2013/05/17 Areva EPR DC - Response to U.S. EPR …2013 to provide technically correct and complete...

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ArevaEPRDCPEm Resource

From: WILLIFORD Dennis (AREVA) [[email protected]]Sent: Friday, May 17, 2013 10:00 PMTo: Snyder, AmyCc: Gleaves, Bill; ANDERSON Katherine (EXTERNAL AREVA); DELANO Karen (AREVA);

LEIGHLITER John (AREVA); ROMINE Judy (AREVA); RYAN Tom (AREVA); KOWALSKI David (AREVA); HONMA George (EXTERNAL AREVA); GUCWA Len (EXTERNAL AREVA); VANCE Brian (AREVA)

Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 8

Attachments: RAI 511 Supplement 8 Response US EPR DC.pdf

Amy, AREVA NP provided a schedule for responding to the six questions in RAI No. 511 on October 21, 2011. Supplement 1 response was sent on November 11, 2011 to provide a response to one (Question 06.02.02-124) of the six questions. Supplement 2, Supplement 3 and Supplement 4 responses to RAI No. 511 were sent on December 13, 2011, January 20, 2012, and February 24, 2012, respectively, to provide a revised schedule for the remaining five questions. Supplement 5 response to RAI No. 511 was sent on March 29, 2013 to provide technically correct and complete final responses to Questions 06.02.02-125, 06.02.02-126 and 06.04-11. Supplement 6 response to RAI No. 511 was sent on May 3, 2013 to provide a revised schedule for the remaining two questions. Supplement 7 response to RAI No. 511 was sent on May 10, 2013 to provide a technically correct and complete final response to Question 06.04-10. The attached file, “RAI 511 Supplement 8 Response US EPR DC.pdf,” provides a technically correct and complete final response to Question 06.04-9. NRC staff comments have been considered and incorporated into the final response to this question. Appended to this file are affected pages of the U.S. EPR Final Safety Analysis Report in redline-strikeout format which support the response to RAI 511 Question 06.04-9. The following table indicates the respective pages in the response document, “RAI 511 Supplement 8 Response US EPR DC.pdf,” that contain AREVA NP’s final response to the subject question. Question # Start Page End Page RAI 511 — 06.04-9 2 6 This concludes the formal AREVA NP response to RAI 511, and there are no questions from this RAI for which AREVA NP has not provided responses. Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: RYAN Tom (RS/NB) Sent: Friday, May 10, 2013 9:47 AM To: [email protected]

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Cc: DELANO Karen (RS/NB); LEIGHLITER John (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); WILLS Tiffany (CORP/QP); ANDERSON Katherine (External AREVA NP INC.); LENTZ Tony (External RS/NB); WILLIFORD Dennis (RS/NB)Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 7 Amy, AREVA NP provided a schedule for responding to the six questions in RAI No. 511 on October 21, 2011. Supplement 1 response was sent on November 11, 2011 to provide a response to one (Question 06.02.02-124) of the six questions. Supplement 2, Supplement 3 and Supplement 4 responses to RAI No. 511 were sent on December 13, 2011, January 20, 2012, and February 24, 2012, respectively, to provide a revised schedule for the remaining five questions. Supplement 5 response to RAI No. 511 was sent on March 29, 2013 to provide technically correct and complete final responses to 3 (06.02.02-125, 06.02.02-126 and 06.04-11) of the remaining 5 Questions. Supplement 6 response to RAI No. 511 was sent on May 3, 2013 to provide a revised schedule for the remaining two questions. The attached file, “RAI 511 Supplement 7 Response US EPR DC.pdf,” provides a technically correct and complete final response to Question 06.04-10. Appended to this file are affected pages of the U.S. EPR Final Safety Analysis Report in redline-strikeout format which support the response to RAI 511. The following table indicates the respective pages in the response document, “RAI 511 Supplement 7 Response US EPR DC.pdf,” that contain AREVA NP’s response to the subject question. Question # Start Page End Page RAI 511 — 06.04-10 2 4 The schedule for technically correct and complete response to the remaining question remains unchanged as provided below. Question # Response Date RAI 511 — 06.04-9 May 17, 2013 Sincerely, Tom Ryan for Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Friday, May 03, 2013 4:31 PM To: [email protected] Cc: [email protected]; ANDERSON Katherine (External AREVA NP INC.); DELANO Karen (RS/NB); LEIGHLITER John (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); KOWALSKI David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 6

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Amy, AREVA NP provided a schedule for responding to the six questions in RAI No. 511 on October 21, 2011. Supplement 1 response was sent on November 11, 2011 to provide a response to one (Question 06.02.02-124) of the six questions. Supplement 2, Supplement 3 and Supplement 4 responses to RAI No. 511 were sent on December 13, 2011, January 20, 2012, and February 24, 2012, respectively, to provide a revised schedule for the remaining five questions. Supplement 5 response to RAI No. 511 was sent on March 29, 2013 to provide technically correct and complete final responses to 3 (06.02.02-125, 06.02.02-126 and 06.04-11) of the remaining 5 Questions. NRC staff review comments on advanced responses to Questions 06.04-9 and 06.04-10 were discussed during a telecon on March 14, 2013 and clarified in an e-mail received on March 20, 2013. Additional discussion and clarification occurred during subsequent telecons on April 8, 2013 and April 22, 2013. NRC staff comments will be considered and incorporated into the final responses to these two questions. The schedule for technically correct and complete responses to the remaining two questions has been changed as provided below. Question # Response Date RAI 511 — 06.04-9 May 17, 2013 RAI 511 — 06.04-10 May 17, 2013 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Friday, March 29, 2013 3:23 PM To: [email protected] Cc: [email protected]; DELANO Karen (RS/NB); LEIGHLITER John (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); WILLS Tiffany (CORP/QP); HONMA George (EXT); KOWALSKI David (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 5 Importance: High Amy, AREVA NP provided a schedule for responding to the six questions in RAI No. 511 on October 21, 2011. Supplement 1 response was sent on November 11, 2011 to provide a response to one (Question 06.02.02-124) of the six questions. Supplement 2, Supplement 3 and Supplement 4 responses to RAI No. 511 were sent on December 13, 2011, January 20, 2012, and February 24, 2012, respectively, to provide a revised schedule for the remaining five questions. The attached file, “RAI 511 Supplement 5 Response US EPR DC.pdf,” provides a technically correct and complete final response to Questions 06.02.02-125, 06.02.02-126 and 06.04-11. Appended to this file are affected pages of the U.S. EPR Final Safety Analysis Report in redline-strikeout format which support the response to RAI 511 Questions 06.02.02-125, 06.02.02-126 and 06.04-11.

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The following table indicates the respective pages in the response document, “RAI 511 Supplement 5 Response US EPR DC.pdf,” that contain AREVA NP’s response to the subject questions. Question # Start Page End Page RAI 511 — 06.02.02-125 2 3 RAI 511 — 06.02.02-126 4 5 RAI 511 — 06.04-11 6 6 A new schedule for technically correct and complete responses to the remaining two questions is being evaluated and is contingent upon scheduling a clarification telecon with NRC staff to further discuss remaining issues and review comments. Question # Response Date RAI 511 — 06.04-9 TBD RAI 511 — 06.04-10 TBD Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Friday, February 24, 2012 5:12 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); KOWALSKI David (RS/NB); GUCWA Len (External RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 4 Importance: High

Getachew, AREVA NP Inc. (AREVA NP) provided a schedule for responding to the six questions of RAI No. 511 on October 21, 2011. Supplement 1 response was sent on November 11, 2011 to provide a response to one (Question 06.02.02-124) of the six questions. Supplement 2 and Supplement 3 responses to RAI No. 511 were sent on December 13, 2011 and January 20, 2012, respectively, to provide a revised schedule for the remaining five questions. The schedule for technically correct and complete responses to the five questions has been changed as provided below. This schedule was transmitted to the NRC in AREVA NP letter NRC:12:008 dated February 21, 2012. Question # Response Date RAI 511 — 06.02.02-125 March 29, 2013 RAI 511 — 06.02.02-126 March 29, 2013 RAI 511 — 06.04-9 March 29, 2013 RAI 511 — 06.04-10 March 29, 2013

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RAI 511 — 06.04-11 March 29, 2013 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Friday, January 20, 2012 2:31 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); KOWALSKI David (RS/NB); GUCWA Len (External RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 3 Importance: High Getachew, AREVA NP Inc. (AREVA NP) provided a schedule for responding to the six questions of RAI No. 511 on October 21, 2011. Supplement 1 response was sent on November 11, 2011 to provide a response to one (Question 06.02.02-124) of the six questions. Supplement 2 response was sent on December 13, 2011 to provide a preliminary revised schedule for the remaining five questions. The preliminary schedule for the response to the remaining five questions has been changed as provided below. This schedule is being reevaluated and a new supplement with a revised schedule will be transmitted by February 21, 2012. Question # Response Date RAI 511 — 06.02.02-125 February 21, 2012 RAI 511 — 06.02.02-126 February 21, 2012 RAI 511 — 06.04-9 February 21, 2012 RAI 511 — 06.04-10 February 21, 2012 RAI 511 — 06.04-11 February 21, 2012 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Tuesday, December 13, 2011 4:26 PM To: [email protected]

