ML20149L847

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Forwards RAIs to Complete Review of Draft Safety Evaluation Rept Open Items Re W AP600 Advanced Reactor Design.Staff Evaluations of Certain Open Items Also Encl
ML20149L847
Person / Time
Site: 05200003
Issue date: 11/13/1996
From: Diane Jackson
NRC (Affiliation Not Assigned)
To: Liparulo N
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
NUDOCS 9611190157
Download: ML20149L847 (20)


Text

I e ..

. November 13, 1996-Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities -

Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 SU8 JECT: STAFF UPDATE TO CERTAIN DRAFT SAFETY EVALUATION REPORT (DSER) OPEN ITEMS (01s) AND REQUESTS FOR ADDITIONAL INFORMATION (RAI) REGARDING THE WESTINGHOUSE AP600 ADVANCED REACTOR DESIGN

Dear Mr. Liparulo:

As a result of recent efforts by the Nuclear Regulatory Commission staff, the status of several DSER OIs has changed and additional information needed to complete the review has been identified. Enclosed are the RAls, which are designated as RAI# 260.83 - 260.89, and the staff's evaluations of certain open items.

Please update the open item tracking system database to reflect this informa-tion. If you have any questiens regarding this matter, you.can contact me at (301) 415-8548.

Sincerely, original signed by:

Diane T. Jackson, Project Manager Standardization Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003 l 4

Enclosure:

As stated cc w/er,::losure: ,

See next page t

DISTRIBUTLON:

4ecketeFi'ed PDST R/F TMartin 3I PUBLIC DMatthews TRQuay TKenyon BHuffman JSebrosky DJackson JMoore, 0-15 B18 WDean, 0-17 G21 ACRS (11) MPSiemien, 0-15 B18 SBlack, 0-9 Al I JPeralta, 0-9 Al _GBagchi, 0-7 H15 TMarsh, 0-8 D1 JLyons, 0-8 D1 CLi, 0-8 D1 JBrammer, 0-7 H15 GGeorgiev, 0-7 H15 Alevin, 0-8 E23 TCollins, 0-8 E23 DOCUMENT NAME: A:UPDA-0IS.NOV -(See previous concurrence)

Ta smeelve e sepy of this doeurnent Indcate in the boa: *C" = Copy without ettschment/encloswa *E" = Copy with attachment /encloswe *N* = No copy 0FFICE PM:PDST:DRPM BC:HQMB:DRCH SPLB:DSSA D:PDST:DRPM l NAME DJackson:sg Mr SBlack* JLyons* TRQuay TtM DATE l( /I1/96 (l

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11/07/96 11/08/96 ff/6 /96 j 3nnn . OFFICIAL RECORD COPY PD j

Mr. Nicholas J. Liparulo Docket No.52-003 Westinghouse Electric Corporation AP600 1

1 cc: Mr. B. A. McIntyre Mr. Ronald Simard, Director i

Advanced Plant Safety & Licensing Advanced Reactor Programs Westinghouse Electric Corporation Nuclear Energy Institute Energy Systems Business Unit 1776 Eye Street, N.W.

P.O. Box 355 Suite 300 Pittsburgh, PA 15230 Washington, DC 20006-3706 Mr. John C. Butler Ms. Lynn Connor i Advanced Plant Safety & Licensing Doc-Search Associates Westinghouse Electric Corporation Post Office Box 34 Energy Systems Business Unit Cabin John, MD 20818 Box 355 Pittsburgh, PA 15230 Mr. James E. Quinn, Projects Manager LMR and SBWR Programs Mr. M. D. Beaumont GE Nuclear Energy Nuclear and Advanced Technology Division 175 Curtner Avenue, M/C 165 Westinghouse Electric Corporation San Jose, CA 95125 One Montrose Metro 11921 Rockville Pike Mr. Robert H. Buchholz

Suite 350 GE Nuclear Energy Rockville, MD 20852 175 Curtner Avenue, MC-781

! Mr. Sterling Franks

. U.S. Department of Energy Barton Z. Cowan, Esq.

NE-50 Eckert Seamans Cherin & Mellott 19901 Germantown Road 600 Grant Street 42nd Floor Germantown, MD 20874 Pittsburgh, PA 15219 Mr. S. M. Modro Mr. Ed Rodwell, Manager Nuclear Systems Analysis Technologies PWR Design Certification ,

Lockheed Idaho Technologies Company Electric Power Research Institute Post Office Box 1625 3412 Hillview Avenue Idaho Falls, ID 83415 Palo Alto, CA 94303 Mr. Frank A. Ross Mr. Charles Thompson, Nuclear Engineer U.S. Department of Energy, NE-42.

