time / location.
In addition, dynamic testing is'used to evaluate degradation of valve seats and guides over the life of the plant.
250.33F-3
     -,,,           .m v            g          y   ,wn.   ,,w,-  g          .-evm,--,,-w-       , -.n_,   -~

NRC FSER Open item De COL applicant is responsible for the detailed Inservice Testing Plan. Based on current plant testing, static test programs, as the result of GL 8910, verify the valve / operator combination will open and close as required. Rese test programs are performed at a time interval based on the valve's risk importance and margin.
Following are some of the parameters these test programs check to verify the operator is functiy.mg correctly, Verify control switches are set correctly, the operating loads are within the accepte: ce criteria, assess degradation of the gearing and bearings, the operator to stem interface functions as required, assess degradation in the valve components, the valve travel / operating time is acceptable and the valve fully opens and closes. His test program verifies the valves functionality and minimizes the probability of an unexpected gross failure of a valve.
For swing check valves the functional testing of the valves with instrumentation verifies the valves open and reclose. As for the motor. operated valves, the verification that the valve is functional and that the valve has reclosed would also minimizes the potential for gross leakage acro.s the valve since the valve is closed.
Herefore, the inservice testing of the PIVs outlined in this discussion, as well as the additional design features of the AP600 provide justification for the modification of the standard PIV Technical Specification for the AP600.
The following addresses the items delineated in the FSER Open Item:
(a) Comment has been addressed in discussion above.
(b) Agree. His item has been incorporated in the proposed revision.
(c) Comment has been addressed in discussion above.
(d) Comment he.s been addressed in the Response to FSER Open Item 230.140.
SSAR Revisions: NONE See the response to FSER Open item 250.30F.
Technical Specification Revision:
See attached draft of Technical Specification 3.4.16 and associated bases 2so.33 s W wesuous.

   '.                                                                                          PIV Integrity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) w 3.4.16 RCS Pressure Isolation Valve (PIV) Integrity LFAnA6C                                           vseru.a J e mr LCO 3.4.16 ht:;rity of each RCS PIV shall be ,eir,teir,W.
A APPLICABILITY:                      an         3 H0 H0DEDES
                                      -3      1'en+d 4           2)w4th pr::surizei vic53nree 1000 p;it. R es nor
                                           % nr. cc.eLG% % y 'T"M g 'R N.$
ACTIONS                                                                         .
       ..................................... NOTES.                                                    .....
: 1. Separate Condition entry is allowed for each flow path.
: 2. Enter applicable Conditions and Required Actions for systems made inoperable by an inoperable PIV.
CONDITION                               REQUIRED ACTION               COMPLETION TIE
[ g Ag 44 5 F Am u A. # One or more RCS PIVs NOTE .             -
inopereble.~                      Each valve used to s                    -**"""'#"A is vo r weroa pairs              Required Action A.1, %mustAhave              '-            -
been verified to meet SR3.4.1%flandbeinthe nactor coolant pressure boundary or the high pressure portion of the system.
A.1          Isolate the high            8 hours pressure portion of the affected system from the low pressure portion by use of one closed manual, deactivated automatic, or check valve.
(continued) b m AP600   sma .i. ,e.im 3.4 30                        08/97 Amendnent 0

P!V Integrity ossgA T k ACTIONS     (continued)
CONDITION                           REQUIRED' ACTION                                               COMPLETION TIME
                                                     )                                                                           72. H~AS B. Required Action and              B.1       Be in H0DE 3.                                               6 hours associated Completion Time for Condition A             AND not met.                                    3g its Ma n 5' B.2       Reduce-pressurteer                                            12 hours pretter: ; 1000 peig.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                                                               FREQUENCY
                           &                   LG A h t4C                                                                               TVEfY R S fv61 INS SR 3.4.1/.1             Verify OPERABit4TV-ef each RCS PIV &                                                           4a accorderce .our u g eccordeace with tk- Ir. service Testing-                                                       with-the Erosr6E. 15 6 G u a y A L F N'7" *T'o (                                                        I466PVice (0 e}. Y M kr A H %$ .1hy. PA SS$ ve l                                                                                     gg
                                      ).[.,22es")7$s& A n v f. [t t.si) Psit                                                             24 w thi AW or ier --te enter.in9-HOBE- 2 e Ma^ver the uait het been h "00C 0 for 7 d:yc or acre, if tasting-has not-kcre p^rferra.d in the previous 12 mont w-
              -S'1  3. t .1L7 Verifv affected RCS PIV in closed
                                            ~
Within 24 Nurs feMewir4 valve g ... w .        x ..
te eutesetic ^#
eersel a uion or flow th@
t M velve -
              @    AP600                                         3.4 31                                                                                  08/97 Amendment 0       4 m is. ~ a u i. , n o                                                                                                                                               1

