ML19344D264
| ML19344D264 | |
| Person / Time | |
|---|---|
| Site: | 05000531, 05000550 |
| Issue date: | 03/03/1980 |
| From: | Sherwood G GENERAL ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| MFN-052-80, MFN-52-80, NUDOCS 8003110611 | |
| Download: ML19344D264 (12) | |
Text
l wuctsaa powna GENERAL h ELECTRIC SYSTsMS DIVISION GENERAL ELECTRIC COMPANY.175 CURTNER AVE., SAN JOSE CALIFORNIA 95125 j March 3,1980 MFN-052-80 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: H. R. Denton, Director Gentlemen:
SUBJECT:
IN THE MATTER OF EXTENSION OF PRELIMINARY DESIGN APPROVALS FOR THE 251/238 NUCLEAR STEAM SUPPLY SYSTEM, GENERAL ELECTRIC STANDARD SAFETY ANALYSIS REPORTS (GESSAR/, DOCKET NOS. STN 50-531 AND STN 50-550
Reference:
- 1) Letter, udson G. Case from Glenn G. Sherwood, March 20, 1978, " Application for Extension of Preliminary Design Approvals"
- 2) Letter, Glenn G. Sherwood from Roger S. Boyd, October 13, 1978, " Extension Review Matters for Preliminary Design Approvals"
- 3) Letter, H. R. Denton from Glenn G. Sherwood, November 30, 1978, "PDA Extension Matters for the Nuclear Island GESSAR" This letter transmits additional information to enable the NRC staff to complete their review of G.E. responses to PDA extension review items. The background for this is as follows.
In G.E.'s letter of March 20,1978 (Reference 1), General Electric requested an extension of the Preliminary Design Approvals (PDAs) for each of the GESSAR dockets.
On October 13, 1978, the NRC staff issued a letter (Reference 2) stating that each application for a PDA extension will be subject to an assessment of the design with respect to regulatory guidance issued since the regulatory requirements cutoff date for the PDA 4y $
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GENERAL @ ELECTRIC Nuclear Regulatory Comission Page 2 March 3, 1980 On November 30,1978 (. Reference 3) and December 21, 1978, G.E. filed Amendments No. 46 and 47 to the Nuclear Island GESSAR application, Docket STN 50-447. These amendments provided G.E. assessments of the "
Nuclear Island design for the PDA extension matters identified in Category I, II, III and IV issued since March 1,1974 through and in-ciuding October 13, 1978. In Attachment 1 to Reference 3. G.E. identi-fied all assessments which applied to the NSSS scope. In this manner, Amendments No. 46 and 47 of the Nuclear Island GESSAR application pro-vide the basis for PDA extensions of the 251 and 238 NSSS GESSAR appli-cations.
Accordingly, this letter transmits additional information which supple-ments that provided in Amendments 46 and 47 of the Nuclear Island GESSAR pertaining to the NSSS, and addresses NRC regulatory guidance issued since October 13, 1978 through and including March 3, 1980. These additional items are listed herein as Attachment 1. Assessments of the 251 and 238 NSSS GESSAR designs relative to these requirements are provided in Attachment 2.
The infomation provided in Attachment 2 coupled with reference to the NSSS infomation cont 0ined in Amendments 46 and 47 of the Nuclear Island GESSAR application provide sufficient information as required to enable the staff to sue PDA extensions t7 the 251 and 238 NSSS CESSARs.
& &aal Glenn G. Sherwood, Manager Safety and Licensing Operation
/ph cc: D. F. Ross (NRC)
W. F. Kane (NRC)
C. 0.; Thomas (NRC)
J. F. Quirk C. A. Cameron L. S. Gifford (Bethesda)
Attachments
ATTACitMENT 1 REGULATORY GUIDANCE APPROVED BY RRRC SINCE OCTOBER 13, 1978 EFFECTIVE. DOCUMENT-DATE NO. REVISION TITLE CATEGORY I 10/19/78 SRP 13.1 1 S'*9agement and Technical Support av snization 10/19/78 SRP 13.4 1 Operational Review Jan. 1970 R.G. 1.144 (Draft) Auditing of Quality Assurance Programs 10/19/78 SRP 11.5 (Appendix 11.5-A) 0 Design Guidance for Radiological Effluent Monitoring Instrumentation March 1979 R.G. 1.132 1 Site Investigations for Foundations of '
Nuclear Power Plants
' March 1979 R.G. 1.134 1 Medical Evaluation of Personnel Requiring Operator Licenses CATEGORY III Anticipated Transients Without Scram 1/02/79 NUREG-0460 Volume 3 ,
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ATTACHMENT 2 REGULATORY GUIDANCE ASSESSMENTS
4 GESSAR REGULATORY GUIDANCE ASSESSMENT SRP SECTION 13.1 REVISION: 1 DATED: October 1978
, TITLE: Management and Technical Support Organization BRIEF DESCRIPTION OF SRP 13.1:
This SRP defines the informtion required by the NRC staff related to the organizational structure of the applicant.
