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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20216J0681999-09-29029 September 1999 Forwards Rev 3 of AP600 Design Control Document, Incorporating Documentation Changes Resulting from Final Review Performed to Check Consistency of Implementation of Approved Design Change Proposals.With Summary of Changes ML20207G5411999-06-0808 June 1999 Discusses Request Made by Westinghouse on 981109 That Proprietary WCAP-14252,Rev 1,be Withheld from Public Disclosure.Determined Info to Be Proprietary & Will Be Withheld from Public Disclosure ML20195D5201999-06-0404 June 1999 Discusses Westinghouse Request That Change Pages Submitted on 980921 to WCAP-14292 Be Withheld from Public Disclosure. Determined Info to Be Proprietary & Will Be Withheld from Public Disclosure ML20196G2431999-05-21021 May 1999 Informs That USNRC Has Published in Fr Encl Notice of Proposed Rulemaking Re AP600 Design Certification Rule. Rulemaking Allows Applicants or Licensees to Construct AP600 Std Plant Design by Referencing Design Certification Rule ML20206G5411999-05-0505 May 1999 Forwards Draft Environ Assessment Re Proposed Certification of AP600 Std Plant Design.Environ Assessment Will Be Used as Basis for NRC Finding of No Significant Environ Impact Resulting from Certification of AP600 Design ML20205J3351999-04-0707 April 1999 Informs That USNRC Staff Has Completed Review of Rev 2 of AP600 Design Control Document,Verified That All of Changes in Rev 2 Are Acceptable & Determined That AP600 Dcd,Rev 2, Can Now Be Used in Proposed Design Certification Rule NSD-NRC-99-5827, Forwards Rev 2 to AP600 Design Control Document.Attachment 1 Provides Summary of Changes Made as Part of Mar 1999 Rev to AP600 Design Control Document1999-03-31031 March 1999 Forwards Rev 2 to AP600 Design Control Document.Attachment 1 Provides Summary of Changes Made as Part of Mar 1999 Rev to AP600 Design Control Document ML20205D3051999-03-25025 March 1999 Requests Amend to 920626 Application for Design Certification of AP600,including AP600 Ssar & AP600 Dcd,To Reflect Sale of CBS Commercial Nuclear Business to W ML20203C5481999-02-10010 February 1999 Forwards Rev 1 to AP600 Design Control Document (DCD) for Docket File.Dcd Provides Reference Basis for AP600 Design Certification ML20199H8671999-01-20020 January 1999 Forwards Comments on AP600 Design Control Document,Submitted by Westinghouse ML20199B1121999-01-0707 January 1999 Advises That Info Contained in NSRA-APSL-92-0268 & Containing Presentation Matl Used in 921209-10 Meeting,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA ML20198B4601998-12-14014 December 1998 Discusses W Ltr NTD-NRC-95-4556,dtd 950918,provided as Status Rept on Proprietary Matl Submitted to NRC to Support AP600 Design Review Effort.Proprietary Info in Encl Have Been Removed from AP600 Docket File & Being Returned ML20197G3501998-11-30030 November 1998 Forwards AP600 Design Control Document, Vols 1-12 for Docket File.Submittal Closes Confirmatory Items 1.5-1 & 1.5-2 from Sept 1998 Final SER Re Certification of AP600 Std Design ML20195E9331998-11-0909 November 1998 Requests That Rev 1 to WCAP-14252, AP600 Low-Pressure Integral Sys Test at or State Univ Final Data Rept, Vols I- Iv,Be Withheld (Ref 10CFR2.790) NSD-NRC-98-5806, Forwards non-proprietary Rev 1 to WCAP-14253 & Proprietary Rev 1 to WCAP-14252, AP600 Low-Pressure Integral Sys Test at or State Univ Final Data Rept. Proprietary Rept Includes Vols 1-4.Proprietary Info Withheld,Per 10CFR2.7901998-11-0909 November 1998 Forwards non-proprietary Rev 1 to WCAP-14253 & Proprietary Rev 1 to WCAP-14252, AP600 Low-Pressure Integral Sys Test at or State Univ Final Data Rept. Proprietary Rept Includes Vols 1-4.Proprietary Info Withheld,Per 10CFR2.790 ML20155G9021998-11-0303 November 1998 Advises That Info Contained in 981012 ltr,NSD-NRC-98-5795, Will Be Withheld from Public Disclosure,Per 10CFR2.790(b) (5) & Section 103(b) of AEA of 1954,as Amended ML20155G9271998-11-0202 November 1998 Forwards Copy of NRC Staff FSER for Westinghouse AP600 Design.Staff Completed Review of Design & Issued Final Design Approval & FSER on 980903.Without Encl ML20155G7591998-11-0202 November 1998 Forwards Copy of NRC Staff FSER for Westinghouse AP600 Design,Per Discussion at Sept 1997 Meeting.Staff Completed & Issued Final Design Approval of FSER on 980903.Without Encl NSD-NRC-98-5795, Informs That Figures from Rev 0 & Rev 3 of PRA Which Indicate Location of H Igniters Should Be Considered Proprietary.Nonproprietary Versions of AP600 General Arrangement Drawings Were Provided in Rev 7 of Ssar1998-10-12012 October 1998 Informs That Figures from Rev 0 & Rev 3 of PRA Which Indicate Location of H Igniters Should Be Considered Proprietary.Nonproprietary Versions of AP600 General Arrangement Drawings Were Provided in Rev 7 of Ssar ML20154A4091998-09-29029 September 1998 Advises That Certain Info Contained in Westinghouse Ltr NTD-NRC-95-4506,dtd 950713,submitting WCAP-14425,will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5).Figure 3-1 Will Be Placed Into Public Record ML20153G2521998-09-25025 September 1998 Advises That Proprietary Matl Discovered by NRC in NSD-NRC-97-4966 & Proprietary Matl Noted by W in NSD-NRC-98-5772 Will Be Withhheld from Public Disclosure Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954 ML20153C1001998-09-15015 September 1998 Advises That Matls Re AP600 Notrump Final Validation Rept, WCAP-14807,marked Proprietary Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended NSD-NRC-98-5788, Forwards Formal Transmittal of Correspondence Previously Sent Informally Over Period of 980702-0826.Index of Encl Matl Provided1998-09-15015 September 1998 Forwards Formal Transmittal of Correspondence Previously Sent Informally Over Period of 980702-0826.Index of Encl Matl Provided ML20151X4381998-09-15015 September 1998 Informs That Staff Has Decided to Accept Claim That Info in WCAP-14135,Rev 1 Is Proprietary & Will Be Withheld from Public Disclosure,Per W 980821 & 26 Ltrs ML20151X4041998-09-11011 September 1998 Discusses Revised Tier 2 Info for AP600 Design.Staff Revised Decision on Whether Fire Protection Should Expire at First Full Power Encl ML20151V1711998-09-0808 September 1998 Advises That Info Re Westinghouse AP600 Std Safety Analysis Rept Through Rev 4 & PRA Through Rev 5 Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5).Disposition