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Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 2 Getachew, AREVA NP Inc. (AREVA NP) provided a schedule for responding to the six questions of RAI No. 511 on October 21, 2011. Supplement 1 response to RAI No. 511 was sent on November 11, 2011 to provide a response to one (Question 06.02.02-124) of the six questions. The preliminary schedule for the remaining five questions has changed from that provided in the November 11, 2011 response. The preliminary revised schedule is provided below. This schedule is being reevaluated and a new supplement with a revised schedule for the remaining five questions will be transmitted by January 25, 2012. Question # Response Date RAI 511 — 06.02.02-125 January 25, 2012 RAI 511 — 06.02.02-126 January 25, 2012 RAI 511 — 06.04-9 January 25, 2012 RAI 511 — 06.04-10 January 25, 2012 RAI 511 — 06.04-11 January 25, 2012 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: RYAN Tom (RS/NB) Sent: Friday, November 11, 2011 11:37 AM To: Tesfaye, Getachew Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); GUCWA Len (External RS/NB); WILLIFORD Dennis (RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 1 Getachew, AREVA NP Inc. (AREVA NP) provided a schedule for responding to the six questions of RAI No. 511 on October 21, 2011. The attached file, “RAI 511 Supplement 1 Response US EPR DC.pdf,” provides a technically correct and complete response to Question 06.02.02-124. The response references a revision to technical report, ANP-10293P, which is being provided by separate letter. The following table indicates the respective pages in the response document, “RAI 511 Supplement 1 Response US EPR DC.pdf,” that contain AREVA NP’s response to the subject questions. Question # Start Page End Page RAI 511 — 06.02.02-124 2 2

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The preliminary schedule for the remaining 5 questions is unchanged from that provided in the October 21, 2011 response. A new supplement with a revised schedule for these 5 questions will be transmitted by December 14, 2011. Question # Response Date RAI 511 — 06.02.02-125 December 14, 2011 RAI 511 — 06.02.02-126 December 14, 2011 RAI 511 — 06.04-9 December 14, 2011 RAI 511 — 06.04-10 December 14, 2011 RAI 511 — 06.04-11 December 14, 2011 Sincerely, Tom Ryan for Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected]

From: WILLIFORD Dennis (RS/NB) Sent: Friday, October 21, 2011 12:33 PM To: [email protected] Cc: BENNETT Kathy (RS/NB); DELANO Karen (RS/NB); ROMINE Judy (RS/NB); RYAN Tom (RS/NB); KOWALSKI David (RS/NB); GUCWA Len (External RS/NB) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6

Getachew, Attached please find AREVA NP Inc.’s response to the subject request for additional information (RAI). The attached file, “RAI 511 Response US EPR DC.pdf,” provides a schedule since technically correct and complete responses to the six questions cannot be provided at this time. The following table indicates the respective pages in the response document, “RAI 511 Response US EPR DC.pdf,” that contain AREVA NP’s response to the subject questions. Question # Start Page End Page RAI 511 — 06.02.02-124 2 2 RAI 511 — 06.02.02-125 3 3 RAI 511 — 06.02.02-126 4 4 RAI 511 — 06.04-9 5 6 RAI 511 — 06.04-10 7 8 RAI 511 — 06.04-11 9 9 The schedule for responding to Question 06.02.02-124 listed below is consistent with the commitment date for other GSI-191 questions that was provided in the GSI-191 Closure Plan letter (NRC:11:092) dated August 25, 2011. A preliminary schedule for technically correct and complete responses to the other 5 questions is provided below. This schedule is being reevaluated and a new supplement with a revised schedule for these 5 questions will be transmitted by December 14, 2011.

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Question # Response Date RAI 511 — 06.02.02-124 November 18, 2011 RAI 511 — 06.02.02-125 December 14, 2011 RAI 511 — 06.02.02-126 December 14, 2011 RAI 511 — 06.04-9 December 14, 2011 RAI 511 — 06.04-10 December 14, 2011 RAI 511 — 06.04-11 December 14, 2011 Sincerely, Dennis Williford, P.E. U.S. EPR Design Certification Licensing Manager AREVA NP Inc. 7207 IBM Drive, Mail Code CLT 2B Charlotte, NC 28262 Phone: 704-805-2223 Email: [email protected] From: Tesfaye, Getachew [mailto:[email protected]] Sent: Wednesday, September 21, 2011 5:20 PM To: ZZ-DL-A-USEPR-DL Cc: Ashley, Clinton; ODriscoll, James; Jackson, Christopher; McKirgan, John; Scarbrough, Thomas; Terao, David; Colaccino, Joseph; ArevaEPRDCPEm Resource Subject: U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6 Attached please find the subject requests for additional information (RAI). A draft of the RAI was provided to you on August 31, 2011, and discussed with your staff on September 21, 2011. Drat RAI Questions 06.04-9 was modified as a result of that discussion. The schedule we have established for review of your application assumes technically correct and complete responses within 30 days of receipt of RAIs. For any RAIs that cannot be answered within 30 days, it is expected that a date for receipt of this information will be provided to the staff within the 30 day period so that the staff can assess how this information will impact the published schedule.

Thanks, Getachew Tesfaye Sr. Project Manager NRO/DNRL/NARP (301) 415-3361

Hearing Identifier: AREVA_EPR_DC_RAIs Email Number: 4476 Mail Envelope Properties (554210743EFE354B8D5741BEB695E6561659BC) Subject: Response to U.S. EPR Design Certification Application RAI No. 511 (6019,6020,6012), FSAR Ch. 6, Supplement 8 Sent Date: 5/17/2013 10:00:14 PM Received Date: 5/17/2013 10:00:25 PM From: WILLIFORD Dennis (AREVA) Created By: [email protected] Recipients: "Gleaves, Bill" <[email protected]> Tracking Status: None "ANDERSON Katherine (EXTERNAL AREVA)" <[email protected]> Tracking Status: None "DELANO Karen (AREVA)" <[email protected]> Tracking Status: None "LEIGHLITER John (AREVA)" <[email protected]> Tracking Status: None "ROMINE Judy (AREVA)" <[email protected]> Tracking Status: None "RYAN Tom (AREVA)" <[email protected]> Tracking Status: None "KOWALSKI David (AREVA)" <[email protected]> Tracking Status: None "HONMA George (EXTERNAL AREVA)" <[email protected]> Tracking Status: None "GUCWA Len (EXTERNAL AREVA)" <[email protected]> Tracking Status: None "VANCE Brian (AREVA)" <[email protected]> Tracking Status: None "Snyder, Amy" <[email protected]> Tracking Status: None Post Office: FUSLYNCMX03.fdom.ad.corp Files Size Date & Time MESSAGE 18828 5/17/2013 10:00:25 PM RAI 511 Supplement 8 Response US EPR DC.pdf 346266 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Response to

Request for Additional Information No. 511, Supplement 8

9/21/2011

U. S. EPR Standard Design Certification AREVA NP Inc.

Docket No. 52-020 SRP Section: 06.02.02 - Containment Heat Removal Systems

SRP Section: 06.04 - Control Room Habitability System

Application Section: 6.3

QUESTIONS for Containment and Ventilation Branch 1 (AP1000/EPR Projects) (SPCV)

QUESTIONS for Component Integrity, Performance, and Testing Branch 1 (AP1000/EPR Projects) (CIB1)

AREVA NP Inc. Response to Request for Additional Information No. 511, Supplement 8 U.S. EPR Design Certification Application Page 2 of 6 Question 06.04-9:

Clarify how primary containment bypass leakage that is not captured by the AVS or the leakoff system, is captured by the secondary containment.

Based on the staff’s review of your responses and proposed Tier 1 and Tier 2 markups to questions in RAI 277 (Supplement 18 response) and RAI 462 (Supplement 4 response), the staff requests the following information with regard to FSAR Section 6.2.3 “Secondary Containment”:

The staff understands that the containment leakoff system functions with the AVS to provide assurance that some but not all primary containment leakage is directed back to the AVS filtration trains. Details of the system will be documented in the FSAR per your response to RAI 462 Question 06.02.03-8. The staff understands that there remain other bypass leakage pathways including hatches and isolation valves that terminate in the fuel building and the Safeguard buildings. In several locations in the FSAR you credit the existence of a .25 inch water gauge negative pressure in these buildings as the means to assure that any leakage of potentially contaminated air to the outside environment is prevented.

In accordance with SRP 6.2.3, since you assume zero bypass leakage (0.00La) of secondary containment in section 6.2.6.5, of the FSAR and in the FSAR chapter 15 radiological analyses, the staff considers the Fuel Building and the Safeguard Building Controlled Areas along with the Shield Building as containment structures that are part of the secondary containment. The staff understands that, it is the intent of the design that in a DBA, 100% of containment leakage is filtered at 99% efficiency 305 seconds after ESF system actuation. It is the function of the secondary containment to capture any primary containment leakage, and provide 100% filtration of La in order to meet assumptions used in the radiological analyses.

Since the SBVS is the ESF system that establishes the negative pressure in the Safeguard Building and the Fuel building, and the SBVS is credited to establish a negative pressure in the Fuel Building and the Controlled Area of the Safeguard Buildings for the purpose of capturing this primary containment bypass leakage, the staff requests the following clarifications in the US EPR FSAR:

a. Clarify The Tier 2 and Tier 1 safety- related functions of the Fuel Building, Safeguard Building, and the SBVS to state that they provide the safety-related function of capturing the primary containment bypass leakage that is not captured by the leak-off system. Clarify the discussion on secondary containment in 6.2.6.5 to clarify that the secondary containment encompasses all SSCs that are credited with secondary containment functions (i.e those SSC’s relied upon to ensure that zero bypass leakage is zero (0.00La)).

b. In order to verify the FSAR Chapter 15 accident analyses assumptions, add Tier 1 ITAAC to verify that the Fuel Building and the Safeguard Building Controlled Areas are capable of being drawn down to a negative pressure of .25 inches of water gauge in 305 seconds.

c. Clarify the scope of Technical specification 3.6.6 to cover the functions of the entire secondary containment as opposed to just the shield building (only a portion of the secondary containment). Specifically,

AREVA NP Inc. Response to Request for Additional Information No. 511, Supplement 8 U.S. EPR Design Certification Application Page 3 of 6

I. Include similar operability requirements and required actions for the Safeguard Building Controlled Areas and the Fuel Building as that in LCO 3.6.6.