AP600 Certification l Office of LWR Safety and Technology NE-50 19901 Germantown Road 19901 Germantown Road

Germantown, MD 20874 Germantown, MD 20874 i

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NRC Status of Various Open Items  !

l OITS# 562 - DSER Open Item 3.2.1-1

(

In your. response to Open Item 3.2.1-1 (562) in the attachment to your  !

October 14, 1996, letter to the NRC (NSD-NRC-96-4841) you stated: "When the guidance in RG 1.29 position C.4. was developed, the concept of '

graded QA had not been developed. An Appendix B QA program is not neeced

-[our emphasis) to provide the seismic Category II systems, structures, and components do not fail in a manner that would reduce the functioning of a safety-related component. The degree [our emphasis) of QA provided i for AP600 equipment Class D provides an appropriate level of QA for this l function. Westinghouse has defined QA requirements for the regulatory l treatment of nonsafety systems, systems, and components. .Those require- l ments also are sufficient [our emphasis) to satisfy the regulatory  ;

requirements [our emphasis] for seismic Category II." i Section A, " Introduction," of Regulatory Guide (RG) 1.29, " Seismic Design Classification," Revision 3, states, in part, that General Design l Criterion 2, " Design Bases for Protection Against Natural Phenomena," of Appendix A to 10 CFR Part 50, requires that nuclear power plant struc-tures, systems, and components (SSCs) important to safety be designed to withstand the effects of earthquakes without loss of capability to perform their safety functions.

Appendix B to 10 CFR Part 50 est' a blishes quality assurance (QA) require-ments for the design, construction, and operation of nuclear power plant-SSCs that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the_ public. The certinent requirements of Appendix B apply to all activities affecting the safety-related functions of those SSCs.

Appendix A to 10 CFR Part 100, " Reactor Site Criteria," requires that all nuclear power plants be designed so that, if the Safe Shutdown Earthquake (SSE) occurs, certain SSCs remain functional.

RG 1.29, Regulatory Position (RP) C.4 of RG 1.29, Revision 3, states "The pertinent [our emphasis] QA requirements of Appendix B to 10 CFR Part 50 should be applied to all activities affecting the safety-related func-tions of those portions of structures, systems, and components covered under RPs 2 and 3 above."

RG 1.29, RP C.2. states "Those nortions of structures, systems, or  !

components whose continued function is not required but whose failure  !

could reduce the functioning of any plant feature included in itses 1.a through 1.q above to an unacceptable safety level- or could result in '

incapacitating injury to occupants of the control room should be designed and constructed so that the $$E would not cause such failure [our emphasis)."

Enclosure ,

i RP C.3. states " Seismic Category I design requirements should extend to the first seismic restraint beyond the defined boundaries. Those portions of structures, systems, or components that form interfaces between Seismic Category I and non-Seismic Category I features should be

designed to Seismic Category I requirements [our emphasis]."

Status: Action W - Pending resolution to RAls# 260.83 - 260.87 Based on the above, the staff requests the following additional informa-tion:

RAI# 260.83 - HQMB - DSER Section 3.2.1 Is it Westinghouse's position that RP C.4 of RG 1.29 is incongruous with j

the " concept of graded QA"? Also, please explain what Westinghouse's

" concept of Graded QA" is and where that concept is defined in the standard safety analysis report (SSAR).

RAI# 260.84 - HQMB - DSER Section 3.2.1 Explain how QA requirements for the regulatory treatment of nonsafety j systems, systems, and components (RTNSS) which, Westinghouse has defined in Letter NSD-NRC-96-4670, dated March 26, 1996, are also sufficient to satisfy the reaulatory reauirements for seismic Category II, as described

, i in RG 1.29, i.e., "all activities affecting the safetv-related functions of those portions of structures, systems, and components covered under

RPs 2 and 3" of the RG?

RAI# 260.85 - HQMB - DSER Section 3.2.1 Please identify all RTNSS SSCs that would also satisfy the functional and

design criteria of those portions of structures, systems, and components j covered under RPs 2 and 3 of RG 1.29.