of Ssar & PRA Proprietary Info Encl ML20151V2231998-09-0808 September 1998 Informs That NRC Determined That WCAP-14132 Encl in Westinghouse Ltr NTD-NRC-94-4244,dtd 940729 & Marked as Proprietary,Will Be Withheld from Public Disclosure,Per to 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954 ML20151S9181998-09-0303 September 1998 Advises That Info Marked as Proprietary Re Westinghouse AP600 Design Ltrs Concerning Pxs Scaling & Pirt Closure Rept WCAP-14727,will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20239A1481998-09-0303 September 1998 Forwards Notice of Issuance of Final Design Approval & Final SER for AP600.FDA Allows AP600 Design to Be Referenced in Application for Construction Permit or Operating License Under 10CFR50 or Application for Combined License ML20239A3111998-09-0303 September 1998 Forwards Final SER Which Summarizes Staff Safety Review of AP600 Design Against Requirements of Subpart B of 10CF5R52 & Delineates Scope of Technical Details Considered in Evaluating Proposed Design ML20151V8521998-09-0101 September 1998 Extends Invitation to Attend Ceremony on 980911,where NRC Will Present Final Design Approval for AP600 Std Nuclear Reactor Design to Westinghouse NSD-NRC-98-5781, Informs That W Determined That AP600 FSER Contains No Proprietary Info1998-09-0101 September 1998 Informs That W Determined That AP600 FSER Contains No Proprietary Info ML20151V2201998-08-31031 August 1998 Informs That EPRI Documents, GOTHIC Containment Analysis Package Qualification Rept, GOTHIC Containment Analysis Qualification Manual, & Listed Documents Dtd Sept 1993 Will Be Withheld from Public Disclosure ML20151V8431998-08-31031 August 1998 Extends Invitation to Attend Ceremony on 980911,where NRC Will Present Final Design Approval for AP600 Std Nuclear Reactor Design to Westinghouse ML20238F3241998-08-31031 August 1998 Advises That AP600 RAI Responses Encl in Westinghouse Ltrs NTD-NRC-95-4598,dtd 951117,as Modified by NSD-NRC-98-5776, Dtd 980826,marked Proprietary Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) ML20238F5991998-08-31031 August 1998 Refers to W 980821 Revised Response to Insp Rept 99900404/97-01 That Contained All Substantive Info Provided w/DCP/NRC-1074 Ltr.Nrc Will Destroy DCP/NRC-1074,as Requested NSD-NRC-98-5783, Forwards non-proprietary Rev 2 to WCAP-14989, Accident Specification & Phenomena Evaluation for AP600 Passive Containment Cooling Sys1998-08-28028 August 1998 Forwards non-proprietary Rev 2 to WCAP-14989, Accident Specification & Phenomena Evaluation for AP600 Passive Containment Cooling Sys NSD-NRC-98-5782, Forwards Corrected Pages 4-28 Through 4-32 to Be Inserted in Rev 2 to non-proprietary WCAP-14953, AP600 Pxs Scaling & Pirt Closure Rept. Pages Were Originally Submitted W/Incorrect Header Which Stated 'W Proprietary Class 2.'1998-08-28028 August 1998 Forwards Corrected Pages 4-28 Through 4-32 to Be Inserted in Rev 2 to non-proprietary WCAP-14953, AP600 Pxs Scaling & Pirt Closure Rept. Pages Were Originally Submitted W/Incorrect Header Which Stated 'W Proprietary Class 2.' NSD-NRC-98-5778, Provides Commitment to Include Requested Changes Into AP600 Design Control Document.Discussion W/Vijuk on 980825 Re Disposition of Ltrs DCP/NRC1074,dtd 971016 & DCP/NRC1324,dtd 980403,formalized1998-08-27027 August 1998 Provides Commitment to Include Requested Changes Into AP600 Design Control Document.Discussion W/Vijuk on 980825 Re Disposition of Ltrs DCP/NRC1074,dtd 971016 & DCP/NRC1324,dtd 980403,formalized ML20237E4421998-08-27027 August 1998 Advises That Info Contained in Ltr DCP/NRC-0985,dtd 970821, Sought to Be Withheld,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended NSD-NRC-98-5777, Provides Revised Response to NRC Ltr Re W Requests for Withholding Info Re AP600 PCS Final Data rept,WCAP-14135 & WCAP-141381998-08-26026 August 1998 Provides Revised Response to NRC Ltr Re W Requests for Withholding Info Re AP600 PCS Final Data rept,WCAP-14135 & WCAP-14138 NSD-NRC-98-5776, Forwards Proprietary Revised Response to Ref NRC Ltr Re W Requests for Withholding Info Re AP600 Design Certification Test Program,Notrump Computer Code,Wcobra/Trac Computer Code & Loftran Computer Code.Proprietary Info Withheld1998-08-26026 August 1998 Forwards Proprietary Revised Response to Ref NRC Ltr Re W Requests for Withholding Info Re AP600 Design Certification Test Program,Notrump Computer Code,Wcobra/Trac Computer Code & Loftran Computer Code.Proprietary Info Withheld ML20237E0731998-08-26026 August 1998 Advises That Info in WCAP-14812,revs 1 & 2, Accident Spec & Phenomena Evaluation for AP600 PCS, Will Be Withheld from Public Disclosure ML20238F8031998-08-26026 August 1998 Requests That Proprietary W Revised Response to NRC Ltrs Re Requests for Withholding Info,Be Withheld from Public Disclosure IAW 10CFR2.790 NSD-NRC-98-5774, Informs That W Faxed Last Response Re Afser Open Item 1.1-1 to NRC on 980821.Last of Attachments Supporting Several of Responses Faxed to NRC Over Past Several Days Were Express Mailed to NRC on 980821.Responses Close Subject Open It1998-08-24024 August 1998 Informs That W Faxed Last Response Re Afser Open Item 1.1-1 to NRC on 980821.Last of Attachments Supporting Several of Responses Faxed to NRC Over Past Several Days Were Express Mailed to NRC on 980821.Responses Close Subject Open Item NSD-NRC-98-5773, Responds to Questions Raised in NRC 971022 & s Re Proprietary Info Contained in 970930 Summary of Meeting Held on 970804-15 Concerning Structural Design of AP600.Figure 12-24 of WCAP-14407 Still Considered Proprietary by W1998-08-21021 August 1998 Responds to Questions Raised in NRC 971022 & s Re Proprietary Info Contained in 970930 Summary of Meeting Held on 970804-15 Concerning Structural Design of AP600.Figure 12-24 of WCAP-14407 Still Considered Proprietary by W ML20237E7991998-08-21021 August 1998 Forwards non-proprietary Results of AP600 Design Assurance Review (Dar) That Was Commitment in W Response to NRC Insp Rept 99900404/97-02.Info Should Assist in Closing Nonconformances & Unresolved Item Identified in Insp Rept NSD-NRC-98-5771, Forwards non-proprietary Rev 2 to WCAP-14138, Final Data Rept for PCS Large-Scale Tests,Phase 2 & Phase 3. Submittal Satisfies Verbal Commitment to Revise non-proprietary Version of PCS Final Data Rept Made by W1998-08-21021 August 1998 Forwards non-proprietary Rev 2 to WCAP-14138, Final Data Rept for PCS Large-Scale