EVALUATION OF GESSAR (BWR-6) WITH RESPECT TO STANDARD REVIEW PLAN 13.1 Section 13.1 of the SAR is primarily the responsibility of the appli-cant and, as such, is not included in GESSAR. Areas to be addressed by the applicant include definition of: management and technical support organization, operating organization and qualifications of nuclear plant personnel. The applicant is requested to include information about its major contractors to allow the NRC staff to assess the technical capability of the NSSS vendor, facility design, etc. Pertinent information related to this point is found in GESSAR Section 1.4.
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GESSAR REGULATORY GUIDANCE ASSESSMENT SECTION 13.4 REVISION: 1 Dated: October 1978 TITLE: Operational Review BRIEF DESCRIPTION OF SRP 13.4:
This SRP states the NRC staff's position related to the applicant's plan for conducting required reviews of operating phase activities that are important to safety, e.g., proposed changes, tests and experiments, as well as after-the-fact evaluation of unplanned events.
EVALUATION OF GESSAR (BWR-6) WITH RESPECT TO STANDARD REVIEW PLAN 13.4 Since this SRP addresses the applicant's procedures during the plant operating phase, it is not addressed in the GESSAR text.
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j GESSAR REGULATORY GUIDANCE ASSESSMENT l
REVISION: 0 (DRAFT) DATED: January 1979 l REGULATORY GUIDE: 1.144
- TITLE: Auditing of Quality Assurance Programs for Nuclear Power Plants :
REGULATORY GUIDE:
This guide describes the method acceptable to the NRC staff for complying with the Commission's regulations with regard to auditing of quality assurance programs for nuclear power plants.
EVALUATION OF GESSAR (BWR-6) WITH RESPECT TO THE REGULATORY GUIDE The General Electric Quality Assurance au'diting program is in compliance with ANSI N45.2.12-1977, which is the basis for Regulatory Guide 1.144. This compliance is reflected in GE document NED011209-04A, Rev.1, "NEBG Boiling Water Reactor Quality Assurance Program Description." However, the following exceptions have been taken to the draft Regulatory Guide 1.144:
- 1. The last sentence of the last paragraph under Section B.
Discussion should be included under Section C. Regulatory Position as a Section C5 which should read as follows:
"5. Where more than one purchaser buys from a single supplier, and it is deemed advantageous to the purchasers and suppliers to perform a single audit of the supplier on behalf of the purchasers, such an audit is acceptable to the NRC staff in meeting the requirements of this Regulatory Guide provided all other requirements of the Regulatory Guide are met."
- 2. The overriding of the exclusion statement regarding applica-bility of ASME/ ANSI N45.2.12 to ASME Code Section III, Divisions 1 & 2, and Section XI, as presented in Section C2, may cause purchaser confusion and nonconformance with respect to activities involving ASME Code products or services. It takes detailed study and analysis to recognize that the Regulatory Guide requires that the purchaser must conduct audits of suppliers of ASME Code products and services in the same manner as is required for any safety-related product or service since the ASME audit requirements do not cover all subjects required by 10CFR50, Appendix B, and they are not required to be conducted in accordance with the requirements of ASME/ ANSI N45.2.12. The NRC is, in effect, not accepting the ASME audit program of their authorized code stamp holders and thus will increase the audits of such suppliers. Based on the history of ASME control of authorized stamp holders, and the quality of products produced by them, we consider this to be an unnecessary escalation of the audit process.