RAl# 260.86 - HQMB - DSER Section 3.2.1 How would RTNSS QA requirements as defined in NSD-NRC-96-4670 address interface desian reauirements identified in RP C.3.?

1 RAI# 260.87 - HQMB - DSER Section 3.2,.1 l

Westinghouse's statement above appears to imply that RTNSS QA require-ments as defined in NSD-NRC-96-4670 would also be applicable to 111 AP600 l equipment Class D. Please clarify.

OITS# 563 - Open Item 3.2.1-2 4

In your response to this Open Item (October 14, 1996, NSD-NRC-96-4841) you have proposed to revise the seventh paragraph of 3.2.2.6 as follows:

" Standard industrial QA standards are applied to Class D structures, systems, and components to provide appropriate integrity and function

, 10 CFR Part 50 Appendix B and 10 CFR Part 21 do

! although not apply. (our emphasis)iSOEAjipp5diRBf,andflCCFR]ht!21[do?ipplfto 101CFRlPiFt 4

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! i i DistFEtHHifHiystiiiiiW~aMXamponintiittispiWis t siiiki Cats j ClisiTljndustria1104 These standards ~are consisteniliiith"thi gdidilines~g6iFim foi NRC  ;

QualitF~Grody'D T The industry standards....."

Status: Action W - Pending resolution to RAI# 260.88 - 89.

Based on the above discussion, the staff requests the following addition-
al information
,

i RAI# 260.88 - HQMB - DSER Section 3.2.1 While the staff may agree that " industrial QA standards are consistent J with the guidelines for NRC Quality Group D", it is not clear how you  :

concluded that such standards, without NRC endorsement, satisfy the  !

{ provisions of Appendix B to 10 CFR Part 50. Please clarify.

RAI# 260.89 - HQMB - DSER Section 3.2.1 SSAR Section 3.2.2.2, " Application of Classification," Page 3.2-5,  ;

states, in part, " Structures, systems, and components classified equip- ,

j ment. class A, B, or C or seismic Category I are basic components as  !

a defined in 10 CFR Part 21." Please clarify how a " Basic Component" as j_ defined in 10 CFR Part 21 can also be classified as Equipment Class D, as  !

defined in SSAR Section 3.2.2.6.

i OITS# 934 (DSER 5.4.2.1-2) 4 The staff reviewed the SSAR Section 5.4.2.3 and found it acceptable.

Status: Resolved OITS# 1892 (DSER 5.2.1.1-1)

The staff has reviewed the SSAR change and found it acceptable. l

. Status: Resolved '

OITS# 1893 (DSER 5.2.1.1-2) j The staff has reviewed the SSAR change and found it acceptable.

s Status: Resolved i

The following list is our review status of AP600 SSAR (up to Revision 9) Sec-tions 9.2.1, 9.2.2, 10.2, 10.3, and 10.4 (10.4.1-10.4.4, and 10.4.10). We 4

have incorporated the results of our telecon of September 23, 1996, between Westinghouse and the staff. We have identified those items that conflicting i positions exist between Westinghouse and us. If resolution can not be reached

before the time that we have to write the safety evaluation report (SER),

these items will become "open items" in the SER.

l Service Water System (SWS), discrepancies OITS# 223 (DSER Section 9.2.1) in SSAR and Probabilistic Risk Assessment 1 (PRA) )

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! PRA Fig. 19.1 (Revision 7) and SSAR Revision 9 Chapter 14 (Sec-

tions 14.2.9.4.5 and 14.2.9.2.6) resolved the discrepancy.

. Status: Resolved l

OITS# 224 (DSER Section 9.2.1) SWS, RTNSS Requirenients  !

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The acceptability of the response to RAI Q410.109 is pending on the policy position for the requirements of DID and RTNSS.

i Status: Action W OITS# 225 (DSER Section 9.2.1) SWS Testing and' Inspection The staff is evaluating Westinghouse's position pending policy decision on RTNSS requirements of testing and inspection.

Status: Action N OITS# 226 (DSER Section 9.2.1) SWS Leakage RAI Q410.110 concerned radioactive leakage into and out of the SWS. The staff has reviewed SSAR Revision 3 and Revision 6, Section 9.2.1 and finds that Westinghouse has not adequately included all the information in the response to RAI Q410.110. For example, the provisions for taking local fluid samples and isolation by remote manual control were discussed in the RAI response but not in the revised SSAR. The response to Q410.110 is acceptable, but the revised SSAR is incomplete.