Tests,Phase 2 & Phase 3. Submittal Satisfies Verbal Commitment to Revise non-proprietary Version of PCS Final Data Rept Made by W NSD-NRC-98-5769, Responds to NRC Ref Ltrs Re W Requests for Withholding Info. Info Provided as Proprietary in Ref 1 Has Either Been Moved from Ssar to Ref 3,which Includes non-proprietary Version of Rept or Made non-proprietary in Current Version of1998-08-21021 August 1998 Responds to NRC Ref Ltrs Re W Requests for Withholding Info. Info Provided as Proprietary in Ref 1 Has Either Been Moved from Ssar to Ref 3,which Includes non-proprietary Version of Rept or Made non-proprietary in Current Version of Ssar NSD-NRC-98-5772, Forwards non-proprietary & Proprietary Info in Response to NRC Ltrs Re W Requests for Withholding Info.Separate Ltr & Affidavit Justifying Proprietary Nature of Info,Encl. Proprietary Info Withheld,Per 10CFR2.7901998-08-21021 August 1998 Forwards non-proprietary & Proprietary Info in Response to NRC Ltrs Re W Requests for Withholding Info.Separate Ltr & Affidavit Justifying Proprietary Nature of Info,Encl. Proprietary Info Withheld,Per 10CFR2.790 1999-09-29
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20216J0681999-09-29029 September 1999 Forwards Rev 3 of AP600 Design Control Document, Incorporating Documentation Changes Resulting from Final Review Performed to Check Consistency of Implementation of Approved Design Change Proposals.With Summary of Changes NSD-NRC-99-5827, Forwards Rev 2 to AP600 Design Control Document.Attachment 1 Provides Summary of Changes Made as Part of Mar 1999 Rev to AP600 Design Control Document1999-03-31031 March 1999 Forwards Rev 2 to AP600 Design Control Document.Attachment 1 Provides Summary of Changes Made as Part of Mar 1999 Rev to AP600 Design Control Document ML20205D3051999-03-25025 March 1999 Requests Amend to 920626 Application for Design Certification of AP600,including AP600 Ssar & AP600 Dcd,To Reflect Sale of CBS Commercial Nuclear Business to W ML20203C5481999-02-10010 February 1999 Forwards Rev 1 to AP600 Design Control Document (DCD) for Docket File.Dcd Provides Reference Basis for AP600 Design Certification ML20197G3501998-11-30030 November 1998 Forwards AP600 Design Control Document, Vols 1-12 for Docket File.Submittal Closes Confirmatory Items 1.5-1 & 1.5-2 from Sept 1998 Final SER Re Certification of AP600 Std Design NSD-NRC-98-5806, Forwards non-proprietary Rev 1 to WCAP-14253 & Proprietary Rev 1 to WCAP-14252, AP600 Low-Pressure Integral Sys Test at or State Univ Final Data Rept. Proprietary Rept Includes Vols 1-4.Proprietary Info Withheld,Per 10CFR2.7901998-11-0909 November 1998 Forwards non-proprietary Rev 1 to WCAP-14253 & Proprietary Rev 1 to WCAP-14252, AP600 Low-Pressure Integral Sys Test at or State Univ Final Data Rept. Proprietary Rept Includes Vols 1-4.Proprietary Info Withheld,Per 10CFR2.790 ML20195E9331998-11-0909 November 1998 Requests That Rev 1 to WCAP-14252, AP600 Low-Pressure Integral Sys Test at or State Univ Final Data Rept, Vols I- Iv,Be Withheld (Ref 10CFR2.790) NSD-NRC-98-5795, Informs That Figures from Rev 0 & Rev 3 of PRA Which Indicate Location of H Igniters Should Be Considered Proprietary.Nonproprietary Versions of AP600 General Arrangement Drawings Were Provided in Rev 7 of Ssar1998-10-12012 October 1998 Informs That Figures from Rev 0 & Rev 3 of PRA Which Indicate Location of H Igniters Should Be Considered Proprietary.Nonproprietary Versions of AP600 General Arrangement Drawings Were Provided in Rev 7 of Ssar NSD-NRC-98-5788, Forwards Formal Transmittal of Correspondence Previously Sent Informally Over Period of 980702-0826.Index of Encl Matl Provided1998-09-15015 September 1998 Forwards Formal Transmittal of Correspondence Previously Sent Informally Over Period of 980702-0826.Index of Encl Matl Provided NSD-NRC-98-5781, Informs That W Determined That AP600 FSER Contains No Proprietary Info1998-09-0101 September 1998 Informs That W Determined That AP600 FSER Contains No Proprietary Info NSD-NRC-98-5782, Forwards Corrected Pages 4-28 Through 4-32 to Be Inserted in Rev 2 to non-proprietary WCAP-14953, AP600 Pxs Scaling & Pirt Closure Rept. Pages Were Originally Submitted W/Incorrect Header Which Stated 'W Proprietary Class 2.'1998-08-28028 August 1998 Forwards Corrected Pages 4-28 Through 4-32 to Be Inserted in Rev 2 to non-proprietary WCAP-14953, AP600 Pxs Scaling & Pirt Closure Rept. Pages Were Originally Submitted W/Incorrect Header Which Stated 'W Proprietary Class 2.' NSD-NRC-98-5783, Forwards non-proprietary Rev 2 to WCAP-14989, Accident Specification & Phenomena Evaluation for AP600 Passive Containment Cooling Sys1998-08-28028 August 1998 Forwards non-proprietary Rev 2 to WCAP-14989, Accident Specification & Phenomena Evaluation for AP600 Passive Containment Cooling Sys NSD-NRC-98-5778, Provides Commitment to Include Requested Changes Into AP600 Design Control Document.Discussion W/Vijuk on 980825 Re Disposition of Ltrs DCP/NRC1074,dtd 971016 & DCP/NRC1324,dtd 980403,formalized1998-08-27027 August 1998 Provides Commitment to Include Requested Changes Into AP600 Design Control Document.Discussion W/Vijuk on 980825 Re Disposition of Ltrs DCP/NRC1074,dtd 971016 & DCP/NRC1324,dtd 980403,formalized ML20238F8031998-08-26026 August 1998 Requests That Proprietary W Revised Response to NRC Ltrs Re Requests for Withholding Info,Be Withheld from Public Disclosure IAW 10CFR2.790 NSD-NRC-98-5776, Forwards Proprietary Revised Response to Ref NRC Ltr Re W Requests for Withholding Info Re AP600 Design Certification Test Program,Notrump Computer Code,Wcobra/Trac Computer Code & Loftran Computer Code.Proprietary Info Withheld1998-08-26026 August 1998 Forwards Proprietary Revised Response to Ref NRC Ltr Re W Requests for Withholding Info Re AP600 Design Certification Test Program,Notrump Computer Code,Wcobra/Trac Computer Code & Loftran Computer Code.Proprietary Info Withheld NSD-NRC-98-5777, Provides Revised Response to NRC Ltr Re W Requests for Withholding Info Re AP600 PCS Final Data rept,WCAP-14135 & WCAP-141381998-08-26026 August 1998 Provides Revised Response to NRC Ltr Re W Requests for Withholding Info Re AP600 PCS Final Data rept,WCAP-14135 & WCAP-14138 NSD-NRC-98-5774, Informs That W Faxed Last Response Re Afser Open Item 1.1-1 to NRC on 980821.Last of Attachments Supporting Several of Responses Faxed to NRC Over Past Several Days Were Express Mailed to NRC on 980821.Responses