II. Add similar surveillance requirements for the Fuel Building and the Safeguard Building Controlled Area as those for the Shield Building specifically, expand the scope of SR 3.6.6.5, inspection requirements to include the Safeguard Building Controlled Area and the Fuel Building)

III. Clarify the Shield Building Technical Specification Bases 3.6.6 discussion to indicate that the Shield Building functions in conjunction with the Safeguard Building Controlled Areas and the Fuel Building to ensure that the release of radioactive materials from the primary containment atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses.

IV. Clarify the SBVS Technical Specification Bases 3.7.12 to clarify that the SBVS design basis addresses the capture of the primary containment bypass leakage, that is described in Tier 2 paragraph 6.2.6.5, (i.e. that bypass leakage that is not captured by the AVS or the leak-off system. )

d. Re- address RAI 233 Question 06.05.03-1 which requested the scope of the secondary containment review to include the Safeguard Buildings and the Fuel building, and questioned the effect of wind on the outside walls of these buildings, on the capability of the SBVS to maintain the credited negative pressure within. In your response to this RAI, please assume the SBVS flow rate stated in SR 3.7.12.7 in your analysis.

e. Revise the analysis that supports the functional capability of the EPR secondary containment design in response to a LOCA, to include the Safeguard Building Controlled Area and the Fuel Building along with the Shield Building Annulus. Address SRP Section 6.2.3 Acceptance Criteria 1A through 1H with this scope.

Response to Question 06.04-9:

Item a

The U.S. EPR FSAR will be revised to clarify the Fuel Building (FB), Safeguard Building (SB), and the Safeguard Building (Controlled Area) Ventilation System (SBVS) safety-related function for capturing the primary containment bypass leakage. These changes are provided in the following U.S. EPR FSAR sections:

• U.S. EPR FSAR Tier 1, Section 2.6.4, Fuel Building Ventilation System

• U.S. EPR FSAR Tier 1, Section 2.6.6, Safeguard Building Controlled-Area Ventilation System

• U.S. EPR FSAR Tier 2, Section 9.4.2, Fuel Building Ventilation System

• U.S. EPR FSAR Tier 2, Section 9.4.5, Safeguard Building Controlled-Area Ventilation System

Additional clarification will be added to Section 6.2.3.2.3 to clarify that the structures, systems and components (SSCs) that are credited with secondary containment functions are all located

AREVA NP Inc. Response to Request for Additional Information No. 511, Supplement 8 U.S. EPR Design Certification Application Page 4 of 6 within the filtered areas. This change was made as a part of the response to Question 06.02.03-8 in RAI 462, Supplement 8.

Item b AREVA NP Inc. will revise the Tier 1/ ITAAC test requirement for a negative pressure of 0.25 inches water gauge in the Safeguard Buildings and the Fuel Building. The revision will include the 305 second draw down time in the Fuel Building and the hot mechanical rooms of the Safeguard Buildings relative to the outside environment after receipt of a containment isolation signal test input signal from the PACs module. U.S. EPR FSAR Tier 1, Section 2.6.6 and Table 2.6.6-3, Safeguard Building Controlled-Area Ventilation System ITAAC, Item 7.1 will be revised to include this change.

Item c

As described in U.S. EPR FSAR Tier 2, Section 6.2.6.5, the Annulus, Safeguard Buildings and Fuel Building perform a similar function in capturing and processing post-accident leakage through ESF filter systems. Upon receipt of Containment Isolation Phase 1 signal, the Fuel Building Ventilation System isolates from the Nuclear Auxiliary Building Ventilation System (NABVS) and directs flow to the SBVS. Since the Annulus Ventilation System (AVS) and SBVS provide comparable leakage processing functions, the surveillance requirements (SR) for these systems were compared and an SR will be added to the SBVS (U.S. EPR FSAR Tier 2, Chapter 16, Technical Specification 3.7.12) to require a visual inspection of the exposed interior and exterior portions of the Safeguard Buildings and Fuel Building. The Background sections of the Bases for U.S. EPR FSAR Tier 2, Chapter 16, Technical Specifications 3.6.6 and 3.7.12 will be revised to note the shared mission of processing containment and penetration leakage.

Item d

Item d is addressed in RAI 233, Supplement 5, Question 06.05.03-1.

Item e

A separate GOTHIC analysis has been performed for the drawdown of the FB and SB by the SBVS on receipt of a containment isolation signal. This analysis determined the required capacity of the SBVS fans to draw down the FB and SB to a negative pressure of 0.25 inches water gauge in 305 seconds (i.e., the time it takes the AVS to draw down the Annulus). The requirements and design of the SBVS to meet these requirements are addressed in U.S. EPR FSAR, Tier 2 Sections 6.5.1.3, 9.4.5 and Technical Specification Basis 3.7.12.

The following SRP Section 6.2.3 Acceptance Criteria are applicable:

1.B. Adiabatic boundary conditions are assumed for the surface of the FB and SB exposed to the outside environment.

1.D. In-leakage from the primary containment (by-pass leakage) and the outside environment into the SB and FB is considered.

1.E. No credit is taken for out-leakage from the FB and SB.

AREVA NP Inc. Response to Request for Additional Information No. 511, Supplement 8 U.S. EPR Design Certification Application Page 5 of 6 1.F By design, both SBVS accident fans start upon receipt of a CI signal. This analysis

assumes the failure of one fan to start.

1.G. Heat loads are included for both the FB and SB.

1.H. To account for potential degradation such as clogged filter, the SBVS design capacity was degraded by increasing the system resistance and decreasing the fan performance.

In addition, the following SRP Section 6.2.3 Acceptable Criteria are not applicable:

1.A. Heat transfer from the primary containment to the FB and SB is not considered as the buildings are not adjacent to each other.

1.C. The compressive effect of primary containment expansion on the FB and SB atmosphere is not considered since the annulus is between the primary containment and the FB and SB.

Additional Clarifications

The following additional clarification is being provided to address comments discussed with NRC Staff during the March 19, 2013 and April 8, 2013 teleconference.

Fuel Handling Accidents

In the event of a fuel handling accident in the FB, the NABVS air exhaust and supply to the fuel pool area are isolated by closing the isolation dampers serving this room. The isolation dampers to the SBVS accident filtration trains open and the exhaust is processed by the SBVS. This occurs automatically by the sampling activity monitor R-19 or via a local push buttons located in the fuel pool room. The NABVS will continue to ventilate the other areas in the FB U.S. EPR FSAR Tier 2, Sections 9.4.2, 9.4.3, 9.4.5, and Figure 11.5-1 will be revised.

During cold shutdown, both the full flow and low flow purge subsystems of the CBVS are operating. In the event of a fuel handling accident in the RB, the CI valves of the full and low flow purge supply and the full flow purge exhaust are closed by pushing the emergency button located in the fuel handling area inside containment. The CBVS purge supply air damper to the equipment hatch area and the FBVS exhaust damper at the emergency airlock are closed. The CBVS low flow purge exhaust system will continue to operate and filter the containment air and discharge it to the vent stack U.S. EPR FSAR Tier 2, Sections 9.4.3, 9.4.5, and 9.4.7 will be revised.

The SBVS and the CBVS low flow purge accident filtration systems can be used as backup for the fuel handling accidents though this is not a required function of the systems.

U.S. EPR FSAR Tier 2, Section 9.4 will be revised to clarify the fuel handling accidents in the Reactor Building and Fuel Building.

Operational and Accident Operation Modes of the SBVS

The processing of the SBVS exhaust during normal operation by the NABVS has two potential filtration paths:

AREVA NP Inc. Response to Request for Additional Information No. 511, Supplement 8 U.S. EPR Design Certification Application Page 6 of 6 1. In normal operation, exhaust is directed through a HEPA filter.

2. If radiation is detected, exhaust is directed though an iodine filtration train. The SBVS exhaust radiation monitors are part of the NABVS system and are shown in U.S. EPR FSAR Tier 2, Figure 9.4.3-3.

The Operational Air Exhaust Mode in U.S. EPR FSAR Tier 2, Section 9.4.5.2.1 has been revised to include the two potential filtration paths during normal plant operation.

The Accident Air Exhaust Mode is described in U.S. EPR FSAR Tier 2, Section 9.4.5.2.1, which discusses the exhausting of the controlled area in the SB. The SBVS alignment during a fuel handling accident in the FB or the RB is discussed in paragraphs following this section. The function of the SBVS during a fuel handling accident in the RB has been added.

U.S. EPR FSAR Tier 2 Section 9.4.5.2.1 will be revised to clarify the accident operation of the SBVS.

Leak-Off System

See response to Question 6.2.3-8, RAI 462, Supplement 8 for clarification of the leak-off system.

RAI 584

On May 8, 2013, AREVA NP Inc. received RAI 584 that documents NRC Staff’s additional comments and questions regarding RAI 511, Question 06.02.03-9. Those specific comments and questions will be addressed in our response to RAI 584.

FSAR Impact:

U.S. EPR FSAR Tier 1, Section 2.6.4, Table 2.6.4-3, Section 2.6.6, Section 2.6.8, Table 2.6.6-3, Table 2.6.8-4 will be revised as described in the response and indicated on the enclosed markup.

U.S. EPR FSAR Tier 2, Table 3.11-1, Section 9.4.2, Section 9.4.3, Section 9.4.5, Section 9.4.7, Section 11.5.3.1.4, Table 11.5-1 (Sheet 3 of 17), Figure 11.5-1, Section 12.3.6.5.6, Table 12.3.4, and Chapter 16 Technical Specifications Sections 3.7.12 SR 3.7.12.9, B 3.6.6, B 3.7.12 will be revised as described in the response and indicated on the enclosed markup.