Following the telecon of September 23, 1996, Westinghouse sent marked-up pages of SSAR Sections 9.2.1.3 and 9.2.1.5. The staff finds the revised pages acceptable pending the incorporation of these changes in the SSAR.

Status: Action-W, technically resolved.

OITS# 227 & 228 were resolved previously.

OITS# 229 (DSER Section 9.2.1)

Following the telecon of September 23, 1996, Westinghouse sent marked-up pages of the response to RAI 510.115, Revision 1 and SSAR changes. The staff. finds the revised pages acceptable pending the incorporation of these changes.

Status: Action-W, technically resolved.

OITS# 230 (DSER Section 9.2.2) Component Cooling Water System (CCS) Descrip-tion I Status: Resolved per SSAR Revision 6 Table 9.2.2-2  !

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, i l l OITS# 231 was resolved previously.  !

OITS# 232 (DSER Section 9.2.2) Inconsistency on CCS Testing Status: Resolved per Westinghouse letter dated August 30, 1996, which  !

provided the response to RAI 410.15, Revision 1.

1 OITS# 233 (Section 9.2.2) CCS RTNSS Requirements l

l- l l The acceptability of the response to RAI Q410.120 is pending on the

policy position for the requirements of DID and RTNSS.

i Status: Action W OITS# 234 & 235 were resolved previously.  !

i

) OITS# 358 (Section 10.2) Turbine Overspeed Trip Design i i 3

The AP600 turbine generator does not have a mechanical overspeed trip  ;

j devices, which deviates from the standard review plan (SRP) Section 10.2,  ;

, Paragraph III.2.c. The staff has reviewed Westinghouse's justification

in the SSAR and has not found adequate bases for this deviation.

t .

j The turbine generator system installed in a nuclear plant is typically i j equipped with redundant overspeed protection. SRP Section 10.2, Turbine Generator, provides the guidance for the staff to review the overspeed protection. Specifically, the adequacy of the control and overspeed i protection system is discussed in Paragraphs III.2.a through III.2.d, i which includes the following recommendations:

I a.- The indepth defense that is provided by the turbine generator protection system to preclude excessive overspeeds should be de-signed with diverse protection means.

b. The electro-hydraulic control system fully cuts off steam at approx-i imately 103 percent of rated turbine speed by closing the control l and intercept valves.
c. A mechanical overspeed trip device is provided that will close the  ;

i stop and. intercept valves at approximately 111 percent of rated j speed.

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d. An independent and redundant backup electrical overspeed trip l circuit is provided to close all valves at approximately 112 percent ,

of rated speed. '

In the Draft Safety Evaluation Report for AP600, the staff identified in

.l Open Item 10.2.4-1 that the AP600 turbine generator did not have a

mechanical overspeed trip device, which deviates from the recommendation j in SRP Section 10.2 Paragraph III.2.c.

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. _ _ . _ . _ _ _ _ _ _ _ . _ . _ . _ _ _ ._ _ _ . _ .._ _ _. _ _ ..~..._. _ _ _ .

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!. -G-i In response, Westinghouse states in SSAR Revision 5, Section 10.2.2.5.3,

that AP600 turbine provides the speed control and overspeed protection of
the digital electrohydraulic system combined with the emergency trip i system to provide a level of redundancy and diversity that is at least equivalent to the turbine overspeed protection recommended in SRP Section 10.2 paragraph 111.2. Westinghouse states that AP600 overspeed trip
reliability is comparable to the reliability for the combination of mechanical and electrical overspeed trips in operating nuclear power j plants. Furthermore, Westinghouse states that adverse interactions and human factors difficulties associated with the mechanical overspeed trip during testing of the mechanical and electrical trips have previously i

contributed to several overspeed events. Westinghouse believes that the elimination of the mechanical overspeed trip will enhance the AP600 i

turbine generator reliability during testing.

i

! However, Westinghouse has not provided any engineering analysis or operating data to support its belief that AP600 overspeed trip reliabili-l ty is comparable to the reliability for the turbine overspeed protection i recommended in SRP Section 10.2 paragraph III.2. It is not clear to the j staff that giving up a diverse means of overspeed protection is the best approach to eliminate the trouble of turbine trip testing. AP600 turbine

! overspeed trip design is different from all operating nuclear plants and

advanced reactor designs (System 80+ and ABWR). It also deviates from EPRI Requirements Documents for Advanced Light Water Reactors of passive
designs, which states that a mechanical overspeed trip device shall be

! provided. Based on the available information so far, the staff has determined that AP600 turbine overspeed trip design not acceptable.

