ML17275B003
| ML17275B003 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/08/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Ferguson R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 8104200536 | |
| Download: ML17275B003 (21) | |
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Docket No.:
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Washington Public Power Supply System ATTN:
her.
R. L. Ferguson hlanaging Director 3000 George Washington Way
- Richland, Washington 99352
Dear hlr. Ferguson:
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DISTRIBUTION:
Pocket Fi-1e~s LB81 Rdg DEisenhut BJYoungblood DLynch MRushbrook RTedesco RVollmer TMurley DRoss RHartfield, MPA VNoonan OELD OIE (3)
BClayton bcc:
TERA NRC/PDR L/PDR NSIC TIC ACRS (16)
Subject:
Request for Additional Information Regarding the Initial Test Program for the WHP-2 Facility In the course of our review of your applciation for an operating license for the WHP-2 facility, we have identified a need for additional information regarding your initial test program.
This request is contained in the enclosure
=and represents our second round of questions on this subject.
We request that your respond with the additional information by July of this year so that we can maintain our present schedule for issuing our SER in March 1982.
If you have any questions on this matter, please contact M. D. Lynch at 301/492-8413 or L. Rib at 301/492-8174.
Sincerely,
~i%I signed by 8050K% Igy TQQU8~i
Enclosure:
As stated Robert L. Tedesco, Assistant Director for Licensing Divjsion of Licensing cc:
See next page
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NRC FORM 318110/801NRCM 0240 OFFICIAL RECORD COPY o USGP0; 1980-329-824
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R. L. Ferguson Hanaging Director Was'hington Public Power Supply System.
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Box 968
,3000 George Washington Way
- Richland, Washington 99352 ccs Nicholas Reynolds, Esq.
Debevoise
& Liberman 1200 Seventeenth
- Street, N.
W.
Washington, D.
C.
20036 Richard Q. Quigley, Esq.
Washington Public Power'upply System P.
0.
Box 968
, Richland, Washington 99352 4
h Nicholas Lewis, Chairman Energy Facility Site Evaluation Council 820 East Fifth Avenue Olympia, Washington 98504'r.
0.
K. Earle Licensing Engineer P. O..Box 968
- Richland, Washington 99352 Hr. Albert D. Toth Resident Inspector/HPPSS-2 NPS c/o U., S. Nuclear Regulatory Commission P. 0. Box,69
- Richland, Washington 99352 1'
423.30 Our review disclosed that several of your star tup test descriptions are not acceptable.
Accordingly, modify the individual test abstracts
's indicated below.
1.
Some of the test descriptions are missing Level 1 or Level 2
criteria.
Accordingly, add the missing criteria.
Alternatively, if they are not applicable, so state.
The startup tests which are missing Level 1 criteria are Numbers 11, 18, 28 and 22.
The tests missing Level 2 criteria are Numbers 1, 2, 3, 6, 10, 19 and 20.
2.
For Full Core Shutdown Margin Startup Test ¹4, expand the Level 1 criteria to specify the temperature conditions for the shutdown margin calculation.
State how the exposure dependent correction factor will be used to correct the shutdown margin if the deter-mination of the margin is made at some time during the cycle other than the most reactive time.
3.
For Control Rod Drive System Startup Test ¹5:
a.
Expand the test procedure description to state that at reactor pressures below the design value, scram times must not exceed those at the design pressure value.
Alternatively, provide the bases for the less conservative acceptance criteria.
b.
Provide justification for your proposal to perform the friction test only for the four slowest control rod drives (CRD) at rated reactor pressure.
Alternatively, revise the table in this test procedure to indicate that all CRDs will be included in the friction test.
4.
In your response to Item'23.21, D.2.o, Rod Sequence Exchange r~
Startup Test ¹8, you state that the rod pattern exchange demonstration will not be conducted since it does not approach any safety margin or operating limit.
Modify Section 14.2.7.2 of the FSAR to incor-porate and justify this exception, or propose such a startup test.
The test, if included, should demonstrate that core limits will not be exceeded during or following an exchange of control rod patterns which will be permitted during reactor operation.
Our position is that the demonstration test should be conducted at the highest power level at which control rod pattern exchanges will be allowed during plant operation.
This includes fuel con-ditioning thermal limits.
5.
Water Level Reference Leg Temperature Measurement Startup Test ¹9:
a.