U.S. EPR Final Safety Analysis Report Markups

U.S. EPR FINAL SAFETY ANALYSIS REPORT

Tier 1 Revision 5—Interim Page 2.6-41

2.6.4 Fuel Building Ventilation System

Design Description

1.0 System Description

The fuel building ventilation system (FBVS) receives the conditioned air supply from the nuclear auxiliary building ventilation system (NABVS). The exhaust from the FBVS is processed by the NABVS through a filtration train, and the exhaust air is directed to the vent stack.

The FBVS controls the Fuel Building temperature, humidity and air change rate for personnel comfort, personnel safety, and equipment protection during normal plant operation. The FBVS provides cooling, heating, and ventilation for the Fuel Building (FB) to remove equipment heat and heat generated from other sources. The FBVS also provides heat to maintain a minimum temperature in the building. The FBVS provides a minimal air change rate for the building and controls the building pressurization to reduce spreading of contamination.

The FBVS provides the following safety-related functions:

� Isolation of the FB from NABVS supply and exhaust on receipt of containment isolation signal. The FB atmosphere is then processed through iodine filtration trains of the safeguard building controlled-area ventilation system (SBVS).

� Heating of the rooms which have safety-related systems, structures, or equipment containing borated fluid and the rooms surrounding the extra borating system tanks to maintain minimum ambient room temperatures.

� Cooling of rooms which have the extra borating system pumps and the fuel pool cooling system pumps to maintain ambient conditions.

The FBVS provides the following non-safety related functions:

� Diverts the ventilation air flow to the NABVS iodine filter train on high radioactivity in the Fuel Building.

� Isolates the fuel handling area ventilation on high activity in the Fuel Building exhaust.Maintains the room ambient conditions for operation of equipment and to allow personnel access during normal operation.

� Reduces spread of contamination from the contaminated rooms to less contaminated rooms during normal operation.

� Reduces concentration of aerosols and radioactive gases from the room air.

� Maintains a negative pressure within the Fuel Building with respect to outside atmosphere.

All indicated changes are in response to RAI 511, Question 06.04-9



2.6.6 Safeguard Building Controlled-Area Ventilation System

Design Description


The safeguard building controlled-area ventilation system (SBVS) provides cooling, heating, and ventilation for the hot areas of the four divisions of the Safeguard Buildings to remove equipment heat and heat generated from other sources. The SBVS also provides heat to maintain a minimum temperature in areas of the Safeguard Buildings. The SBVS provides a minimal air change rate for the buildings and controls the building pressurization to reduce spreading of contamination.

The SBVS provides the following safety-related functions:

� Isolates the volume of the hot mechanical area of the Safeguard Buildings and confines this volume by maintaining a negative pressure and removing the iodine that might be released due to post-accident operation of the safety injection system (SIS).

� Removes heat generated by equipment of the safety injection / residual heat removal systems in the hot mechanical rooms to maintain ambient temperatures during accident conditions.

� Removes heat generated by piping and equipment of the component cooling water and emergency feedwater systems in the valve rooms to maintain ambient temperatures during accident conditions.

� Removes heat generated by equipment of the hydrogen monitoring and post accident atmosphere sampling systems to maintain ambient temperatures during accident conditions.

� Maintains a negative pressure in the Fuel Building (FB) and Safeguard Building (SB) mechanical areas to capture leakage from the primary containment upon receipt of a containment isolation signal. The exhaust air is directed through the SBVS iodine filtration trains before being released into the environment. to direct the air from the FB to the SBVS iodine filtration trains when the FB is isolated from the nuclear auxiliary building ventilation system (NABVS) on receipt of a containment isolation signal.

The SBVS provides the following non-safety-related functions:

� Diverts the ventilation air flow to the NABVS iodine filter train on high radioactivity in the Safeguard Buildings.Ventilates the hot mechanical areas of the Safeguard Buildings and provides a minimum required air change rate during normal operation.

� Maintains acceptable ambient conditions in the hot mechanical areas of the Safeguard Buildings during normal operation.




2.6.8 Containment Building Ventilation System

Design Description


The containment building ventilation system (CBVS) controls the Reactor Containment Building temperature, humidity and air change rate for personnel comfort, personnel safety, and equipment protection during normal plant operation. The CBVS provides cooling, heating, and ventilation for the Reactor Containment Building to remove equipment heat, and heat generated from other sources. The CBVS also provides heat to maintain a minimum temperature in the building. The CBVS provides a minimal air change rate for the building and controls the building pressurization to reduce spreading of contamination.

The CBVS provides the following safety-related functions:

� Upon receipt of a containment isolation signal, the CBVS provides automatic isolation of the containment atmosphere by quick closure of the system containment isolation valves.

� Upon receipt of a containment isolation signal during a low flow purge operation, air exhausted from containment will be filtered by the CBVS low flow iodine filtration units until the containment isolation valves are closed.

The CBVS provides the following non-safety-related functions:

� Isolation of Containment Building Low Flow Purge Subsystem supply air damper to Fuel Building hatch area when the equipment hatch is open on receipt of a signal from the emergency push button located in the fuel handling area inside the RB.

� Isolation of Fuel Building Ventilation System exhaust air damper to the area in front of emergency airlock on receipt of a signal from the emergency push button located in the fuel handling area inside the RB.

� Containment full flow purge supply and exhaust during outages.

� Containment low flow purge supply for containment entry during normal plant operation.

� Internal filtration to reduce radioactive contamination inside the equipment compartment.

� Supply of cool air to the reactor pit area to prevent concrete degradation.

� Containment cooling to maintain ambient conditions.




3.12 ASME Code Class 1, 2 and 3 components are fabricated, installed, and inspected in accordance with ASME Code Section III requirements.

3.13 ASME Code Class 1, 2 and 3 piping systems are designed in accordance with ASME Code Section III requirements.

3.14 Deleted.

3.15 Deleted.

3.16 Deleted.

3.17 Deleted.

4.0 I&C Design Features, Displays, and Controls

4.1 Displays listed in Table 2.6.8-3 are indicated on the PICS operator workstations in the MCR and the RSS.

4.2 Controls on the PICS operator workstations in the MCR and the RSS perform the function listed in Table 2.6.8-3.

4.3 Equipment listed as being controlled by a PACS module in Table 2.6.8-3 responds to the state requested and provides drive monitoring signals back to the PACS module. The PACS module will protect the equipment by terminating the output command upon the equipment reaching the requested state.

4.4 Deleted.

5.0 Electrical Power Design Features

5.1 Equipment designated as Class 1E in Table 2.6.8-3 are powered from the Class 1E division as listed in Table 2.6.8-3 in a normal or alternate feed condition.

5.2 Deleted.

6.0 Environmental Qualifications

6.1 Equipment designated as harsh environment in Table 2.6.8-3 will perform the function listed in Tables 2.6.8-1 and 2.6.8-2 under normal environmental conditions, containment test conditions, anticipated operational occurrences, and accident and post-accident environmental conditions.

7.0 Equipment and System Performance

7.1 The CBVS low flow purge exhaust subsystem exhausts through a CBVS iodine filtration train.

7.2 DeletedUpon receipt of a signal from the emergency push button in the fuel handling area in the RB, the following actions occur automatically:




� Close Containment Building Low Flow Purge Subsystem supply air damper to Fuel Building hatch area when the equipment hatch is open.

� Close Fuel Building Ventilation System exhaust air damper to the area in front of emergency airlock.

Inspections, Tests, Analyses, and Acceptance Criteria

Table 2.6.8-4 lists the CBVS ITAAC.




7.1 The CBVS low flow purge exhaust subsystem exhausts through a CBVS iodine filtration train.

Tests will be performed to verify the capability of the low flow purge exhaust subsystem to exhaust through a CBVS iodine filtration train.

The CBVS exhausts through a CBVS iodine filtration train when the CBVS low flow purge exhaust subsystem is operating.

7.2 Upon receipt of a signal from the emergency push button in the fuel handling area in the RB, the following actions occur automatically:� Close Containment

Building Low Flow Purge Subsystem supply air damper to Fuel Building hatch area when the equipment hatch is open.

� Close Fuel Building Ventilation System exhaust air damper to the area in front of emergency airlock.Deleted.

A test will be performed to verify that upon receipt of a test input signal, the following actions occur automatically:� Close Containment



The following actions occur automatically within 60 seconds after receipt of an isolation test input signal from the PACS module:� Close Containment



Table 2.6.8-4—Containment Building Ventilation System ITAAC Sheet 6 of 6

Commitment WordingInspections, Tests,

Analyses Acceptance Criteria


U.S

. EPR

FIN

AL

SAFE

TY A

NA

LYSI

S R

EPO

RT

Tier

2 R

evis

ion

5—

Inte

rim

Pag

e 3

.10-

151

RCS

CL3 I

so V

lv30

KUA3

0AA0

0230

UJA1

8007

MM

SIS

C/NM

Y (5

)RC

S CL

3 Inn

er C

ont Is

o Vlv

30KU

A30A

A003

30UJ

A 070

16M

MES

PAM

SIS

C/NM

Y (5

)RC

S CL

3 Oute

r Con

t Iso V

lv30

KUA3

0AA0

0430

UFA0

6095

MH

ESPA

MSI

SC/

NMY

(3)

Y (5

)RC

S CL

3 Tes

t CKV

30KU

A30A

A090

30UJ

A 180

07M

MSI

SY

(5)

RCS

CL3 I

solat

ion C

KV30

KUA3

0AA0

9130

UJA 0

7016

MM

SIS

Y (5

)RC

S CL

3 Tes

t Iso V

lv 1

30KU

A30A

A092

30UJ

A 070

16M

MSI

SC/

NMY

(5)

RCS

CL3 T

est Is

v Vlv

230

KUA3

0AA0

9330

UJA 0

7016

MM

SIS

C/NM

Y (5

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S CL

3 Tes

t Iso V

lv 3

30KU

A30A

A094

30UJ

A 070

16M

MSI

SC/

NMY

(5)

RCS

CL3 T

est Is

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430

KUA3

0AA0

9530

UJA0

7016

MM

SIS

C/NM

Y (5

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S CL

3 Ven

t Vlv

130

KUA3

0AA5

0130

UJA 1

8007

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SIS

C/NM

Y (5

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S CL

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t Vlv

230

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0AA5

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30KU

B10A

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30UF

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C/NM

Y (3

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(5)

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Cont

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Mon

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Tab

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10-1

—Li

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f Sei

smic

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and

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Qua

lifie

d M

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nica

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of 2

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tion)

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Num

ber

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l Are

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(Roo

mLo

catio

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EQEn

viron

men

t(N

ote 1

)

Radi

atio

n En

viron

men

t Zo

ne (N

ote 2

)

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signa

ted

Func

tion

(Not

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Safe

ty C

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(Not

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EQ P

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All

indi

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06.0

4-9



9.4.2 Fuel Building Ventilation System

The fuel building ventilation system (FBVS) is designed to maintain acceptable ambient conditions in the Fuel Building (FB), to permit personnel access, and to control airborne radioactivity in the area during normal operation, anticipated occurrences, and following fuel handling accidents.