Close Subject Open It1998-08-24024 August 1998 Informs That W Faxed Last Response Re Afser Open Item 1.1-1 to NRC on 980821.Last of Attachments Supporting Several of Responses Faxed to NRC Over Past Several Days Were Express Mailed to NRC on 980821.Responses Close Subject Open Item ML20237E7991998-08-21021 August 1998 Forwards non-proprietary Results of AP600 Design Assurance Review (Dar) That Was Commitment in W Response to NRC Insp Rept 99900404/97-02.Info Should Assist in Closing Nonconformances & Unresolved Item Identified in Insp Rept ML20237D3161998-08-21021 August 1998 Requests That W Response to NRC Ltrs Re Requests for Withholding Info Be Withheld from Public Disclosure,Per 10CFR2.790 NSD-NRC-98-5773, Responds to Questions Raised in NRC 971022 & s Re Proprietary Info Contained in 970930 Summary of Meeting Held on 970804-15 Concerning Structural Design of AP600.Figure 12-24 of WCAP-14407 Still Considered Proprietary by W1998-08-21021 August 1998 Responds to Questions Raised in NRC 971022 & s Re Proprietary Info Contained in 970930 Summary of Meeting Held on 970804-15 Concerning Structural Design of AP600.Figure 12-24 of WCAP-14407 Still Considered Proprietary by W NSD-NRC-97-5370, Transmits Results of AP600 Foake Design Assurance Review as Requested in NRC .Info Is Being Provided to Close Unresolved Item Identified in Insp Rept 99900404/97-011998-08-21021 August 1998 Transmits Results of AP600 Foake Design Assurance Review as Requested in NRC .Info Is Being Provided to Close Unresolved Item Identified in Insp Rept 99900404/97-01 NSD-NRC-98-5763, Responds to NRC Ltrs Re W Claim for Treatment of Proprietary Info Submitted in .As Discussed W/Nrc on 980821, Info Contained in W Is self-critical Analysis of W QA Program & Therefore Falls Under Items of Affidavit1998-08-21021 August 1998 Responds to NRC Ltrs Re W Claim for Treatment of Proprietary Info Submitted in .As Discussed W/Nrc on 980821, Info Contained in W Is self-critical Analysis of W QA Program & Therefore Falls Under Items of Affidavit NSD-NRC-98-5772, Forwards non-proprietary & Proprietary Info in Response to NRC Ltrs Re W Requests for Withholding Info.Separate Ltr & Affidavit Justifying Proprietary Nature of Info,Encl. Proprietary Info Withheld,Per 10CFR2.7901998-08-21021 August 1998 Forwards non-proprietary & Proprietary Info in Response to NRC Ltrs Re W Requests for Withholding Info.Separate Ltr & Affidavit Justifying Proprietary Nature of Info,Encl. Proprietary Info Withheld,Per 10CFR2.790 NSD-NRC-98-5769, Responds to NRC Ref Ltrs Re W Requests for Withholding Info. Info Provided as Proprietary in Ref 1 Has Either Been Moved from Ssar to Ref 3,which Includes non-proprietary Version of Rept or Made non-proprietary in Current Version of1998-08-21021 August 1998 Responds to NRC Ref Ltrs Re W Requests for Withholding Info. Info Provided as Proprietary in Ref 1 Has Either Been Moved from Ssar to Ref 3,which Includes non-proprietary Version of Rept or Made non-proprietary in Current Version of Ssar NSD-NRC-98-5771, Forwards non-proprietary Rev 2 to WCAP-14138, Final Data Rept for PCS Large-Scale Tests,Phase 2 & Phase 3. Submittal Satisfies Verbal Commitment to Revise non-proprietary Version of PCS Final Data Rept Made by W1998-08-21021 August 1998 Forwards non-proprietary Rev 2 to WCAP-14138, Final Data Rept for PCS Large-Scale Tests,Phase 2 & Phase 3. Submittal Satisfies Verbal Commitment to Revise non-proprietary Version of PCS Final Data Rept Made by W ML20237D3551998-08-20020 August 1998 Requests That Proprietary Info Re W Response to NRC Ltrs Re Requests for Withholding Info Concerning AP600 Pxs Scaling & Pirt Closure Rept, WCAP-14727 Be Withheld from Public Disclosure IAW 10CFR2.790 NSD-NRC-98-5762, Forwards Proprietary Change Pages for Chapters 7 & 8,for Inclusion as Rev 2 of TR WCAP-14727,in Response to NRC Ltr Dtd 980714.Non-proprietary Rev 2 to TR WCAP-14953 Re AP600 Scaling & Pirt Closure Encl.Proprietary Info Withheld1998-08-20020 August 1998 Forwards Proprietary Change Pages for Chapters 7 & 8,for Inclusion as Rev 2 of TR WCAP-14727,in Response to NRC Ltr Dtd 980714.Non-proprietary Rev 2 to TR WCAP-14953 Re AP600 Scaling & Pirt Closure Encl.Proprietary Info Withheld NSD-NRC-98-5764, Responds to NRC Ltrs Re Requests for Withholding Info from Public Disclosure for W AP600 Design Ltr of 951117,dtd 960229.W Considers Matl Proprietary Since Matl Discusses Approach Used by W to Develop Analysis Models of Cctf Test1998-08-20020 August 1998 Responds to NRC Ltrs Re Requests for Withholding Info from Public Disclosure for W AP600 Design Ltr of 951117,dtd 960229.W Considers Matl Proprietary Since Matl Discusses Approach Used by W to Develop Analysis Models of Cctf Test NSD-NRC-98-5768, Responds to NRC Ref Ltrs Re W Requests for Withholding Info. Specific Info Considered non-proprietary or Proprietary Discussed1998-08-20020 August 1998 Responds to NRC Ref Ltrs Re W Requests for Withholding Info. Specific Info Considered non-proprietary or Proprietary Discussed NSD-NRC-98-5766, Provides Summary of 980813 Telcon W/Nrc Re W Explanation of Rationale Which Was Used to Determine What Info Was Considered to Be Proprietary in TR WCAP-148121998-08-20020 August 1998 Provides Summary of 980813 Telcon W/Nrc Re W Explanation of Rationale Which Was Used to Determine What Info Was Considered to Be Proprietary in TR WCAP-14812 NSD-NRC-98-5770, Responds to NRC Ltrs Re W Requests for Withholding Info.W Withdraws AP600 Rept Entitled, Wcobra/Trac Core Makeup Tank Preliminary Validation Rept, Since Rept Was Not Required by NRC to Make Safety Determination of AP6001998-08-20020 August 1998 Responds to NRC Ltrs Re W Requests for Withholding Info.W Withdraws AP600 Rept Entitled, Wcobra/Trac Core Makeup Tank Preliminary Validation Rept, Since Rept Was Not Required by NRC to Make Safety Determination of AP600 NSD-NRC-98-5760, Forwards Rev 25 to GW-GL-021, AP600 Ssar, Vols 1-11. Revised Tables of Contents,Change Page Instructions,List of Effective Pages,Document Cover Sheet & Change Roadmap Outlining Changes in Each Section Also Encl1998-08-19019 August 1998 Forwards Rev 25 to GW-GL-021, AP600 Ssar, Vols 1-11. Revised Tables of Contents,Change Page Instructions,List of Effective Pages,Document Cover Sheet & Change Roadmap Outlining Changes in Each Section Also Encl NSD-NRC-98-5761, Provides Written Confirmation That Identified Figure Is Not Considered Proprietary by