Insert A A.2    Verify a second operable PIV can meet the leakage limits. This valve is required to be a check valve, or a closed valve, if it isolates a line that penetrates containment e
h

   *,                                                                                                          PIV Integrity B 3.4.16 B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.16 RCS Pressure Isolation Valves (PIV) Integrity BASES         :
BACKGROUND          10 CFR 50.2, 10 CFR 50.55a(c), and GDC 55 of 10 CFR 50.
Appendix A (Refs. 1, 2, and 3), define the RCS pressure boundary as all those pressure containing components such as pressure vessels, piping, pumps, and valves which are connected to the reactor coolant system, up to and including the outermost containn.ent isolation valve in system piping which penetrates primary reactor containment, the second of two valves normally closed during normal reactor operation in system piping which does not penetrate primary reactor containment, and the reactor coolant system safety and relief valves. This includes any two normally closed valves in series within the reactor coolant pressure boundary (RCPB), which separate the high pressure RCS from an attached low pressure system. During their lives, these valves can experience varying amounts of reactor coolant leakage through either normal operatig,nflwear or mechanical deterioratio% The AP600= velv;; ar4 listed in SSAR Table Prpa         3.9 f;P v@f:.             Tht:3 %epecificetien iv;r,in            Table 3.^ 15. eddr,ese     TM selves- . =         subs t. v Mert:d        by thi: specificetier. Li.g                               .fie for P!Y:.
es & fird b:lsw. The RCS PIV Inte ..,                                 "A11,0ws RCS high pressure cperation when PIV OPEA EftifYA                               6W!      eri fied,W 20:erder,ce with th: Ir.::rvice Test De^a*=                           (IST)               ^
The purpose of this specification is to prevent overpressure failure or degradation of low pressure portions of connecting systems. The following criteria was used in identifying PIVs for inclusion in the specification. A v'lve a    was included in this specification if it's failure may
:                                    result in:
i                                    1. Failure of low pressure portions of connected systems, such as a loss of Coolant Accident (LOCA) outside of containment, which could place the plant in an unanalyzed condition.
l l
(continued)
!               b e.AP600.o   - e,o,e.m ,                     B 3.4 67                                     08/97 Amendment 0
                .       o

                  ,                                                                                                                               PIV Integrity B 3.4.16 l
BASES BACKGROUND                                       2.        Degradation of low pressure portions of connected (continued)                                             systems. such as damage to a core cooling system. which could degrade a safety related function that mitigates a
:                            DBA.
Valves considered for inclusion in this specification are used to isolate the RCS from the following connected systems:
: e.       Passive Core Cooling System (PXS) Accumulators;
: b. Normal Residual Heat Removal System'(RNS): and                                           , , , 4 ,,
                                                                                                                                                             -r.
: c.        Chemical and Voltme Control System (CVS).
ggs 7Ap.ssu4g g..an4Ay iSonw u Awr_s
                                       ,,,,,,,W 1he3 valves idenMHed IINE the first Meriterised FaA ThePXSaccumulatorcheckva10esweredeterminedtomeetthe j u n u si. ~ su r a,y                          3 second PIV criteria for inclusion in this specification.                                It is determined that the RNS-end CVS PIVs do not meet either                            ~
criteria for inclusion in this specification.
The s cier leter PIVs that are addressed by this specification ' :11 M f6L ;ng: A4E A.is r s b / N 5'54
,                                                                       ~Tk32. E. 3.1- I e .
                                                                                -PXS VG^^e                      PXS  ^,cc -'letor Ditc hrg" CP M Y!!""
fX5 V525A                      FX5 A      i.i.e- Diecter;; Cbd Velve _..
pre uman                    ove --.- i "-- 01 sch3 n. ch.ek valv.
PXS V0.~.                   PXS .'ec; .10ter Di=Mrge Ct.Gk Velv: -
'l ite FX3 occu ulai.ur Jwd velvee ere located ^^ tM
:= -later discterge lira; tht interfec= with tM DCS E=P. ere'_ 21 ster discheraa lh weias t= ch*ck valves                                         _
mrt vn7AA 1 R and DYR unggA 3 n) j. ;eiiva lheT. 1solaf.e U1e accum444ce: fra tt.e RCS dorir,g i. err.el pier.t Operatier..
m re-1ta4_wedasw .d to acceot some inleakaoe from J
(continued)                  ,
1 1
M   AP600w..,,                           n.,
8 3.4 68                     08/97 Amendnent 0
                                                                                                                            -.                . _       .- -                  O