! In OITS database, Westinghouse determined the status of this item as

! " Closed." The staff believes that this item is "Open." Westinghouse is

taking a position that deviates from the staff review guidance and that i does not have sufficient justification for the staff to find it accept-able.

Status: Action W OITS# 359 (DSER Section 10.2) Turbine Extraction Nonreturn Valve Westinghouse performed its turbine overspeed analysis in accordance with ASME PTC 20.2. The closure time of extraction nonreturn valve is not important for turbine trips. A closure time is specified to ensure that the valves close during an accident to minimize overall flow following a turbine trip.

Status: Resolved

l OITS# 360 (DSER Section 10.2) Turbine Valve Inspection Westinghouse provided justification in the SSAR Revision 8 Section 10.2.3.6.

Status: Resolved OITS# 361 (DSER Section 10.2) Turbine Valves Test Frequency

Westinghouse provided a referenced topical report, WCAP-11525, which was reviewed and found acceptable.

Status: Resolved l OITS# 362 (DSER Section 10.2) Turbine Generator Rating Inconsistency was identified on turbine generator rating. Westinghouse revised SSAR. However, there is still inconsistency. SSAR Revision 5, Section 10.1.0 states 675,000 KW, but Table 10.2.1 states 792,000

Kilowatts (KW). l In the telecon of September 23, 1996, Westinghouse explained that these l two numbers are supposed to be different. The first number represents '

the required KW and the second number represents the KW that the turbine generator may provide, which has a margin over the requirement. Subse-quently, Westinghouse provided marked-up pages of SSAR p. 10.1-1 and 10.1-5 to clarify the confusion.

Status: Action W - Technically resolved OITS# 363 (DSER Section 10.2) Turbine Generator Design Basis The remaining concerns on meeting SRP 10.2 is subject to the resolution '

of OITS# 358, Turbine Overspeed Trip Design.

Status: Active - pending resolution of OITS# 358.

OITS# 364 was resolved previously OITS# 365 (DSER Section 10.3) Leak-Before-Break (LBB) Application to Steamlines The Plant Systems Branch has reviewed Westinghouse's letter, dated July 26, 1996, regarding "AP600 LBB QUESTIONS" and discussed it with EMCB and TSB staff (S. Hou, D. Terao, and A. Chu). We find the Westinghouse new position described in the letter regarding steamline leakage control unacceptable.

In the SSAR, Westinghouse applies LBB to steamlines. The application of LBB in current PWRs is limited to the reactor coolant system, which has a

i reactor coolant pressure boundary leakage detection system and Technical Specification (TS) controls. In order to apply LBB to steamlines, a steamline leakage detection system that is comparable to the reactor coolant pressure boundary leakage controls should be provided. In its previous response to Q410.145, Westinghouse committed to provide leak 2

detection systems and TS control for the steamline leakage control.

In a letter of July 26, 1996, Westinghouse revised its response to Q410.145 to withdraw its TS commitment for steamline leakage detection

without withdrawing LBB for the steamline application. This is not acceptable because the technology of LBB relies on the detection of leaks prior to pipe breaks. Without TS requirements on steamline leakage detection, the staff will not accept the application of LBB to steamlines. The alternative method proposed by Westinghouse in the letter, using administrative procedures, does not provide sufficient measures to justify LBB application for steamlines. The staff has determined that Westinghouse should either provide a proper TS for steamline leakage detection or withdraw its LBB application for steamlines.

Subsequent to the telecon of September 23, 1996, Westinghouse provided draft TS 3.7.8, Secondary Coolant Leakage, on this issue. We are reviewing it with TSB and EMCB. We intend to provide our comments on draft TS 3.7.8 along with other comments from our AP600 TS review.

Status: Action N OITS# 366 (DSER Section 10.4)

Following the telecon of September 23, 1996, Westinghouse sent marked-up pages of the response to RAI 510.255, Revision 1, which clarified its previous responses and SSAR changes. The staff finds the revised response acceptable.