W.Refs 1-5,discussed1998-08-19019 August 1998 Provides Written Confirmation That Identified Figure Is Not Considered Proprietary by W.Refs 1-5,discussed ML20237D2681998-08-18018 August 1998 Requests That Proprietary Informal Correspondence Be Withheld from Public Disclosure,Per 10CFR2.790 NSD-NRC-97-5046, Submits Rev 1 of W Ltr Originally Submitted 970917,which Transmitted Proprietary & non-proprietary Informal Correspondence.Rev Includes Notarized Affidavit as Part of Application for Withholding Info.Proprietary Info Withheld1998-08-18018 August 1998 Submits Rev 1 of W Ltr Originally Submitted 970917,which Transmitted Proprietary & non-proprietary Informal Correspondence.Rev Includes Notarized Affidavit as Part of Application for Withholding Info.Proprietary Info Withheld NSD-NRC-98-5759, Submits Response to NRC Ltrs Re Request for Withholding Info.Figure 8-19 Will No Longer Be Considered Proprietary by W1998-08-17017 August 1998 Submits Response to NRC Ltrs Re Request for Withholding Info.Figure 8-19 Will No Longer Be Considered Proprietary by W NSD-NRC-98-5756, Responds to NRC 980714 & 21 Ltrs Re Request for Withholding Proprietary Info That Was Not Clearly Identified Other than Being Marked W Proprietary Class 21998-08-14014 August 1998 Responds to NRC 980714 & 21 Ltrs Re Request for Withholding Proprietary Info That Was Not Clearly Identified Other than Being Marked W Proprietary Class 2 NSD-NRC-98-5757, Responds to Ref NRC Ltrs Re Request for Withholding Proprietary Info Re W AP600 Ltr.Per 980708 Telcon,W Has Reviewed TRs WCAP-13288 & WCAP-13289 & Considers None of Info to Be Proprietary1998-08-14014 August 1998 Responds to Ref NRC Ltrs Re Request for Withholding Proprietary Info Re W AP600 Ltr.Per 980708 Telcon,W Has Reviewed TRs WCAP-13288 & WCAP-13289 & Considers None of Info to Be Proprietary ML20151Z0971998-08-13013 August 1998 Requests That Proprietary Rev 5 to WCAP-14807, Notrump Final Validation Rept, Be Withheld from Public Disclosure, Per 10CFR2.790 NSD-NRC-98-5754, Forwards non-proprietary Versions of Revs 3-5 to WCAP-14808 & Proprietary Version of Rev 5 to WCAP-14807, Notrump Final Validation Rept for AP600, in Form of Replacement Pages. Proprietary Encl Withheld1998-08-13013 August 1998 Forwards non-proprietary Versions of Revs 3-5 to WCAP-14808 & Proprietary Version of Rev 5 to WCAP-14807, Notrump Final Validation Rept for AP600, in Form of Replacement Pages. Proprietary Encl Withheld NSD-NRC-98-5749, Forwards Rev 13 to AP600 PRA for Simplified Passive Advanced LWR Plant Program. Rev Represents Final Version of AP600 Pra.All NRC Comments Related to Rev 12 of AP600 PRA Have Been Resolved1998-08-13013 August 1998 Forwards Rev 13 to AP600 PRA for Simplified Passive Advanced LWR Plant Program. Rev Represents Final Version of AP600 Pra.All NRC Comments Related to Rev 12 of AP600 PRA Have Been Resolved NSD-NRC-98-5753, Responds to Ref NRC Ltrs & W Ltr Re Request for Withholding Proprietary Info Re AP600 Design Ltrs1998-08-13013 August 1998 Responds to Ref NRC Ltrs & W Ltr Re Request for Withholding Proprietary Info Re AP600 Design Ltrs NSD-NRC-98-5752, Responds to Open Item 1.1-2 Contained in 980501 Advance Final SER for AP600 Requesting Update of Comparison of AP600 to NRC Reviewed Version of Alwr Util Requirements Document. Changes Resulting from NRC Comments Re Plant Design,List1998-08-13013 August 1998 Responds to Open Item 1.1-2 Contained in 980501 Advance Final SER for AP600 Requesting Update of Comparison of AP600 to NRC Reviewed Version of Alwr Util Requirements Document. Changes Resulting from NRC Comments Re Plant Design,Listed NSD-NRC-98-5755, Forwards Rev 7 to Simplified Passive Advance Light Water Reactor Plant Program AP600 Tier 1 Matl, Incorporating Comments Received from NRC Technical Staff,As of 980812.Encl Closes Open Item 14.3-1 from Advanced Final SER1998-08-13013 August 1998 Forwards Rev 7 to Simplified Passive Advance Light Water Reactor Plant Program AP600 Tier 1 Matl, Incorporating Comments Received from NRC Technical Staff,As of 980812.Encl Closes Open Item 14.3-1 from Advanced Final SER ML20153D9491998-08-12012 August 1998 Submits Response to NRC Ltrs Re Requests for Withholding Info.Info Does Not Have Commercial Value & No Longer Considered to Be Proprietary by W NSD-NRC-98-5751, Submits Response to NRC Ltrs Re Requests for Withholding Info.Info Does Not Have Commercial Value & Is No Longer Considered Proprietary by W1998-08-12012 August 1998 Submits Response to NRC Ltrs Re Requests for Withholding Info.Info Does Not Have Commercial Value & Is No Longer Considered Proprietary by W NSD-NRC-98-5748, Forwards Rev 24 of AP600 Ssar.Revised Tables of Contents, Change Page Instructions,List of Effective Pages,Document Cover Sheet & Change Roadmap Outlining Changes in Each Section Also Encl.Rev Submitted Under Encl Oath1998-08-0707 August 1998 Forwards Rev 24 of AP600 Ssar.Revised Tables of Contents, Change Page Instructions,List of Effective Pages,Document Cover Sheet & Change Roadmap Outlining Changes in Each Section Also Encl.Rev Submitted Under Encl Oath NSD-NRC-98-5743, Forwards Table Which Compares Combined License (COL) Info Items Identified in AP600 Design Certification Application W/Col Action Items Identified in AP600 Advance Final SER Provided to W by NRC on 9805061998-07-31031 July 1998 Forwards Table Which Compares Combined License (COL) Info Items Identified in AP600 Design Certification Application W/Col Action Items Identified in AP600 Advance Final SER Provided to W by NRC on 980506 NSD-NRC-98-5733, Forwards Rev 6 to GW-GL-030, Simplified Passive Advance LWR Plant Program,AP600 Tier 1 Matl, Which Incorporates Comments Received from NRC Technical Staff as of 9807221998-07-27027 July 1998 Forwards Rev 6 to GW-GL-030, Simplified Passive Advance LWR Plant Program,AP600 Tier 1 Matl, Which Incorporates Comments Received from NRC Technical Staff as of 980722 NSD-NRC-98-5742, Forwards Rev 12 to AP600 PRA Rept. All NRC Open Items Related to AP600 PRA Have Been Resolved1998-07-24024 July 1998 Forwards Rev 12 to AP600 PRA Rept. All NRC Open Items Related to AP600 PRA Have Been Resolved 1999-09-29
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I Westinghouse Energy Systems Ba 355 Pittsburgh Pennsylvania 15230-0355 ,
Electric Corporation NSD-NRC-97-4972 l DCP/NRC0732 l Docket No.: STN-52-003 ;
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February 6,1997 .