The conditioned air supply to the FB is provided by the nuclear auxiliary building ventilation system (NABVS) (refer to Section 9.4.3). The exhaust from the building is also processed by the NABVS through a filtration train, and the exhaust air is directed to the vent stack (refer to Section 9.4.3).

9.4.2.1 Design Bases

The following components are safety-related and designed to Seismic Category I requirements:

� Fuel pool floor handling hall isolation dampers.

� Isolation dampers for the fuel handling hall located in front of the equipment hatch.

� Isolation dampers for the room located in front of the emergency airlock.

� NABVS supply and exhaust isolation dampers to and from FBVS.

� FB isolation dampers to safeguard building ventilation system (SBVS).

� Electric fan heaters for heating of rooms that have safety-related systems, structures or components containing borated fluid and the rooms surrounding the extra borating system tanks.

� Recirculation cooling units in the extra borating system pump rooms, and fuel pool cooling system pump rooms.

� FBVS exhaust duct.

The FBVS air supply duct and other components of the FBVS are designated as Supplemental Grade (NS-AQ) safety class and Seismic Category II.

The FBVS components are located inside the FB structure, which is designed to withstand the effects of natural phenomena, such as earthquake, tornados, hurricanes, floods and external missiles (GDC-2).

The safety functions of the FB ventilation system can be performed assuming a single active component failure coincident with the loss of offsite power (LOOP). Upon receipt of a containment isolation signal, the FBVS supply and exhaust is isolated from the NABVS. Potential bypass leakage from primary containment is captured and




filtered by the SBVS iodine filtration trains before being released into the environment.

The seismic design of the system components meets the guidance of RG 1.29 (Position C.1 for the safety-related portion and Position C.2 for the non-safety-related portion). Table 3.2.2-1 provides the seismic design and other design classifications for components in the FBVS.

The safety-related components and systems of the FB ventilation system are not shared among nuclear power units (GDC-5).

The release of radioactive material to the environment is controlled by meeting the guidance of RG 1.140, positions C.2 and C.3 (GDC-60). RG 1.52 is not applicable because the FBVS is not required to operate during post-accident engineered safety features (ESF) atmospheric cleanup. In case of high radiation alarm in the FB (refer to Table 11.5-1, Monitors R-17 and R-18), the system will automatically direct the building exhaust through activated charcoal filtration beds located in the NABVS.

The FBVS provides appropriate ventilation and filtration to limit potential release of airborne radioactivity to the environment from the fuel storage facility under normal operation and in the event of a fuel handling accident in the fuel pool area. The design of the ventilation system meets the guidance of RG 1.13, Position C.4 (GDC-61).

Air conditioning and heating loads for the FB Rooms are calculated using methodology identified in ASHRAE Handbook (Reference 3).

� Summer air conditioning loads will be calculated with a maximum outside air design temperature 0 percent exceedance value, using U.S. EPR Site Design Envelope Temperature (See Table 2.1-1). The analysis will be completed for both a normal and accident plant alignment configuration.

� The cooling supply units are designed to provide cooling as required to prevent the FB room temperatures from exceeding their maximum design temperature.

� Winter heating loads will be calculated with the plant operating in an outage alignment configuration. Winter heat loads will be calculated with a minimum outside air design temperature 0 percent exceedance value, using U.S. EPR Site Design Envelope Temperature (See Table 2.1-1).

The FBVS provides the following important non-safety-related functions:

� Controls and maintains a negative pressure during normal operation within the FB relative to the outside environment. Rooms identified as having possible radioactive contamination are designed to be at a negative pressure relative to the adjacent rooms to make sure air flows from areas of low radioactivity to areas of potentially higher radioactivity.




Containment Building is processed through a dedicated filtration train to a common exhaust plenum, and subsequently directed by two of the four exhaust fans to the vent stack.

The laboratory exhaust is processed through one of the two iodine filtration trains, with one of two exhaust fans operating, prior to its discharge through the vent stack.

All system fire dampers are in the open position.

When the plant is in cold shutdown, the NABVS operates in combination with the containment building ventilation system to purge the containment service compartments. The exhaust is processed through a specific NABVS exhaust train.

Abnormal Operating Conditions

Failure of Iodine Adsorber Train

Failure of a fan in an operating iodine adsorber train initiates the operation of another iodine train; thus, the single failure has no effect on the functioning of the system. For the laboratory exhaust system, two filter trains are provided; in the event of a failure in one of the trains, the other train will start automatically.

Iodine Activity Detection

In the event iodine is detected in the NAB, FB, or SB, the affected exhaust flow paths are redirected through the iodine filtration train prior to discharge through the vent stack. Iodine activity is detected separately in each cell.

Fuel Handling Accident in the Fuel Building

In the event of a fuel handling accident in the FB, the FB exhaust and supply are isolated by closing the appropriate dampers (refer to Section 9.4.2). To prevent spread of airborne contamination, the iodine filtration trains of the SB ventilation system process the exhaust air to maintain the required pressure in the FB pool hall (refer to Section 9.4.5). The remainder of the FB is ventilated by the NABVS. During and after the fuel handling accident, proper NABVS supply and exhaust flow rates are maintained by adjusting the control dampers.

Fuel Handling Accident in the Containment Building

In the event of a fuel handling accident in the Containment Building, the CBVS full and low flow purge supply and the full flow purge exhaust containment isolation valves are closed and low flow purge exhaust is filtered through the low flow purge exhaust subsystem filtration trains (refer to Section 9.4.7). the containment isolation valves close (refer to Section 9.4.7). Exhaust from the Containment Building is routed




to the iodine filtration trains of the CBVS. Excess air supply from the NABVS is redirected by adjusting the supply air control dampers.

Operation of Safety Injection System during LOCA

In the event of a loss of coolant accident (LOCA), leakages in the safety injection system (SIS) can lead to iodine activity levels that are above the limits of the NABVS iodine filtration trains. In such a case, the SB exhaust is routed through the SB ventilation system (refer to Section 9.4.5). Excess air supply from NABVS is redirected by adjusting the supply air control damper. The NABVS supply and exhaust to the FB are isolated (refer to Section 9.4.2).

Loss of Offsite Power (LOOP)

A LOOP results in a loss of power to the NABVS electrical components, such as fans, dampers, cooling units, and heaters. The NABVS system is not provided with emergency power.Upon loss of offsite power, the isolation dampers fail to the closed position, preventing any pathway for potentially contaminated air to leak out to the environment.

Station Blackout (SBO)

In the event of SBO, there will be no power to any of the electrical components of the NABVS. Isolation dampers with spring return will fail to the closed position. Other isolation dampers will fail “as-is”.

9.4.3.3 Safety Evaluation

The backdraft damper located in the NABVS exhaust at the vent stack is the only component in the NAVBVS that performs a nuclear safety-related function. None of the other NABVS components are required to operate during a design basis accident (DBA). In case of a DBA, the NABVS is isolated from the HVAC systems of other buildings by isolation dampers. The backdraft damper prevents exhaust air flow from the AVS and SBVS from discharging into the NABVS.

The NABVS provides adequate capacity and redundant trains to maintain proper temperature levels in the NAB, FB, Containment Building, and annulus.

9.4.3.4 Inspection and Testing Requirements

The NABVS major components, such as dampers, motors, fans, filters, coils, heaters, and ducts are located to provide access for initial and periodic testing to verify their integrity.




(GDC 4). Refer to Section 3.5.1.1, Section 3.5.1.4, Section 3.5.2, and Section 3.6.1 for information on compliance with GDC 4 as it relates to protection from missiles and postulated piping failures.

The safety-related components and systems of the SBVS are not shared among nuclear power units (GDC 5).

The essential onsite electrical power systems meet the guidance of NUREG-CR/0660 (subsection A–item 2, and subsection C-item 1) (Reference 1) for protection of essential electrical components (such as contactors, relays, circuit breakers) from failure due to the accumulation of dust and particulate materials (GDC 17). This is accomplished by the roughing prefilters and filters of the supply air units of the SBVSE as described in Section 9.4.6.

The release of radioactive materials to the environment is controlled by meeting the guidance of RG 1.52 (position C.3) (GDC 60). Upon receipt of a high radiation alarm in the hot mechanical areas of the SBs (refer to Table 11.5-1, Monitor R-25), the SBVS will direct the exhaust air (accident exhaust) through NABVS activated charcoal filtration beds located in the NAB prior to release through the plantvent stack.

Filtration during normal operation is provided by the NABVS by meeting the guidance of RG 1.140 (positions C.2 and C.3). Refer to Section 9.4.3.

Capability for withstanding or coping with a station blackout (SBO) event is provided to comply with the requirements of 10 CFR 50.63. Acceptance is based on meeting the applicable guidance of RG 1.155, including position C.3.2.4. Refer to Section 8.4 for a description of the design features to cope with the SBO event.