Status: Resolved 1

OITS# 367 (DSER Section 10.4.2):

WCAP-13054 indicates that RG 1.33, " Quality Assurance Program Require-ments (Operation)," is not applicable to design certification. It applies only to operational phase of nuclear power plants. Therefore, the staff will review COL applications to ensure their conformance with RG 1.33. A COL applicant referencing the AP600 certified design should demonstrate compliance with RG 1.33. Westinghouse should include this COL Action Item in the SSAR.

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In the telecon of September 23, 1996, Westinghouse indicated that SSAR Section 17.4 has a generic COL Action Item on QA program for operation. .

Therefore, the issue is resolved.

Status: Resolved 1

OITS# 368 (DSER Section 10.4.2):

)

This is an open item because Westinghouse takes a position that deviates  ;

from RG 1.26 and the staff finds Westinghouse's position not acceptable.

4 In RAI Q410.257, the staff questioned the compliance with RG 1.26 as  !

related to main condenser evacuation system (CMS) quality group classifi-l cation. In response, Westinghouse, referring to SSAR Sections 3.2.2.6 and 3.2.2.7, indicated that the CMS is Class E according to AP600 4

classification, which defines systems and components that have potential to be contaminated with radioactive fluids but do not normally contain radioactive- fluids as Class E. The staff has reviewed SSAR Section 3.2.2.6 and 3.2.2.7, but has not found sufficient justification for Westinghouse's position of using Class E for CMS. The referenced SSAR sections simply stated Westinghouse's position, but did not identify it i as a deviation from RG 1.26 nor provide any justification for its deviation. "AP600 classification" is not a regulation and does not mean it meets NRC regulations. Simply referring the referenced section did 3

i not answer the staff question. i l

In a meeting of February 22-23, 1995, Westinghouse agreed this was a i deviation from RG 1.26, and committed to revise WCAP-13054, "AP600 Compliance with SRP Acceptance Criteria," to identify it as a deviation l i

from RG 1.26 for document consistency. Meanwhile, the staff evaluated l the acceptability of Class E for CMS and found Westinghouse's position inconsistent with RG 1.26 and Section 10.4.2 of the SRP. RG 1.26 l Position C.3 states that Quality Group D should be applied to components i and systems that "contain" or "may contain" radioactive material. 1 Radioactive contaminants in CMS can be obtained through primary-to-  ;

secondary system leakage resulting from steam generator tube leakage.

SRP Section 10.4.2 states that the components of the CMS should be designed to Quality Group D as defined in RG 1.26. The staff can not find specific AP600 design differences that would justify Westinghouse's position.

In Revision 2 to WCAP-13025, Westinghouse indicates that RG 1.26 will not be met and consider the status of this item is " Closed." However, Westinghouse did not provide any justification for its deviation from RG 1.26. The staff believes the status of this item is " Active."

As a result of the telecon of September 23, 1996, Westinghouse provided justifications for its position via facsimile dated October 14, 1996.

Westinghouse indicated that based on its operating experience of current PWRs the p obability of a radioactive release from the CMS is low, and 4

the consequences is limited even if there were a release. 1 4

The staff reviewed the justifications and found them not acceptable. The reason for the staff finding is that there is no difference in CMS- ,

between AP600 and other PWR plants. The CMS of other PWRs meets RG 1.26 '

with respect to Quality Group D requirement. The argument of low probability and limited consequences can only justify the system to Quality Group D. Therefore, the CMS of AP600 should not be downgraded in QA; Quality Group D should be applied to the system. In a telecon of October 21, 1996, Westinghouse disagreed with the staff and believed that RG 1.26 should be revised. The staff has determined that Westinghouse's position is not acceptable. This is an unresolved open item.

I Westinghouse is taking a position that deviates from the staff review guide and that does not have sufficient justification for the staff to

find it acceptable.

Status: Action W OITS# 369 (DSER Section 10.4.3):

Same comment as OITS Item No. 367 applies.

Status: Resolved OITS# 370 (DSER Section 10.4.3):

Same comments as 0ITS# 368 apply to the turbine steam sealing system.

Westinghouse is taking a position that deviates from the staff review guide and that does not have sufficient justification for the staff to find it acceptable.

Status: Active - pending resolution of OITS# 368 OITS# 371 & 374 were resolved previously.

OITS# 1090 (DSER 9.2.1-1)

Status: Active - This item will be resolved subject to the resolution of all open items of SWS (Items 223-229).