Document Control Desk ;
U. S. Nuclear Regulatory Commission i Washington, DC 20555 TO: T.R. QUAY SUB.IECT: RESPONSE TO RAls 630.11 THROUGH 630.14
REFERENCE:
LETTER FROM NRC TO WESTINGHOUSE (HUFFMAN TO LIPARULO),
" REQUEST FOR ADDITIONAL INFORMATION ON WESTINGHOUSE AP600 TECHNICAL SPECIFICATIONS OPTIMIZATION METHODOLOGY", DATED DECEMBER 12, 1996.
Enclosed for NRC review are the Westinghouse responses to the following Technical Specification RAls, provided by the above Reference.
i 630.11 Completion Time Anchor Point 630.12 Surveillance Frequency Baseline 630.13 Request for Response to RAI 630.10 630.14 Differences Between the Proposed Tech Specs Approach and Tech Specs Rev. 2 This completes Westinghouse activity for Open Item Tracking System items 4224 through 4227, a report for which is attached. Please advise as to the NRC status for these items. If you have any questions regarding this transmittal, please contact Robin K. Nydes (412) 374-4125.
Brian A. McIntyre, Manager Advanced Plant Safety and Licensing l
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cc: W. Huffman, NRC (w/ enclosure / attachment)
!- A. Chu, NRC (w/ enclosure / attachment) ynsh 9702190016 970206 PDR ADOCK 05200003i A -. PDR g l .,
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ATTACHMENT TO WESTINGHOUSE l LETTER NSD-NRC-97-4972 l
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AP600 Open Item Tracking System Datbase: Exec:tiva Summary Selecties: [ item no] between 4224 And 4227 And [aps! coord] = 'Nydes' Sorted by item # ,
item DSER Section/ Titic/ Description Resp (W) NRC No. Branch Question Type Detail Status Engineer Status Status Letter No. / Date -
4224 NRR/TSB 16 i RAl-OI TechSpec/Suggs Closed Action W NTD-NRC-97-4972 2/12/97 l Respond to RAI 630.1I rec'd 12/12/96 , l in progress to mgt review 2/5 OTD Feb 6 by NTD-NRC-97-4972. rkn 4225 NRR/TSB 16.1 RAI-OI TechSpec/Suggs Closed Action W 2/12/97 l Respond to RAI 630.12 rec *d 12/12/97. l in progress to mgt review 2/5 OTD Feb 6 by NTD-NRC-97-4972. rkn 4226 NRR/TSB 16.1 RAl-OI TechSpec/Suggs Closed Action W 2/12/97 l Respond to RAI 630.I3 rec'd 12/12/96. l in progress (closes with providing response to RAI 630.10 and final PRA report) to mgt review 2/3 OTD Feb 6 by NTD-NRC-97-4972. rkn RAI4M TechSpec/Suggs Closed Action W 2/12M7 4227 NRR/TSB 16.1 l Respond to RAI 630.14 rec'd 12/12/96. l in progress to mgt reticw 2/5 OTD Feb 6 by NTD-NRC-97-4972. rkn t
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i ENCLOSURE TO WESTINGHOUSE i LETTER NSD-NRC-97-4972 I
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NRC REQUEST FOR ADDITIONAL INFORMATION j ...
I Question 630.11 A detailed discussion needs to be proposed about how from a 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> " anchor point" for the Completion Time logic of Figure 1, the four other possible outcomes were selected. Hat discussion should address specifically how repair times were arrived at, how uncertainties in such judgements were accounted for, how and why thermal-hydraulic criteria varied from the precedents of the STS, specifically how PRA was used to justify the selection of longer completion times and where that was done, and finally a discussion of the differences between the
" conservative" and " realistic" analysis referred to in the Notes to Figure 1.
Response
Figure 1 Discussion - Application of STS Precedents to AP600 Logic Re AP600 Technical Specifications include several LCOs for which'no STS examples exist. In order to specify Completion Times for these AP600 unique LCOs, a simple logic was developed based on review of STS (NUREG-1431) Completion Times. In general, the logic presented in Figure 1 (Reference 630.11-1) is consistent with the Completion Times specified in the STS. Inconsistencies occur where the STS specifies different times for basically the same conditions or where the STS times fall between the smaller set of standard times selected for the AP600 criteria. Each of the Figure 1 outcomes (logic tree branches) is discussed below.
Branch 1 - 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> (7 days) ne branch 1, 7-day, Completion Time is reached if the equipment which remains OPERABLE can mitigate all DBAs even with a single failure. STS examples fitting this situation are Conditions A and B of LCO 3.6.6B (inoperable spray train and inoperable cooling train).
Additionally, branch I applies to a parameter deviation (e.g., temperature,' pressure, volume, concentration, etc.)
in one component which would not prevent accident mitigation of all DBAs even with a single failure. This was applied in cases where the parameter deviation could be expected to be discovered while the out of limit deviation was small.
Branch 2 - 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ne branch 2, 72-hour, Completion Time applies only to parameter deviations in all components such as boron concentration out of limit in both accumulators. For branch 2 cases, all DBAs can be mitigated, assuming a conservative analysis and a single failure. His portion of the logic is based on LCO 3.5.1 Condition A, boron concentration out of limit in one accumulator, for which the STS Bases discussion supports mitigation of all DBAs assuming a conservative analysis and a single failure.
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i Branch 3 - 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> l 1
ne branch 3, 72-hour, Completion Time is based on STS examples of two 100% train ECCS systems (i.e., LCO l 3.5.2, Condition A, LCO 3.6.6.A, Condition A, and LCO 3.8.1, Condition B). For a case of one inoperable ECCS '
train, the figure logic requires the remammg train to be capable of mitigating all DBAs, based on a conservative analysis but without a single failure.
Branch 4 - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I ne branch 4, 24-hour, Completion Time applies to conditions in which the remaining equipment can mitigate all DBAs based on a realistic analysis with a single failure. An STS example which is consistent with these conditions is LCO 3.6.2, Condition C (inoperable air lock (s)). Required Action C.1 specifies that compliance with the overall containment leakage limit be verified immediately. With the overall . containment leakage limit met, the containment will perform as assumed in the accident analysis. Air locks are not subject to single failures.