      ".                                                                                                                                                                                                                                                          PIV Integrity B 3.4.16 BASES BACKGROUND                    _tha are ettM;;t :ff--ti ; ;;;ilot,ility.                                                                                                                              nowWy,I, 'eile:                                               .
(continued)                 .cf tt ;;;ir letyr vi= d valves coula re3uli. 171-
_e . - -                               ___._ a.. .,
_.... ..m,,n
                                                                 ..                                 4. .. ..a.v_,.vi                                       bus www . . . .. ....,oa                                                   . __ a_._n,,a     - _ _ _ _ t_4nn                       nf ,
7,.___
i                                                          .k u..w awiuby IWI5LWQ TunbblDH Ui VIvvlulliy IVW yi s . ,w.                                                                                                                                                          . -
                                                            %4destivu s"Ur mitigating DBAs. -
The CVS and-ANS pressure isolation valves were not included in this specification based on the defined criteria. The justification for excluding the CVS r.d ^# PIVs is discussed in the following paragraphs.                                                                                                                                                             ,
i
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lj nse "'i:Pi cvui = b 6 i.o Ine e alrect vestwi injectic.-0"I)
                                                          .l.im-u ___.                      ___              , u Due                                                 u..___                                        *u are na th._ oue                                                 -
_r.. 7...                        . ..                . . .                           . . - - . - . . . ..._ . _ _ _ - . - -                                                                               - _ _
                                                         -caatminnent isolation valva < ara da*4;--d to th= naaentina mre<<ura af tha a==-+ = ^caa1==+                                                                                                                          =ve+==                   The r- -4r.dr ;f                                              _
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tww.wbiuri V51VW.                                                          -
l (continued)                    L h   AP600.ow.c a m,                                                                                   B 3.4 69                                                                                                             08/97 Amendnent 0 ei.

            ,                                                                                                                                                                                                                                                          P!V Integrity                                    .
B 3.4.16                     ;
BASES w i
                                                                                         ^        ""! relief velvw is incatea insivw cer,t:f - nt and is BACrGROUND                                                                     .
                                                                                         =aa-- t -d t: t'; 30 ps;;;p sectiv6 iinc. Thi. sel= 4e (continued)                                                                                                                                                                                                                                                              _
d="a ; =" ta p vid; le .iwiipwrature ovvi vi eseure pr;tect'0: ,,
61 the DM                                ft i                        ;;aa ,,( ,f i,y yi, h                                              j yt,        37;; g--                          an, tQ tha N -a !"cti^= 'i- Or.d rudvww. ii                                                                                                         ri:         of                         _
0=rp ;;surizinii tt,. ivw pressure portions of de syster.                                                                                                                                                            ,
W             ","O diashar vw lines nave tour normally Ciomi i;;1: tie-yal n iri ew, ivi, ali sne orancn iines snai, interface wiin                                                                                                                                                            -
1
                                                                                       -tie dir;;t V;^ eel $6jusi,ivu ii6 s ^;d "^atMn tm normally _
cln==d > bd voivus Inat are RC5 pressure Dounvoiy leeleti0r
                                                                                        . Val"^f.                 II; in ends l inwa.sv,nuwu6   >                        .                      L Io is ut L__     > _ _
_n imadwi iha6    . .
nana,r=,;,
wn,u n - i6. _ inia u_
                                                                                                              .                                                                                                        - - _ - _-i .     .wwi          svusalns two                                                     t CC"t".ii .i6 i5olat1On Valves, a CneCK Valve Inside
                                                                                                                                                                                                                                                                                                          ~
CentHitir, .;nt and                                  a mui.ur v. pus sivu gate                                                             Valve         ouT,51ou4.,3 Con.b.. a. --o..
su
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                                                                                       -for edvancea 11gnt water reactors, the NRC has issueo oesign
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The CVS contains four high pressure / low pressure connections with the RCS. Since the portion of the CVS which is located inside reactor containment is designed to full RCS pressure, the high pressure / low pressure interfaces with the RCS are the lines that penetrate the reactor containment. The CVS lines that penetrate l                                                                                        containment include the makeup line, the letdown line to the (continued) h     AP600 m m me,o,ewn 8 3.4 70                                                                                        08/97 Amendment 0 l
l
        .~    ., ~       . . . . - . _ _ , _ . . . _ . - . . _ _ _ . - _ _ . _ - _ .