OITS# 1091 (DSER 9.2.2-1)

Status: Active - This item will be resolved subject to the resolution of all open items of CCS (Items 230-234).

OITS# 1093 (DSER 9.2.8-1) was resolved previously.

_- .- .. ~ . . ~ . . . .. - - - ~ . . . . - .- .- . ...- . - - . - . - - - -

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, I OITS# 1133 (DSER 10.2-1) l Same status as OITS# 362: Active j

'0ITS# 1134 (DSER 10.2.4-1) Turbine Overspeed Trip Design j Same status as OITS# 358: The design is not acceptable.

l OITS# 1142 (DSER 10.2.10-1)

' Status: Active - This item will be resolved subject to the resolution of  !

Items 358-361.

l OITS# 1143 (DSER Section 10.3-1)

Status: Active - This item will be resolved subject to the resolution of Items No. 364 & 365 are resolved.

OITS# 1150 (DSER Section 10.4.1-1) i Status: Resolved - This item was resolved with the resolution of 1

OITS# 366. ,

! OITS# 1151 (DSER Section 10.4.2) {

. This item will be resolved when Item Nos. 367 and 368 are resolved.

i OITS# 1152 (DSER Section 10.4.3) l l This item will be resolved when Item Nos. 369 and 370 are resolved.

, OITS# 1153 (DSER Section 10.4.4) was resolved previously.

l OITS# 1165.(DSER Section 10.4.10-1) was resolved previously.

! The following table represents the NR'C staff's current status of open items i associated with AP600 SSAR Chapter 21. A number of these items are resolved L

pending satisfactory treatment in the recently submitted PIRT/ Scaling report.

The. status of these items should be " Resolved" under NRC status and the status

.line should be revised to reflect NOTE 1 below. '

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l l NOTE 1: Resolved - pending satisfactory treatment of the subject in the PIRT/ Scaling Report

OITS # NRC STATUS STATUS INFORMATION UPDATE- I 8 CLOSED 9 CLOSED 11 CLOSED

! 12 CLOSED 14 CLOSED 18 CLOSED 25 ACTION W Waiting for submittal of .

revised PRHR Report l 38 RESOLVED ** SEE NOTE 1 l i

39 RESOLVED ** SEE NOTE 1

2075 RESOLVED ** SEE NOTE 1 2076 CLOSED 1 2077 RESOLVED ** SEE NOTE 1 4

2078 RESOLVED ** SEE NOTE 1 2079 CLOSED 2080 CLOSED l J81 CLOSED I 2082 CLOSED 2083 CLOSED -

2084 CLOSED

. 2085 CLOSED 2086 CLOSED ,

2087 RESOLVED ** SEE NOTE 1 2088 CLOSED 4

2090 CLOSED 2091 CLOSED 2092 CLOSED

OITS i NRC STATUS STATUS INFORMATION UPDATE 2093 CLOSED l

2094 CLOSED t 2095 CLOSED 2096 RESOLVED ** SEE NOTE 1 2097 CLOSED 2098 CLOSED 1

2099 CLOSED ,.

2100 CLOSED l

2101 CLOSED

2102 CLOSED 2103 CLOSED
2104 CLOSED g

2105 CLOSED 2106 CLOSED d 107 CLOSED _

2108 CLOSED 2109 CLOSED 2110 CLOSED 2111 CLOSED 2112 CLOSED 2113 RESOLVED ** SEE NOTE 1 2114 CLOSED 2115 CLOSED 2116 RESOLVED ** SEE NOTE 1 _ , , , , _

2117 CLOSED 2118 RESOLVED ** SEE NOTE 1 2119 CLOSED 2120 CLOSED

4 OITS # NRC STATUS STATUS INFORMATION UPDATE 2121 CLOSED

, 2122 CLOSED __

2123 CLOSED 2124 CLOSED 2125 CLOSED

, 2126 CLOSED 2127 RESOLVED ** SEE NOTE 1

2128 CLOSc0
2129 CLOSED 2130 CLOSED 2131 CLOSED i

2132 CLOSED 2133 CLOSED 2134 CLOSED

^

2135 RESOLVED ** SEE NOTE 1 2136 CLOSED 2137 CLOSED 2138 CLOSED 2139 RESOLVED ** SEE NOTE 1 2140 RESOLVED ** SEE NOTE 1 2266 CLOSED 2310 CLOSED 2311 CLOSED 2312 CLOSED ,