He branch 4, 24-hour Completion Time logic was applied to only a few STS Conditions for A.P600, including: one 1
inoperable accumulator, containment pressure, and contamment temperature. ,
Branch 5 - 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> ne branch 5, 8-hour, Completion Time applies to conditions in which the remaining equipment can mitigate all DBAs based on a realistic analysis but without a single failure.
There may not be any STS examples fitting the branch 5 logic, however, the branch was included to provide for the possibility that some AP600 Conditions would satisfy the logic.
Branch 6 - I hour In the STS, times ranging from "Immediately" to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are applied to conditions in which the inoperability represents a loss of safety function. A standard Completion Time of I hour was selected for the AP600 standard Completion Time to provide a predictable amount of time in which an optimized set of shutdown preparations may be made.
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Repair Times i
Following application of the Completion Time Criteria, utility reviewers were provided the opportunity to comment, j in the event their experience indicated that restoration could not normally be completed within the specified i Completion Time his utility input was taken into consideration when the final Completion Time determinations were made. Here ue no known cases where the logic Completion Time was extended based on the need for a ,
longer repair time. I i
Use of PRA l I
The use of PRA to justify Smveillance Fre vencies and Completion Times is addressed in the response to RAI 630.10 (Reference 630.11-2).
Differences Between the " Conservative" and " Realistic" Analysis As used in the Figure, conservative analysis refers to the analysis performed consistent with the worst cass ,
assumptions required by SSAR Chapter 15 methodologies. He realistic analyses permit use of nominal conditions such as volume, level, flow, temperature, pressure, response time, etc., rather than worst case assumptions.
In some cases, experienced analysts familiar with the AP600 conservative analysis results have evaluated the significance of the potentially out of limit parameters and the margin available due to conservative assumptions and determined if the accident would be mitigated using the realistic conditions. These conclusions are summarized, where applicable, in the AP600 Bases. An example of an AP600 Bases summary is provided for LCO 3.5.1, Accumulators, Action B.1 (inoprable accumulator for a reason other than boron concentration, nitrogen pressure, or volume).
Reference 630.11-1 Westinghouse letter, NSD-NRC-96-4699, dated May 3,1996, ' Westinghouse AP600 Technical Specifications Approach."
630.11-2 Westinghouse letter, NSD-NRC-97-4939, dated January 14,1997, " Westinghouse Response to RAI 630.10.*
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l Question 630.12 A detailed discussion needs to be provided about how 31 days was established as the " baseline" for surveillance frequency and what constitutes a " baseline chance". The discussion should providejustification for the other three possible outcomes on the upper branch of Figure 2, as well as an answer to the question in our [[letter::NSD-NRC-96-4739, Forwards Draft Mark Up of Chapter 54 of AP600 Probabilistic Risk Assessment (PRA) Covering Low Power & Shutdown PRA Assessment.Pra Section Revised to Incorporate Commitments Westinghouse Made in Response to RAIs|June 6,1996 letter]] concerning the appropriateness of only having a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frequency outcome for the lower branch of Figure 2.
June 6 question:
"The staff noted in your optimization methodology that the shortest surveillance frequency requirement would be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, while the STS includes a 12-hour frequency. It is not clear that the AP600 instrumentation and control system warrants the longer surveillance interval. You should consider whether a loss of self-diagnosis capability and failure alarm functions might be sufficient cause for a 12-hour surveillance frequency"
Response
He AP600 Technical Specifications include several LCOs for which no STS examples exist. In order to specify ,
surveillance frequencies for these AP600 unique LCOs, a simple logic was developed based on review of all of the STS (NUREG-1431) times. To the extent possible, the AP600 logic presented in Figure 2 (Reference 630.12-1) was developed to be consistent with the surveillance frequencies specified in the STS. Inconsistencies occur where the STS specifies different times for basically the same surveillances or where the STS times fall between the smaller set of standard times selected for the AP600 criteria. He AP600 logic is considered to be justified by its basis on STS Surveillance Frequency precedents as presented below.
Discussion - AP600 Logie Based on STS Precedents The Surveillance Frequency Criteria discussion attached to Reference 630.12-1 used an evaluation of the 31-day STS accumulator boron concentration surveillance as an example of the elements considered in the application of the criteria. He AP600 Surveillance Frequency Criteria is more thoroughly explained in the following discussion of STS examples of boron / solution concentration surveillances.
STS Examples:
SR 3.5.1.4 Accumulator boron 31 days &
Within 6 Hours after volume increase of []%
SR 3.5.4.3 RWST boron 7 days SR 3.5.6.3 BIT boron 7 days SR 3.6.6E.3 Casing cooling tank boron 7 days SR 3.6.7.3 Spray additive tank solution 184 days SR 3.7.16.1 Spent fuel pool borun 7 days 630.12 1
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The criteria was developed considering that the differences in the STS frequencies for these similar surveillances should relate to the likelihood that the concentration may change and the ability of the operator to detect conditions associated with a concentration change.
Each STS surveillance was evaluated considering:
- 1. The performance location of the surveillance. Surveillances were classified as being performed in the control room or locally.
- 2. If the surveillance is performed locally (not in the control room), the surveillance was classified according to the indirect monitoring available in the control room. If the control room monitor can detect changes in conditions associated with important changes in the primary variable, then the monitor was classified as " effective." If the indirect control room monitor could be slow to detc or unable to detect some types of degradation, the monitor'was classified as "less effective."
- 3. He surveillance was classified according to the likelihood of change in the monitored condition.
(BASELINE DEFINTTION) He likelihood of change is established as either " low" or " baseline" with longer surveillance intervals being assigned to low change likelihood parameters. He STS 31 day accumulator boron concentration surveillance is classified as having a baseline chance of changing ;
rapidly. He accumulator boron concentration was selected as a well understood example, against which other surveillances could be compared as having a similar or lower chance of changing rapidly. .
I By comparison to the accumulator boron concentration, parameters which have a much lower chance of changing rapidly, such as Spray Additive Tank concentration, would be classified r.s having a " low" likelihood of changing rapidly. l 1
Figure 2 Discussion - Application of STS Precedents to AP600 Logic Branch I Once per fuel cycle local Surveillance Effective Control Room Monitor l Low Likelihood of Change ne STS Spray Additive Tank solution surveillance (SR 3.6.7.3) frequency of 184 days is considered to be l consistent with the ability to detect (in the control room) changes associated with dilution and the very low likelihood !
that leakage would occur. For the AP600 logic, it was felt that under these conditions where there were no likely dilution (change) mechanisms, that surveillance each refueling would be adequate.
630.12 2 W Westingh0use
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Branch I (continued) l An AP600 surveillance which meets this criteria is the verification that the pH Adjustment baskets are filled with j 145 ft$ of trisodium phosphate (TSP) each 24 months (SR 3.6.9.1). The volume of TSP must be verified locally, !
in containment. Effective Control Room monitors are available for a variety of containment conditions as well i as RCS leakage which might affect volume. (The TSP baskets are located slightly above the floor such that minor j leaks will not affect the TSP volume.) Additionally, since access to containment is limited during power operations, there is a v-ry low likelihood that the TSP volume will change.