PIV Integrity s                                                                                                          B 3.4.16
  ..                                                                                                                      1 BASES BACKGROUND                             Liquid Radwaste System, the hydrogen supply line, and the (continued)                       demineralizer resin sluice line used to transfer spent resins from the demineralizers to the Solid Radwaste System.
These lines each contain two safety related containment isolation valves which are addressed by the Containment Isolation Specification (LCO 3.6.3). In addition to the containment isolation valves in each of the CVS lines that interface with the RCS. there are additional valves in each line that provide diverse isolation capability. Since more restrictive requirements are imposed by LCO 3.6.3, the CVS isolation valves ar6 not included in this LC0c Since the purpose of this LCO is to verify that the PIVs ub      b1ve            # Nt             e i b TSY Z      N.
provide an acceptable method of determining valve integrity.
The ability of the valves to transition from open to closed provides assurance that the valve can perform its' >ressure isolation function as required. A small amount leatage .
through these valves is allowed, provided that the integrity of the valve was demonstrated.
Violation of this LCO could result in continued degradation of a PIV, which could lead to overpressurization of a low pressure system or the failure of a safety related function to mitigate a DBA.
APPLICABLE                             Pressure isolation valve integrity is not considered in any SAFETY ANALYSES                        design basis accident analyt.as. This specification provides for monitoring the condition of the reactor coolant pressure boundary to detect oegradation which could lead to accidents or which could impair a connected system's ability to mitigate DBAs.
RCS PIV integrity satisfies, Criter ton 2 of the NRC Policy Statement.
l l
l (continued)
             . ,, _ AP60
                    . _ ,0. _ . 4 ,         ..,
B 3.4 71                  08/97 Amendment 0