The SBVS provides isolation and confinement of the hot mechanical areas of the SBs. The system also provides reduction of a possible radioactive release into the environment.

In case of fuel handling accident in the FB, the exhaust air (accident air) from the FB fuel pool area and the hot mechanical area of the SB is directed through the SBVS activated charcoal filtration beds located in the FB prior to release through the vent plant stack.

On receipt of containment isolation signal, the SB hot mechanical areas are isolated and the SBVS iodine filtration trains are initiated. the NABVS supply and exhaust isolation dampers are closed to limit leakage out of the FB. The SBVS maintains negative pressure in the FB and SB hot mechanical areas to capture potential bypass leakage from primary containment. The exhaust air is directed to the SBVS iodine filtration trains before being released into the environment air from the FB is directed to the SBVS iodine filtration trains (refer to Section 9.4.2).




� Maintains acceptable ambient conditions inside the emergency feed water system (EFWS) pumps and component cooling water system (CCWS) componentvalve rooms of the SB during accident conditions, taking into account internal and external heat loads.

� Maintains a negative pressure and filters the hot mechanical areas of Safeguard Buildings and Fuel Building upon receipt of a containment isolation signal

The SBVS performs the following important non-safety-related system functions:

� Controls and maintains a negative pressure within the hot mechanical areas of Safeguard Buildings relative to the outside environment during normal plant operation and plant maintenance.

� Maintains acceptable ambient conditions (temperature and humidity) in the SB hot mechanical rooms for equipment operation and personnel comfort during normal plant operation and plant maintenance.

� Ventilates the hot mechanical rooms in the SB to maintain a good working environment for personnel in these areas during normal plant operation and plant maintenance.

� Provides personnel comfort heating for the service access areas and the stairwell areas during normal plant operation and plant maintenance.

9.4.5.2 System Description

9.4.5.2.1 General Description

The SBVS is composed of following subsystems:

� SB controlled-area air supply subsystem (see Figure 9.4.5-1).

� SB controlled-area exhaust air subsystem (see Figure 9.4.5-2).

The SBVS provides ventilation and cooling to the hot mechanical areas of the four divisions of the SBs. The SB divisions one and four are located on opposite sides of the RB, while SB divisions two and three are housed together and located next to the RB.

The SBVS supplies conditioned air for ventilation to the mechanical area of the SB, divisions one, two, three and four. During normal operation the conditioned air supply to the hot mechanical areas of the SBs SB divisions is provided independently for each division by the SBVSE (refer to Section 9.4.6). The supply duct of each SB division is equipped with two isolation dampers and one pressure volume control damper. The conditioned air is supplied to the cold and hot mechanical areas at all levels of the four SBs via a ductwork distribution network. The flow rate to each room is calculated based on the minimum air renewal rate, equipment heat loads and heat balance between the rooms to make sure that ambient conditions are maintained




within prescribed limits for operation of equipment and the safety and comfort of personnel.

The SBVS air supply and exhaust flows are designed to prevent the spread of airborne contamination and to maintain a negative pressure in the hot mechanical areas of the SBs with respect to the outside environment.

The SBVS has two separate modes of exhaust:

� Operational Air Exhaust Mode–The exhaust air (normal exhaust) from all four divisions of the SBs (hot mechanical areas) connects to a single concrete duct in the annulus, which then runs via the FB and connects to the exhaust duct of the NABVS. The exhaust duct of each SBVS train division is equipped with two isolation dampers and one volume control damper. The exhaust air is processed by the NABVS through a filtration train prior to release through the ventplant stack (refer to Section 9.4.3). If high radiation is detected in the SBVS exhaust duct by monitor R-25, the exhaust is diverted to one of the NABVS iodine filtration trains and released through the vent stack.

� Accident Air Exhaust Mode–If airborne contamination is detected in any of the four hot mechanical areas of the SBs or there is a containment isolation signal, the SBVS will automatically direct the exhaust air (accident exhaust) via four separate exhaust air ducts, and each with two parallel isolation dampers, to one common concrete duct in the annulus. This exhaust duct connects to two accident iodine exhaust filtration trains located in the FB. The exhaust air is processed through one of two redundant and independent iodine filtration trains prior to release through the vent plant stack. Each iodine filtration train includes inlet and outlet dampers, moisture separator, two stage electric heater, prefilter, inlet and outlet high efficiency particulate air (HEPA) filters, carbon adsorber, post filter, exhaust fan, and backdraft damper. The fans direct the exhaust air to the ventplant stack.

In case of a fuel handling accident in the FB, the accident exhaust air from these buildingsthe FB fuel pool area is directed and filtered through the SBVS iodine exhaust filtration trains located in the FB, and released through the vent plant stack. (Refer to Section 9.4.2.)

In case of a fuel handling accident in containment, the SBVS can act as backup to the CBVS low flow purge exhaust system (Refer to Section 9.4.7).

In case of containment isolation signal, the SBVS maintains a negative pressure and filters all areas of the FB and the hot mechanical area of the SB in addition to performing the SBVS accident air exhaust filtration function.

The supply and exhaust duct network of the hot mechanical area in the SBs is equipped with isolation dampers to isolate the following areas from the other rooms:

� Rooms where safety injection and residual heat removal system components in divisions one throughand four are installed.




The containment isolation system is addressed in Section 6.2.4.

Refer to Section 12.3.6.5.6 for ventilation system design features which demonstrate compliance with the requirements of 10 CFR 20.1406.

Containment Purge Subsystem

The containment purge subsystem includes low-flow and full-flow purge supply and exhaust systems. See Figure 9.4.7-1—Containment Building Low Flow and Full Flow Purge Supply Subsystem and Figure 9.4.7-2—Containment Building Low Flow and Full Flow Purge Exhaust Subsystem.

The containment low-flow purge subsystem is normally not in operation during the plant normal operation. However, the low-flow purge subsystem can be used during normal operation and outage conditions. The containment full-flow purge subsystem is used during plant outages. The supply side ducts receive air from NABVS (refer to Section 9.4.3) through the Fuel Building (FB) concrete plenum. The supply air is then directed through the containment annulus penetration ducts into the containment plenum which discharges air into the service compartments of the Containment Building. The service compartments include technical rooms, instrument rooms, staircases, tank rooms, annular space at the operating floor, and annular space at the lower level. With the purge subsystem in operation, the air from the service compartments flows into equipment compartments as a result of pressure differential.

The low-flow purge exhaust subsystem contains two redundant filtration trains located in the FB. Radiation monitors are located upstream of the filtration trains for monitoring the containment exhaust air prior to filtration (refer to Section 11.5.3.1.4 and Table 11.5-1, Monitors R-7 and R-8). The filtration trains receive air from the exhaust duct of the low-flow purge exhaust subsystems. The full-flow purge exhaust is directed to the NABVS dDuring a fuel handling accident in the RB, the full flow and low flow purge supply and the full flow purge exhaust containment isolation valves are closed, and low-flow purge exhaust is filtered through the low-flow purge exhaust subsystem filtration trains. The CBVS low flow purge exhaust can also be directed to the safeguard building controlled-area ventilation system (SBVS) iodine filtration trains in an emergency for redundancy (refer to Section 9.4.5). Each filtration train consists of a moisture separator, an electric heater, prefilter, upstream HEPA filters, carbon adsorber, downstream HEPA post filters, and exhaust fan. The exhaust air from the filtration trains is directed to the plant vent stack. The radiation monitor located downstream of the CBVS low flow purge iodine filtration trains monitors and records the release of radioactive contaminants to the vent stack (refer to Section 11.5.3.1.4 and Table 11.5-1, Monitor R-9). The full-flow purge exhaust subsystem directs the containment exhaust air through the NABVS exhaust filtration train (refer to Section 9.4.3).




corresponding emergency diesel generators. Air cooling unit fans stop in the service compartment cooling subsystem.

Fuel Handling Accident in the Containment Building

In the event of a fuel handling accident in the Containment Building, the containment isolation valves on the containment purge subsystem for the full flow and low-flow purge supply and the full flow purge exhaust can be manually closed by pushing the emergency push button located in the fuel handling area inside the Containment Building. The KLA supply air dampers to the equipment hatch area and the KLL exhaust damper at the emergency airlock are closed when the hatch is opened. The low-flow purge exhaust subsystem is used to avoid the spread of contamination by keeping a negative pressure in the Containment Building and filtering the exhaust through the low-flow purge exhaust subsystem iodine filtration trains. To achieve this safety function, the low-flow purge subsystem exhaust is switched over to the iodine filtration trains of the safeguard building controlled-area ventilation system (refer to Section 9.4.5, Section 11.5.3.1.4, Section 11.5.4.8, and Table 11.5-1, Monitors R-10R-7, R-8, R-9). The SBVS iodine filtration trains can be used as backup.

High Pressure Level or Safety Injection Signal

In case of high-pressure level or a safety injection signal, the containment penetration valves on the containment purge subsystem are closed and air flow in the Containment Building is stopped.

Station Blackout

In the event of an SBO, the reactor pit area is air cooled to prevent degradation of the concrete structure. The reactor pit cooling fans take air from the supply air shaft. The air is supplied to the bottom of the pit and transferred through openings in the pit wall around the main coolant piping to maintain a temperature less than 150°F. The power supply to the reactor pit cooling fans is provided by the SBO diesel generators.

Small-Break Loss-of-Coolant Accident and Loss-of-Coolant Accident

In the event of a small-break loss-of-coolant accident (SBLOCA) or loss-of-coolant accident (LOCA), containment isolation valves automatically close after receipt of the containment isolation signal. These valves are designed to perform their isolation function under LOCA conditions and will close within five seconds after receipt of a containment isolation signal from the PACS module.