REGULATORY GUIDE: 1.144 (continued)
- 3. The second paragraph of Section C3b(2)(b) has been misinterpreted by some persons as being applicable to Sections C3b(1) and C3b(2)(a).
It is requested that it be made clear that the annual evaluation is necessary only when triennial audits are conducted of suppliers.
- 4. We agree with and recommend incorporation of the comments to the subject Reg. Guide provided by AIF.
- 5. It is not clear how a purchaser will have other purchaser audits or 75ME audits available to him to use in the annual evaluation of a supplier. (He might obtain NRC audits from the public document room if they had been performed.) It is therefore recommended that item (4) in the last paragraph of Section C3b(2)(b) be revised to read: (4) results of audits from other sources, if available.
- 6. Since Section 4a converts the "should" of ASME/ ANSI N45.2.12 para-graph 3.5.3 to "shall," it has in effect made it mandatory to conduct audits "when necessary to verify implementation of required corrective action." It is therefore unnecessary to convert the "should" of paragraph 4.3.2.7 of ASME/ ANSI N45.12 to "shall" as done by Section 4b. It is recommended that Section 4b be deleted,'
thus accepting the recomendation as presented by paragraph 4.3.2.7 of ASME/ ANSI N45.2.12.
e GEfeaR REGULAiORY GUIDANCE ASSESSMENT SRP SECTION 11.5 (APPE RIX 11.5-A) REVISION: 0 DATED: October 1978 TITLE: Design Guidance for Radiolocical Effluent Monitoring Instrumentation
~ BRIEF DESCRIPTION OF SRP 11.5 (APrENDIX 11.5-A):
This appendix to the SRP states that radiological effluent monitors providing signals for the actuation of non-ESF systems should be designed and qualified to the design and quality assurance criteria applicable to the actuated system. Criteria for ESF-related monitors are still found in the appropriate Standard Review Plans for Section 7.
EVALUATION OF GESSAR (BWR-6/MK III) WITH RESPECT TO SRP APPENDIX 11.5-A The Process Radiation Monitoring (PRM) system design is in conformance with this appendix. Monitors which provide actuation signals to non-ESF systems include the radwaste effluent and offgas post-treatment monitors. These monitors meet the design and quality assurance criteria of the Radwaste and Offgas systems. The PRM system monitors are discussed in greater detail in Section 7.6.
GESSAR REGULATORY GUIDANCE ASSESSMENT REGULATORY GUIDE: 1.132 REVISION: 1 DATED: March 1979
, TITLE: Site Investigations for Foundations of Nuclear Power Plants REGULATORY GUIDE:
This guide describes programs of site investigations that would
, normally meet the needs for evaluating the safety of the site from the standpoint of the performance of foundations and earthworks under most anticipated loading conditions, including earthquakes.
EVALUATION OF GESSAR (BWR-6/ Mark III) WITH RESPECT TO REGULATORY GUIDE Investigation of site geologic characteristics will be the responsibility of the applicant and therefore excluded from the GESSAR text. .
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a-GESSAR REGULATORY GUIDANCE ASSESSMENT REGULATORY GUIDE:-1.134 REVISION: 1 DATED: March 1979 TITLE: Medical Certification and Monitoring of Personnel Requiring Operator Licenses REGULATORY GUIDE:
' This guide describes a method for complying with the Commission's regulations for evaluation of the medical qualifications of appli-cants for initial or renuewal operator or senior operator licenses.
EVALUATION OF GESSAR (BWR-6/ Mark III) WITH RESPECT TO TiiE REGULATORY GUIDE The medical qualification of operators will be the responsibility of the Applicant and therefore is not mentioned in the GESSAR text.
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GESSAR REGULATORY GUIDANCE ASSESSMENT NUREG -0460. Volume 3 DATED: January 1979
_ TITLE: Anticipated Transients Without Scram (ATWS)
BRIEF
SUMMARY
OF NUREG-0460, Volume 3:
This document presents potential system design modifications, which are proposed to mitigate the consequences of an ' anticipated transient without scram. '
EVALUATION OF GESSAR (BWR-6/MK III) WITH RESPECT TO NUREG-0460, Vol. 3 The subject of ATWS and its required design changes is being reviewed by the NRC staff on a generic basis for BWR plants. Upon completion of
- this generic program, GESSAR will reflect the final design solution.
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