   * ..                                                                                                                                           PIV Integrity i                                                                                                                                                   B 3.4.16   ;
e         .
O BASES (continued)                                                                                                       l LCO                     200 ?!" in6-viity of Ine rour acc m i ivr si,wd, vaivv. i. ~
w  uirea to protect tne i w., pre;esce perti;a; ef tra TX5 ,                                      :
gA   f              -"ht;r; free ;vergin=r: sp;;;r; tht ca"1d
                                                            ,      :ct;ati.ily rw=uit in a ioss of a ..f;ty related function.
E           h;r;Je;1vn vi Use accumuistors could resuit mtre = Re-                                         i of ;;cu wiator injection for mitigation or utms. Inw valie                                    , i L*ET"ILITV i.e ia on.iraiv me ini-viitj ;f t h 8 5 DTVJ                                         i to-par::t ; dei, red.i.ive vi us. FK5 .swumui.iers.
i W DF- acs v.T Bseus u p 37 APPLICABILITY            In MODES 1-and 2. and jn 3 and 4.. witherrr-i:r pr;;;ere- rus A.
                                                                  ;Mte;-ny r t:r ttd.a a' leee t':n paiy;,=this
                                                                                          ;;.         U r:;LOD    ir:d when   applies      the because-6he RCS is pressurized. 'i Z II; yisiivilisi piviivie U 1^^^ pii; ^ t MIT. tI6 .wsumuistor saiuty 76 stien i; 6vi u..w d.                                       --
Additivnally, Ine ioss or one ra5 assumuia6vr as a i..uit, of tM 'eihre vi sne rivs is ==. >v.u oy me analysis for a uvt
.                                                                 g
                                                                     . pg g w ird R us f u .7mn.a Add In MO                                                             .       "--d inrr the        .
'                                                             Re.s 1d DES  reertar5 caahrt and 6,pressure
                                                                                               ?!" int;eri;Y' NIuEdnt to                                          I overpressurize the PE-eeetadeters. ***8
* t 8
* J
* w P8 8'n ve s
.                                                                  - 5 y 57FA.s ACTIONS                 The Actions are modified by two Notes.                                Note 1 provides clarification that each flow path allows separate entry into a Condition. This is allowed based upon the functional ...
independence of the flow path.                   Note 2 requires an                            -
evaluation of affected systems if a PIV is inoperable. The pressurization may have affected system operability, or isolation of an affected flow path with an alternate valve may have degraded the ability of the interconnected system to perform its safety function.
A._d.
With one or more PIVs inoperable, the affected flow path (s) must be isolated. Required Action A.1 is modified by a Note that the valves used for isolation must meet the same integrity requirements as the P!Vs and must be within the RCP8 or the high pressure portion of the system.
(continued) h       AP600.o  m.o, o.m. .                  B 3.4 72                                             08/97 Amendment 0 oon.      -
  - . . . , - - . . , . . - - - . ~ . , - - . , .-                 .
* e                                                                                                                  f s                                                                                                                        f
             *t                                                                                                                 ;
               #                                                                                                               1 Insert a RCs PIV Leakage is identified m                 E into closed systems connected
                                        -to the RCS.           Isolation valve leakage is usually small.- Leakage that          ;
increases significantly suggests that something is operationally                    i' wrong and corrective action must be taken.
The LCO PIV leakage limit is 10 rpm per valve.              This limit is well within the makeup capability of the CVS makeup pumps. This leak                       .
rate will not result in the overpressure of a connected low pressure                  !
system.         Reference 7 permits leakage testing at a lower pressure             ;
4 dif ferential than betwe sa the specified maximum RCS pressure and the               l normal pressure of the connected system during RCS operation (the                     f maximum pressure differential) in those types of valves in which the higher service pressure will tend-to diminish the overall leakage of the valve.          In such cases, the observed leakage rate at lower                 ;
differential pressures can be assumed to be the leakage at the maximum pressure differential. Verification that the valve leakage diminishes with increasing pressure differential is sufficient to verify that the valve characteristics are such that higher service pressure results in a decrease in overall leakage.
i Insert C hA2                                                                                   ;
Required Action A.2 specifies that a second operable PIV can be                       l shown to meet the leakage limits within 8 hours. This valve is                        t required to be a check valve, or a closed val'.e, if it isolates a line that penetrates containment. For the accumulator valves, the normally open accumulator isolation valve is a suitable replacement FIV, but can remain open because leakage into the accumulator is                      '
continuously monitored.              If leakage into the accumulators increased to the allowable operational leakage limit, then the valve could be''
used to isolate the accumulators from the RCS.
The 72 hour Completion Time allows the actions and restricts the operation with inoperable isolation valves.
Insert D
                                           . ' . . leakage and reduces the potential for a LOCA outside containment.                                                                          ;
Insert E l                                          ...        that leakage is below the specified limit and to identify each l                                         1eaking valve. -The leakage limit of 10 rpm applies to each valve.
Leakage testing requires a stable pressure condition.
4