2313 CLOSED 2314 CLOSED 2315 CLOSED 2316 RESOLVED ** SEE NOTE 1 __

j OITS # NRC STATUS STATUS INFORMATION UPDATE 2317 CLOSED

2318 CLOSED 2319 CLOSED 2320 CLOSED

, 2321 CLOSED 2322 RESOLVED ** SEE NOTE 1 2323 CLOSED 2324 CLOSED 2325 RESOLVED ** SEE NOTE 1 2326 RESOLVED ** SEE NOTE 1 2327 CLOSED 2328 CLOSED 2329 RESOLVED ** SEE NOTE 1 2330 RESOLVED ** SEE NOTE 1 2574 CLOSED 2575 CLOSED 2576 CLOSED 2577 CLOSED 2578 CLOSED 2579 CLOSED 2580 CLOSED 2581 CLOSED 2582 RESOLVED ** SEE NOTE 1  !

2583 CLOSED 2584 CLOSED 2585 CLOSED 2586 CLOSED i 2587 RESOLVED ** SEE NOTE 1

i 1

1 j

OITS f NRC STATUS STATUS INFORMATION UPDATE 2588 CLOSED 2589 CLOSED 2590 CLOSED 2591 CLOSED 2592 RESOLVED ** SEE NOTE 1 2593 CLOSED 2594 CLOSED 2595 CLOSED 2596 CLOSED 2638 CLOSED 2649 RESOLVED ** SEE NOTE 1 2650 RESOLVED ** SEE NOTE 1 2651 RESOLVED ** SEE NOTE 1 2652 CLOSED 2653 CLOSED 2654 RESOLVED ** SEE NOTE 1 2655 RESOLVED ** SEE NOTE 1 2656 RESOLVED ** SEE NOTE 1 2657 RESOLVED ** SEE NOTE 1 2658 CLOSED

~

2659 ACTION N This item will be reas-sessed following review of the PIR!/ Scaling Re-port and Code V&V Docu-ments 2660 RESOLVED ** SEE NOTE 1 2661 CLOSED 2662 CLOSED 2663 CLOSED 2664 CLOSED

i 1

- 17 _

OITS # NRC STATUS STATUS INFORMATION UPDATE 4

2665 CLOSED 2666 RESOLVED ** SEE NOTE 1

2667- RESOLVED ** SEE NOTE 1 4 2668 CLOSED 2669 CLOSED

, 2670 CLOSED 2671 RESOLVED ** SEE NOTE 1 2672 ACTION N Staff mull confirm that this item is adequately addressed in PIRT/ Scaling Report 2673 RESOLVED ** SEE NOTE 1 2674 CLOSED 2675 CLOSED 2676 RESOLVED ** SEE NOTE 1 2677 RESOLVED ** SEE NOTE 1 2679 RESOLVED ** SEE NOTE 1 ,

2680 CLOSED 2682 RES01.VED ** SEE NOTE 1 2685 CLOSED 2687 RESOLVED ** SEE NOTE 1 2689 RESOLVED ** SEE NOTE 1 2690 CLOSED 2692 CLOSED 2693 CLOSED 2694 CLOSED 2695 CLOSED 2696 RESOLVED ** SEE NOTE 1 2697 RESOLVED ** SEE NOTE 1

1 OITS # NRC STATUS STATUS INFORMATION UPDATE 2699 RESOLVED ** SEE NOTE 1 2700 RESOLVED ** SEE NOTE 1 2701 CLOSED 2702 CLOSED 2988 CLOSED 2989 RESOLVED ** SEE NOTE 1 2994 CLOSED 2995 RC ?LVED ** SEE NOTE 1 2996 CLOSED 2997 CLOSED 2998 RESOLVED ** SEE NOTE 1 2999 CLOSED 3000 CLOSED 3001 RESOLVED ** SEE NOTE 1 3002 RESOLVED ** SEE NOTE 1 3003 CLOSED 3004 RESOLVED ** SEE NOTE 1 3005 RESOLVED ** SEE NOTE 1 _

3006 RESOLVED ** SEE NOTE 1 3276 ACTION W Westinghouse still needs to address NRC letter dated September 23, 1996 1616 ACTION W Westinghouse agreed to revise roadmap discussion based on telecon with Al Levin 4