ELAP

In the event of a loss of all AC power, the low-flow purge exhaust duct may be used to vent the containment. Compressed air is provided to the CI valves to allow them to




before filters. Especially for the containment atmosphere, an additional tritium monitor is used. Releases of radioactivity into compartment air and contamination of the compartment air in the course of plant operation are monitored by this equipment. Airborne radioactivity monitoring serves for personnel protection and overall plant monitoring.

The CBVS low flow purge is described in Section 9.4.7.2. The CBVS monitoring system consists of three sets of detectors at measurement points R-7, R-8, and R-9, which measure gaseous activity in the ventilation system as shown in Figure 9.4.7-2 and Figure 11.5-1. Measurement points R-7 and R-8 are upstream of the filtration trains and point R-9 is downstream of the filtration trains.

The R-7 continuous effluent monitors consist of one noble gas, one iodine, and one aerosol monitors. Effluent grab sample provisions consist of one aerosol sample point. The R-8 continuous effluent monitors consist of one tritium monitor with a beta-sensitive detector and effluent grab sample provisions. The R-9 continuous effluent monitors consist of two noble gas monitors. This monitoring system provides local and control room indication and alarms. This system automatic actions are described in Table 11.5-1.

Measurement ranges of the CBVS monitoring system are shown in Table 11.5-1. The safety classification for the R-7 and R-8 instruments is non-safety. The safety classification for the R-9 instruments is non-safety, augmented quality. Built-in check sources are used to check the detector and instrumentation circuitry to eliminate the need for special containment entries for circuit checks.

11.5.3.1.5 Containment Building Ventilation System (CBVS) - Internal Filtration

The internal filtration subsystem limits the release of radioactive material by reducing radioactive iodine contamination inside the equipment compartment. The CBVS internal filtration is described in Section 9.4.7.2. The CBVS monitoring system consists of three detectors and sample station at measurement point R-10 shown in Figure 9.4.7-3 and Figure 11.5-1. The R-10 continuous process monitors consist of one noble gas, one iodine, and one aerosol monitors. This aerosol monitor is used for RCS leakage detection to satisfy TS 16.3.4.14. Grab sample provisions consist of one aerosol sample point. This monitoring system provides local and control room indication and alarms. This system does not initiate automatic actions.

Measurement ranges of the CBVS monitoring system are shown in Table 11.5-1. The safety classification for the R-10 instruments is non-safety, augmented quality. A built-in check source is used to check the detector and instrumentation circuitry to eliminate the need for special containment entries for circuit checks.


U.S

. EPR

FIN

AL

SAFE

TY A

NA

LYSI

S R

EPO

RT

Tier

2 R

evis

ion

5—

Inte

rim

Pag

e 11

.5-3

0

Cont

ainm

ent B

uild

ing

Low

Fl

ow P

urge

Sub

syst

em

(KLA

2)

Test

#1 4

4Te

st #

076

R-7

none

none

1 no

ble

gas,

1 ae

roso

l, 1

iodi

ne

mon

itor

KLK

10CR

001

KLK

10CR

031

KLK

10CR

071

none

1 ae

roso

l sam

ple

poin

tK

LK10

CR56

1

3E-7

- 1E

-2

μCi/c

c(K

r-85

, X

e-13

3)

3E-1

0 - 1

E-6

μCi/c

c(C

s-13

7)

3E-1

0 - 5

E-8

μCi/c

c

(I-1

31)

n/a

11.5

-19.

4.7-

211

.5.3

.1.4

Non

-saf

ety

built

-in

R-8

none

none

1 H

-3 m

onito

rK

LK12

CR04

1no

neH

-3 sa

mpl

e an

d an

alys

is3E

-9 -

3E-4

μC

i/cc

n/a

n/a

n/a

11.5

-19.

4.7-

211

.5.3

.1.4

Non

-saf

ety

built

-in

R-9

none

none

Clos

e K

LA

supp

ly a

ir

dam

per t

o th

e Fu

el B

uild

ing

hatc

h ar

ea,

whe

n th

e eq

uipm

ent

hatc

h is

open

Clos

e K

LL

exha

ust a

ir

dam

per t

o th

e ar

ea in

fron

t of

the

emer

genc

y ai

rloc

k

Ope

ns K

LA2

iodi

ne

filtr

atio

n iso

latio

n da

mpe

rs, s

tart

s K

LA2

iodi

ne

filtr

atio

n un

it fa

ns

2 no

ble

gas

mon

itors

KLK

13CR

001

KLK

13CR

002

none

none

1E-5

- 1E

0 ra

d/hr

n/a

n/a

n/a

11.5

-19.

4.7-

211

.5.3

.1.4

NS-

AQ

built

-in

Cont

ainm

ent B

uild

ing

Inte

rnal

Filt

ratio

n Su

bsys

tem

(KLA

5) Test

#14

4Te

st #

075

Test

#18

7

R-1

01

nobl

e ga

s, 1

aero

sol6 ,

1 io

dine

m

onito

rK

LK05

CR00

1K

LK05

CR03

1K

LK05

CR07

1

none

none

1 ae

roso

l gra

b sa

mpl

eK

LK05

CR56

1

none

3E-7

- 1E

-2

μCi/c

c(K

r-85

, X

e-13

3)

3E-1

0 - 1

E-6

μCi/c

c(T

e-12

9,

Ru-

106/

Rh-

106)

3E-1

0 - 5

E-8

μCi/c

c (I

-131

)

n/a

11.5

-19.

4.7-

311

.5.3

.1.5

11.5

.4.8

NS-

AQ

built

-in

Tab

le11

.5-1

—R

adia

tion

Mon

itor D

etec

tor P

aram

eter

s S

heet

3 o

f 17

Proc

ess

Syst

em a

nd

Initi

al T

est P

rogr

am10

Rad

M

eas

Pt

Mon

itor P

rovi

sion

s11Sa

mpl

e Pr

ovis

ions

12, 1

4no

ble

gas

H-3

or N

-16

mon

itor

rang

e 13

, 18

aero

sol

mon

itor

rang

e13, 1

8

iodi

ne

mon

itor

rang

e13, 1

8

liqui

d m

onito

r ra

nge13

, 18

Figu

reTe

xtsa

fety

gr

ade

chec

k so

urce

In

-Pro

cess

co

ntin

uous

AC

FIn

-Effl

uent

co

ntin

uous

In-P

roce

ss

sam

ple

In-E

fflue

ntsa

mpl

e

All

indi

cate

d ch

ange

s ar

e in

resp

onse

to R

AI 5

11, Q

uest

ion

06.0

4-9

U.S

. EPR

FIN

AL

SAFE

TY A

NA

LYSI

S R

EPO

RT

Tier

2 R

evis

ion

5—

Inte

rim

Pag

e 11

.5-4

6

Fig

ure

11.5

-1—

Rad

ioac

tive

Efflu

ent F

low

Pat

hs W

ith P

roce

ss a

nd E

fflue

nt R

adia

tion

Mon

itors

All

indi

cate

d ch

ange

s ar

e in

resp

onse

to R

AI 5

11, Q

uest

ion

06.0

4-9



Design Provisions for Minimizing Contamination of the Environment

The filtered exhaust and the negative differential pressures with respect to the environment produced by the CBVS, AVS, FBVS, SBVS, NABVS, and RWBVS provide the primary protection against contamination of the environment. During normal operation, these ventilation systems produce a sub-atmospheric pressure in their ventilated zones and filter the air from these zones for removal of potential contaminants prior to release to the environment via the vent stack. The AVS provides isolation of the secondary containment and collects containment building leakage. Following a design basis accident, the AVS removes particulates from the contaminated air prior to release to the environment. The normal exhaust from the CBVS, FBVS, AVS, and SBVS are processed by the NABVS through a filtration train and the exhausted air is directed to the vent stack. The RWBVS draws air from locations in the Radioactive Waste Building where radioactivity is likely, and also collects air from activity-bearing systems, vented tanks, and work areas and machinery which may produce airborne releases.

Upon receipt of a containment isolation signal or a high radiation alarm in the mechanical areas of the Safeguard Buildings, the SBVS is isolated from its supply and the NABVS exhaust system, directing its exhaust air through the SBVS activated charcoal filtration beds located in the FB prior to release to the environment through the vent stack. Similarly, upon receipt of a containment isolation signal, the FBVS is isolated from the NABVS and the exhaust is processed through these same filtration trains of the SBVS. A containment isolation signal also isolates the normal operation trains from the NABVS and starts the AVS accident trains to draw a negative pressure in the annulus and filter the exhaust air through activated charcoal filtration beds located in the FB prior to release to the environment through the vent stack. The containment isolation signal also causes the CBVS to automatically isolate the containment atmosphere by quick closure of the system containment isolation valves to maintain the integrity of the containment boundary and to limit the potential release of radioactive material to the environment. The CBVS confines the containment volume and removes iodine released in the event of a fuel handling accident in the RB, The SBVS supply and exhaust duct network for the hot mechanical areas in the Safeguard Buildings are equipped with isolation dampers to isolate these areas during design bases accident conditions. SBVS also confines the volume of the fuel hall by maintaining negative pressure and removes iodine released in the event of a fuel handling accident in the FB. SBVS also confines the containment volume and removes iodine released in the event of a fuel handling accident in the RB. During fuel handling operations, a controlled and monitored ventilation system removes gaseous radioactivity from the atmosphere above the spent fuel pool and processes it through high efficiency particulate air (HEPA) filters and charcoal adsorber units of NABVS.