Branch 2 31 days ,
1 local Serveillance l Effective Control Room Monitor l Baseline Likelihood of Change !
For the Accumulators the normxily available instrumentation can effectively detect changes associated with dilution. i Since accumulator boron concentration has been known to have been diluted by leakage, the change potential ip )
considered to be a " baseline" likelihood of change. The 31 day STS frequency is consistent with the effective control room means of dilution detection.
For AP600 several electrical system surveillances, including category A battery cell parameters, inverters, and distribution systems meet this criteria. In each of these cases local surveillances are required; however, effective control room monitors, such as for voltage, provide an excellent indication of the equipment status. These parameters have been known to have exceeded limits and are, therefore, categorized as having a baseline likelitmod of change.
Branch 3 31 days local Surveillance 1.ess Effective Control Room Monitor Low Ilkelihood of Change Local surveillances of parameters with a low likelihood of change, but with indirect control room monitoring of a less effective variable receive a 31-day frequency with the AP600 logic. Branch 3 is similar to branch I (once per fuel cycle), except that the available indirect variable (s) monitored in the control room are not always as capable of detecting degradation in the primary variable as branch I control room monitors. It is not considered that any STS or AP600 surveillances met this criteria.
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Branch 4 7 days Imal Surveillance less Effective Control Room Monitor l Baseline Likelihood of Change In general, the STS 7-day frequency is associated with solution volumes (RWST, BIT, Spent Fuel Pool) for which available control room monitoring is not especially effective in detecting conditions associated with a concentration change. In these cases the dilution water sources may not be at temperatures significantly different from the volume (temperature monitoring would only be effective in extreme cases of dilution) and level monitoring may not detect small but important changes. Additionally, these volumes are considered to be vulnerable to dilution by leakage.
For AP600 the Core Makeup Tank boron concentration (SR 3.5.2.5) and Refueling boron concentration (SR 3.9.1.1) surveillances met this criteria and are basically the same as the STS examples.
Branch 5 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> j Control Room Monitor i
A frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was selected for AP600 parameters which are measured directly in the control room, even i for parameters which have a base line or low likelihood of change, because the surveillance is easy to perform.
His standard frequency for all control room variables is considered to simplify operations, according to utility input.
Response to June 6 question:
He STS applies the 12-hour frequency to the Channel Check instrumentation surveillance. In the AP600 TS, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been specified for a Channel Check. The reliability ofinstrumentation systems designed and built in the 1970's (or earlier) is considered the source of the 12-hour frequency. Based on engineeringjudgement, the reliability of the AP600 instrumentation is at least twice as good as 1970's technology and warrants a 24-hour frequency for the Channel Check surveillance.
Additionally, utility reviewers have indicated that the control room staff will read the instruments each shift and recognize any inconsistencies, but only having to document the Channel Check surveillances once each 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will provide relief from the administrative burden.
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l Reference 630.12-1 Westinghouse letter, NSD-NRC-%-4699, dated May 3,19%, " Westinghouse AP600 Technical Specifications Approach."
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Question 630.13 The discussion of the sections labeled "Probabilistic Risk Assessment - AP600 Baseline" and "Probabilistic Risk Assessment - AP600 Importance Ranking" can only be fully evaluated by the staff after the submittal of the response to RAI 630.10 (which the first section implies has been made, when in fact, it has not been) and the finalization ,
of the PRA Final Report. Therefore, those submittals need to be made and the response to the RAI should include l not only the original information requested but also, as discussed in our November 20,1996 meeting, a discussion l of how PRA information was used in the TS and on what basis its use was justified. j
Response
See the response to RAI 630.10 in Reference 630.13-1.
Reference:
630.13-1 Westinghouse letter. NSD-NRC-97-4939, dated January 14,1997, " Westinghouse Response to RAI 630.10."
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I Question 630.14 l
here are a number of differences between Table I and the AP600 TS Rev. 2 that need to be explained as does the difference between the MODE 4 time of Table 2 and that of the STS. -
Response
Differences between Reference 630.14-1, Table 1 and the AP600 TS Rev. 2 W letter AP600 System Table 1 Rev. 2 i l
- 1. MODE 5 Containment No Req'mt Closure Capability RCS closed
- 2. MODE 5 PCS No Req'mt 2 Water Flow Paths RCS closed, OPERABLE shutdown
< [100] hrs. ,
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- 3. MODE 5 ADS Stages 1, 2, Stages I, 2, RCS open and 3 open and 3 open Stage 4 OPERABLE i 1
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- 4. MODE 5 ADS Stages 1, 2, Stages 1, 2. ,
RCS open, and 3 open and 3 open l reduced Stage 4 OPERABLE inventory
- 5. MODE 6 ADS Stages 1, 2, Stages 1, 2, internals in and 3 open and 3 open place, cavity Stage 4 OPERABLE not full
- 6. MODE 6 Containment No Reg'mt Closure internals Capability removed, 4 cavity full )
- h. each of the 6 differences listed above, the AP600 Technical Specification, Rev. 2 requirements are mon restrictive and are explained in the Technical Specification Bases. He Rev. 2 requirements followed Reference 630.14-1 by approximately 3 months and represent results of recent analysis of shutdown events.
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NRC REQUEST FOR ADDITIONAL INFORMATION f ~y l
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l For differences #1 and #6 above, containment closure capability was specified for additional Applicability I conditions. In MODE 5 with the pressure boundary closed and in MODE 6 with the reactor internals removed and the cavity full, the time to boiling to is much greater (hours) than for reduced inventory conditions. Originally, it l was considered that the extended time to boiling would allow operation without any requirements for these cases. I Following submittal of Reference 630.14-1, it was decided that containment closure should apply in all of MODES S and 6.
For difference #2 above, OPERABIUTY of 2 Passive Containment Cooling flow paths has been added for MODE 5 with the RCS closed. He AP600 Applicability for Passive Containment Cooling System - Shutdown, LCO 3.6.7 i in Rev. 2 is MODES 5 and 6 with the reactor shut down less than [100 hours). His revised Applicability is l consistent with the availability of the PCS assumed in accident analyses. i For differences #3, #4, and #5 above, OPERABIUTY of Stage 4 flow paths has been added to the LCO applicable in MODE 5 and 6 with the RCS Open. He addition of the Stage 4 flow paths provides vent path redundancy such that a Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be specified in the event one required flow path is closed or inoperable.
Difference between the MODE 4 time of Table 2 and that of the STS. .
He MODE 4 shutdown time for AP600, specified in Table 2 of Reference 630.14-1, is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. He corresponding time specified in the STS is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. He MODE 4 shutdown time for AP600 represents a compromise between the time expected using the passive systems (i.e.,36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />) and the time using the non-Technical Specification active systems (i.e.,12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />). Although only the passive system OPERABIUTY is provided by the Technical Specifications, the active systems will be used when available. He AP600 MODE 4 l shutdown time, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, provides for initiation of plant cooldown using the passive systems and completion of the cooldown using the active systems.
Reference 630.14-1 Westinghouse letter, NSD-NRC-%-4699, dated May 3,1996, " Westinghouse AP600 Technical Specifications Approach." ;
1 630.14 2 W-westinghouse