ML20245A318
| ML20245A318 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/1987 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Zerbe J Committee To Review Generic Requirements |
| Shared Package | |
| ML20235F344 | List: |
| References | |
| NUDOCS 8703190649 | |
| Download: ML20245A318 (3) | |
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l 13127 MEMORANDUM FOR: John E. Zerbe, Actino Chairwan Comittee to Review Generic Requirements FPOM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
RESPONSE TO CRGR COMMENTS CONCERNING P.<0 POSED PEVISION 2 TO STANDARD REVIEW PLAN 6.5.2 At its 105th meeting on January 15, 1987, the Committee made a number of comments concerning its conditional approval of the subject proposal. NRR agrees with the comments and the major comments have been accommodated as follows:
- 1. The implementation instructions have been reworded to make clear that no current licensee or applicant need comply, but may voluntarily adopt the revision's positions.
- 2. The Committee stated that its favorable recommendation was based upon the assumption that proposed Regulatory Guide 1.3/1.4 would be available at least in draf t for public comment prior to the issuance of SRP 6.5.2 in final form, i.e. , in time for CRGR's review of the final revision. Efforts i will be made to expedite the development of Regulatory Guide 1.3/1.4 so that draft copies will be available by the time the final version of SRP 6.5.2 is due to come before CRGR. -jf/cTdc.ie.}
$3. A copy of the proposal is being cent to Jacqueline P. Lonoworth, of the linited King' dom Central Electricity Generatino Board, with a reouest fpr > E comments. (_ - ~N- =I k ^ " ; - M ~y & Ws <=
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- 4. A reference to SRP 6.5.2 bas been added to attempt to coordinate the sprayreviewwiththy~reviewofhy/tpgen,controlsystems.
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< 5. The discussinn of containment sump design has been reworded to remove any implicatici, of conflict with 051 A-43.
- 6. A specific wordinn change suggested by CPGR to avoid misinterpretation, +d5 b,~ ,a, with respect to subatmospheric containments was adopted. h" y
'7. The position that switchover from injection to recirculation was to b? I automatic in rrder to prevent sprey pump damage from loss of suction was l made explicit. g,,, , , gf m ,sg (;.,, ,., f cf/,rg Me Od A lu MM c ow tw-be4
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d John E. Zerbe 2 6<c8.. The proposed revision has been reviewed by the Technical Specifications Coordination Branch and found to be consistent with the Technical Specification Improvement Project. 7
- 9. Wordino has been revised to render explicit that (any/ acceptably equivalent calculation may be used rather than the staff't. adopted computer code, and the format of the new wording has been made consistent
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arold R. Denton, Director Office of Nuclear Reactor Regulation l
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Enclosure 2 to the Minutes of CRGR Meetino No.109 Review of the Proposed New SRP 6.5.5
.B.
Sheron (NRR) and L. Soffer (DSR0) presented for CRGR review the proposed new Standard Review Plan (SRP) 6.5.5.
well as a revised SRP 6.5.5., are attached.The vugraphs used for this presentation
'In essence, SRP 6.5.5. allows credit in the 10 CFR 100 dose calculation for suppression pools as fission product cleanup systems. Such credit is a recognition of the present state of knowledge regarding fission product retention in water.
Allowing credit for suppression pool retention is not intended to reduce plant safety. However, the proposed SRP did envision SGTS filtration system efficiencies 5 percent. as low as 90 percent or containment allowable leakages as high as Other than plants applying for a new Construction Pemit (CP), of which there presently are none, compliance with the SRP is voluntary. Furthemore, if a licensee uses conservative decontamination factors (DFs), then an analysis is not. required. Conservative DFs for Mark I designs are equal to or less than DFs for Mark II/III designs due to Mark I smaller pool inventory and smaller downcomer submergence, .
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ACRS did not object to issuance of SRP 6.5.5. for coment. However, ACRS advised that they wanted to re-look at the revised SRP after comments have been received and evaluated.
The CRGR recomended that the following issues be addressed:
O) If increased fission product concentrations in the suppression pool are acknowledged, then the effect on the environmental qualification of souip-ment and access to equipment during an accident should be addressed.
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' (2) SRP 6.5.5. and R.G. 1.3 are inconsistent. They should both be revised in final form at the same time and, by so doing, be made consistent. This correlation should be indicated when the SPP is issued for comment.
'(3) ALAPA considerations vs. system safety requirements should be balanced.
As a minimum, there should be a recognition of ALARA concerns.
A (4) It should be made clear that the burden of proof should be on the appli-cant if DFs above the conservative allowables are used.
- (5) Revisions to allowable containment leakage rates should be handled separately as part of the siting, source term or containment performance criteria efforts.
CRGP recommends that the staff issue the proposed SRP for comment after appropriate revision to reflect issues 2 through 5. Issue 1 may be addressed subsequent to issuing the SRP for comment,
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