U.S

. EPR

FIN

AL

SAFE

TY A

NA

LYSI

S R

EPO

RT

Tier

2 R

evis

ion

5—

Inte

rim

Pag

e 1

2.3-

78

Fuel

Bui

ldin

g(F

igur

e12

.3-7

3)(c

ontin

ued)

1 ga

seou

s iod

ine

mon

itor (

R-7

) in

ex

haus

t air

of c

onta

inm

ent

vent

ilatio

n(u

pstr

eam

KLA

2 fil

ters

)

---

5E-4

– 3

E+0

μCi

3E-1

0 –

5E-8

μCi

/cc

(I-1

31)

Mus

t be

capa

ble

of d

etec

ting

10

DA

C-ho

urs

1 tr

itium

mon

itor (

R-8

) in

exha

ust a

ir

of c

onta

inm

ent v

entil

atio

n(u

pstr

eam

KLA

2 fil

ters

)

---

3E-9

– 3

E-4

μCi/c

c(H

-3)

2 n

oble

gas

mon

itors

(R-1

9) a

ir

leav

ing

fuel

han

dlin

g ar

ea a

djac

ent t

o m

onito

red

air d

uct

(Fue

l han

dlin

g ar

ea)

Ref

er to

Tab

le11

.5-1

, M

onito

r R-1

91E

-5 –

1E+

0 ra

d/hr

Mus

t be

capa

ble

of d

etec

ting

10

DA

C-ho

urs

2 no

ble

gas m

onito

rs (R

-9) i

n ai

r le

avin

g co

ntai

nmen

t (ne

xt to

air

du

ct) d

owns

trea

m K

LA2

low

flow

pu

rge

exha

ust

Ref

er to

Tab

le11

.5-1

, M

onito

r R-9

1E-5

– 1

E+0

rad/

hr

2 no

ble

gas a

ccid

ent m

onito

rs (R

-27)

in

exh

aust

air

from

exh

aust

cel

l (d

owns

trea

m K

LB a

ccid

ent e

xhau

st

filte

r)

Ref

er to

Tab

le11

.5-1

, M

onito

r R-2

71E

-4 –

1E+

4 ra

d/hr

2 no

ble

gas a

ccid

ent m

onito

rs (R

-26)

in

exh

aust

air

from

exh

aust

cel

l (d

owns

trea

m K

LC a

ccid

ent e

xhau

st

filte

r)

Ref

er to

Tab

le11

.5-1

, M

onito

r R-2

61E

-4 –

1E+

4 ra

d/hr

Safe

guar

d Bu

ildin

g(F

igur

e12

.3-7

2 )(F

igur

e9.

4.1-

1)4

mon

itors

(R-2

9 an

d R

-30)

inta

ke a

ir

of th

e M

CRR

efer

to T

able

11.5

-1, F

ootn

ote

19 fo

r Mon

itors

R-2

9 an

d R

-30

1E-5

– 1

E+1

rad/

hrM

ust b

e ca

pabl

e of

det

ectin

g 10

D

AC-

hour

s

Tab

le12

.3-4

—A

irbor

ne R

adio

activ

ity D

etec

tor P

aram

eter

s S

heet

2 o

f 4

Mon

itor L

ocat

ion

Mon

itor P

rovi

sion

sR

ange

1In

-Pro

cess

Con

tinuo

us

AC

F

All

indi

cate

d ch

ange

s ar

e in

resp

onse

to R

AI 5

11, Q

uest

ion

06.0

4-9

SBVS 3.7.12

U.S. EPR GTS 3.7.12-3 Interim Rev. 5

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE

FREQUENCY

SR 3.7.12.98 Verify each SBVS recirculation cooler has the

capability to remove the design heat load.

24 months

SR 3.7.12.10 Verify Safeguard Building and Fuel Building structural

integrity by performing a visual inspection of the exposed interior and exterior surfaces of the Safeguard Building and Fuel Building.

During shutdown for SR 3.6.1.1 Type A tests


Shield Building B 3.6.6

U.S. EPR GTS B 3.6.6-1 Interim Rev. 5

B 3.6 CONTAINMENT SYSTEMS B 3.6.6 Shield Building BASES BACKGROUND The shield building is a concrete structure that surrounds the

Containment Building. Between the Containment Building and the shield building inner wall is an annular space that collects containment leakage that may occur following a loss of coolant accident (LOCA). This space also allows for periodic inspection of the outer surface of the Containment Building. The Annulus Ventilation System (AVS) establishes a negative pressure in the annulus between the shield building and the containment building. Filters in the system then control the release of radioactive contaminants to the environment. The description of the AVS is provided in the Bases for Specification 3.6.7. The shield building is required to be OPERABLE to ensure retention of containment leakage and proper operation of the AVS in the event of a Design Basis Accident. To ensure the retention of containment leakage within the Containment Building: a. The door in each access opening is closed except when the access

opening is being used for normal transit entry and exit; and b. The sealing mechanism associated with each penetration (e.g., welds,

bellows, or O-rings) is OPERABLE. As discussed in Reference 1, the shield building, portions of the safeguard buildings, and the fuel building are maintained at a negative pressure in order to process any post-accident containment leakage through filters in the AVS and the Safeguard Building Controlled Area Ventilation System (SBVS).

APPLICABLE The design basis for shield building OPERABILITY is a LOCA. SAFETY Maintaining shield building OPERABILITY ensures that the release of ANALYSES radioactive material from the containment atmosphere is restricted to

those leakage paths and associated leakage rates assumed in the accident analyses. The shield building satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).


Shield Building B 3.6.6


BASES SURVEILLANCE REQUIREMENTS (continued)

that all fission products released to the annulus are treated, SR 3.6.6.3 and SR 3.6.6.4 verify that a pressure in the annulus that is less than the lowest postulated pressure external to the shield building boundary can be established and maintained. When the AVS System is operating as designed, the establishment and maintenance of annulus pressure cannot be accomplished if the shield building boundary is not intact. Establishment of this pressure is confirmed by SR 3.6.6.3, which demonstrates that the annulus can be drawn down to a pressure of � -0.25 inches wg using one AVS train. SR 3.6.6.4 demonstrates that the annulus can be maintained at a pressure of � -0.25 inches wg using one AVS train at a flow rate � 1295 cfm. The primary purpose of these SRs is to ensure annulus boundary integrity. The secondary purpose of these SRs is to ensure that the AVS train being tested functions as designed. There is a separate LCO with Surveillance Requirements which serves the primary purpose of ensuring OPERABILITY of the AVS System. These SRs need not be performed with each AVS train. The AVS train used for these Surveillances is staggered to ensure that in addition to the requirements of LCO 3.6.7, either safety AVS train will perform this test. The inoperability of the AVS System does not necessarily constitute a failure of these Surveillances relative to the shield building OPERABILITY. Operating experience has shown the shield building boundary usually passes these Surveillances when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.6.6.5 This SR would give advance indication of gross deterioration of the concrete structural integrity of the Shield Building. The Frequency of this SR is the same as that of SR 3.6.1.1. The verification is done during shutdown.

REFERENCES None.1. FSAR Section 6.2.6.5.


SBVS B 3.7.12


BASES BACKGROUND (continued)

HEPA filter is not credited in the analysis, but serves to collect carbon particles and provides a backup in case the upstream HEPA filter bank fails. The prefilters and moisture separator removes any large particles in the air and any entrained water droplets present to prevent excessive loading of the HEPA filters and carbon adsorbers. In case of a LOCA with assumed ECCS leakage, the accident air exhaust from the safeguard building controlled areas and fuel building is also directed through the accident iodine exhaust filtration trains prior to release through the vent stack. The SBVS accident iodine filtration train is a standby system which may also be operated during normal plant operations. Upon receipt of an actuating signal, the normal air exhaust from the buildings is isolated and the accident air is redirected through the iodine filtration train. The SBVS is discussed in FSAR Section 9.4.5 (Ref. 3). As discussed in Reference 8, the shield building, portions of the safeguard buildings, and the fuel building are maintained at a negative pressure in order to process any post-accident containment leakage through filters in the Annulus Ventilation System (AVS) and the SBVS.

APPLICABLE The SBVS design basis is established by the consequences of the SAFETY limiting postulated accident, which is a LOCA with assumed ECCS ANALYSES leakage. The analysis of a LOCA, given in Reference 4, assumes ECCS

leakage to the safeguard building controlled areas and fuel building is a conservative four gallons a minute. The SBVS consists of two 100% capacity iodine filtration trains in parallel configuration. There are only two iodine filtration trains since only slow failure modes are assumed and filtration efficiency is checked periodically. Both sets of iodine filtration trains are required to be OPERABLE. One SBVS train is then assumed to be lost due to a single failure. The postulated accident analysis assumes that two trains of the SBVS are OPERABLE. The accident analysis accounts for the reduction in airborne radioactive material provided by the one train of this filtration system. The amount of fission products available for release from the safeguard building controlled areas and fuel building is determined for a LOCA. These assumptions and the analysis follow the guidance provided in Regulatory Guide 1.25 (Ref. 5). The SBVS is not credited in the Fuel Handling Accident evaluation. The SBVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).


SBVS B 3.7.12


BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.12.98 This SR verifies that the SBVS recirculation coolers that cool the hot mechanical areas are capable of removing the design heat load assumed in the safeguards building heat load calculation. This SR consists of a combination of testing and calculations. The 24-month Frequency is appropriate since significant degradation of the SBVS is slow and is not expected over this time period. SR 3.7.12.10 This SR would give advance indication of gross deterioration of the concrete structural integrity of the safeguard buildings and the fuel building. The Frequency of this SR is the same as that of SR 3.6.1.1. The verification is done during shutdown.

REFERENCES 1. FSAR Section 9.4.6. 2. FSAR Section 9.4.3. 3. FSAR Section 9.4.5. 4. FSAR Chapter 15. 5. Regulatory Guide 1.25, March 1972. 6. 10 CFR 50.34. 7. Regulatory Guide 1.52, Rev. 3, June 2001. 8. FSAR Section 6.2.6.5.


2013/05/17 Areva EPR DC - Response to U.S. EPR …2013 to provide technically correct and complete...

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Transcript of 2013/05/17 Areva EPR DC - Response to U.S. EPR …2013 to provide technically correct and complete...