i
    *8                                                                                                                 PIV Integrity
    ' ;,                                                                                                                      8 3.4.16 J
BASES ACTIONS                  J (continued)
A Required Action A.1 requires that the isolation with one a      valve must be performec withia 8 hours. Eight hours provides time to verify IST compliance for the alternate
  !                                           isolation valve and isolate the flow path. The 8 hour                                                    '
Cogletion Time allows the actions and restricts the operation with inoperable isolation valves.
INSUf h & B.1 and B.2 9
If PIV integrity cannot be restored, the system isolated, or the other Required Actions accomplished, the plant must be brought to a MODE in which the requirement does not a aly.
To achieve this status, the plant must be brought to MODE 3                                               '
within 6 hours nd prr:rirr - et "-e r+::; t: : 1000 Matt 5
                                            .ps49.within           Burs.
d;r:det.ivn ef tt.e      "O This eccsActio lete(rfiducef              the i.i end yi.ce. gr.nu; e, plan 6 in               .
: naditi r ia sich tM Mc'-"!:t:r sefety fenctier, is not r;;ir;d. Th ;11:r:d Ca-al:ti:- Tir e e,e                                .evn. Liv L..ed E ?i.i. ?. .. N,,v'. W...i.^,5
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                                                                                                                                              /AsrArg 6
i SURVEILLANCE              SR 3.4.lf.1                                                                                   .
13FAkM f-
                                                          ~
i                 REQUIREME or, j                 )#Iggr" If                 Performance isolation valve used  of IST to satisfy g
                                                                                  ~;-s414ty Required         testing Actionon  each RCS P)T(
A.1  '
;                                            reauired to verifve:l'/ dattrity.
l                                                                                        L e os g M L RE% AVMGNY I                                            For the two PIVs in series, the eclx 4-te;rity applies to i                A "b ** f m 7d lach valve inoiviouallyl If the PIVs are not individually AFAu4s c.ouwuffo WAdct ested, one valve may have failed completely and not be AcAoss W vouG5                  tected!' In this situation, the protection provided by redundant valves would be lost.
j p rg crrMA v ALut-l     Ig $ sors McE% TM Testing shall be performed                                  every 24 months, a typical J t.t yl. ;. ds ; aut ge inte J 5 Tui ai-ref j.64K AGE ggtamitywn') p.ueling              .
                                                        , 4"cycle, The' 24 month Frequency is consistent with 10 CFR 50.55a(g) (Ref. 6) as contained in the Inservice Testing Program and is within frequency allowed by the American Society of Mechanical Engineers (ASE) Code, Section XI (Ref. 7).         The F e ncy is also be n d ^^ *
(continued) i b  AP600. _ . ,_ ,,,
                   .,_e B 3.4 73                                     08/97 Amendment 0
.f                                  _     _

8 o*                                                                                              P!V Integrity
       'l                                                                                                    B 3.4.16 o .
o BASES SUkVt. _l L_ LN_.R_t
: m.     ..
5R J.4.11.1     (Continueu)            --
nLyV 4 KLl'ILM I J ed to narfe"- :=h surveiller:: u* tM r^nditdem that                                         -.
app 17during en vuiage ano the potential ror an unpionnea                                -
transiert if the rv;ill:::: etre pefermed with the                                _
reector :t W r. A Tuii sirvke exercise ivai. Of the acri 21:ter di3cheryw check rai,e415 r:girM by tM IST.                          -
ire 5L uke trai.ing vi um Mdition;11y. tM IST aeri-21:ter ditcher        r:;t v:1vea p ive i.o unii j int p ch::
W     A.- 'h ners. Um unii. ITa5 bwen lii "005 5 #"r 7 d ys Oi                      ~
Mee, i? testing her et t=n ~2-fer=1 in tM previces 12 m,nths. l'ert ; tid :=rcise te5Liuv i= avuwpi.able ivr th= celd shuth test. if
* full streh: te.i. is not                            -
pract1PAhls 4
5R 3.4.11.2 -
                                     - This SR r:wir:: veriff e:ti:n th.i. woun RC5 FIV is c105.d.                          -
5fter th: valve he= L... vpenea by automatic or manuai
_ Action.nr hy finw. This ye=4'4;;tiG6 en=ures t'at              n iwyuisud              -
                                     , PTV ite':tica is i e w=i.ablisiiru, prwiudiis degredei.ica of the ennnactM Oy:te;;;. Clesnie . iiicai. ion must ou                              ~
p;rfe. -u wu.nin a nours arter tne ru nas oeen openea. ,
;              REFERENCES               1. 10 CFR 50.2.                                                          -
: 2. 10 CFR 50.55a(c).
: 3. 10 CFR 50, Appendix A. Section V. GDC 55.
i                                       4. SECY 90 016 " Evolutionary light Water Reactor (LWR)
Certification Issues and their Relationship to Current Regulatory Requirements," January 12, 1900.
: 5. WCAP 14425, " Evaluation of the AP600 Conformance to Inter System Loss of Coolant Accident Acceptance Criteria."
: 6. 10 CFR 50.55a(g).
: 7. ASME, Boiler and Pressure Vessel Code, Section XI.
S   AP600 Probabilistic Risk Assessment, b   AP600.cus,m m ,                           8 3.4 74                      08/97 Amendment 0
               . mi ...w i
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