Modify the description section of this test to explain why a fifth level instrument (i.e., the upset range) is included in a list of "four" such systems.
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b.
Rewrite the Level 2 criteria to combine and clarify the repetitive tolerances on narrow and wide range level system indicator readings.
6.
With respect to RCIC System Startup Test 814, we requested in Item 423.23b that you modify the RCIC test abstract to provide for five cold, quick starts of this system.
However, your revised description section does not clearly indicate that five such cold, quick starts will be conducted.
Accordingly, rewrite the description section of this test to include a
summary of the cold starts as originally requested in Item 423.23b.
7.
For Feedwater System Startup Test 823:
a.
Expand the test description to indicate which simulations, if any, will be performed before the test to verify the runback capability of the recirculation system.
b.
Your response to Item 423.23h is not completely acceptable.
Expand the test description to describe how the heater loss will be affected.
Verify that this is the limiting heater loss that could result from a single equipment failure or single operator error.
Verify that the Level 2 acceptance criteria for system response to setpoint changes are based on expected perform-ance for the actual test conditions.
c.
Expand the test description to demonstrate that the maximum feedwater runout capability does not exceed the value you assumed in the FSAR.
d.
Expand the acceptance criteria to specify the required dynamic flow response of each feedwater actuator (i.e., turbine or valve) to small and large step disturbances.
e.
Expand the acceptance criteria to include the allowable water level margin to scram for a feedwater pump trip initiated at 100 percent power conditions.
8.
For Turbine Valve Surveillance Startup Test 824, modify the test description and acceptance criteria to measure bypass valve capacity and ensure that it is within the value you assumed in the accident analysis of bypass failure.
9.
Main Steam Isolation Valves Startup Test 825:
a.
The present method for determining main
'steam isolation valve (MSIV) closure times is inaccurate.
Accordingly, modify the test method to measure the full travel of the valves.
Alternatively, provide technical justification for extrapolating the full closure time when only measuring 90 percent of that value.
If the measurement is to based on 90 percent travel, calculate the MSIV closure time
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as equal to the interval from deenerginzing the solenoids until the valve reaches 90 percent closed, plus the time from 10 percent closed to 90 percent closed divided by 8.
Alternatively, provide technical justification for the current method which "double-counts" delay time.
b.
Since the stated purpose of this test is to functionally check the MSIV's for proper operation, provide a description of a test which demonstrates that the MSIV leakage control system components operate properly when handling steam and that the system can handle the amount of leakage that is present when the main steam system is at operating temperature and pressure.
10.
For Relief Valves Startup Test 826, your proposed Level 1 acceptance criteria states that the sum of the capacity measurements from all relief valves shall be equal to or greater than the rated capacity
(+2 percent, corrected for an inlet pressure of 1112 psig) is very rigorous considering the expected individual tolerances noted in the Level 2 criteria (i.e.,
90 to 135 percent).
Clarify this apparent discrepancy or provide further information about actions to be taken if this particular Level 1 criterion is not met.
11.
Turbine Trip and Generator Load Rejection Startup Test 0'27:
a.
Your response to Item 423.23k is not completely acceptable.
Accordingly, modify the test description to require that both turbine throttle valve trips and the main generator breaker trips are conducted at full rated power.
Alternatively, provide technical justification which shows that the purpose of this
'test can be met without accomplishing both full power trips.
In this regard, we could accept as a sufficient technical justification your statement that the turbine trip would be initiated directly by all remote manual openings or automatic trips of the generator main breaker (i.e.,
a direct electrical
- signal, not a secondary effect such as turbine overspeed).
The method used for opening the main generator breakers by simu-lating an automatic or manual trip should be selected so that the turbine-generator will be subjected'o the maximum credible overspeed condition.
b.
Modify Tables 14.2-2 and 14.2-4 of the FSAR to clearly indicate the status of the turbine trip and generator load rejection tests per your response to Item 423.23a.
12.
Your test description in Shutdown from Outside the Main Control Room Startup Test 828, implies that the reactor scram and MSIV isolation will be performed from inside the control room.
It is our position that all actions in this test be initiated from outside the control room.
Accordingly, modify your test description to comply with our position on this matter.
Additionally, modify your test description to clearly state that you will initiate the shutdown cooling mode
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, of the reactor heat removal (RHR) system outside the control room and use it to partially cool down the plant while outside the control room.
I 13.,Your response-,to Item 423.21, 0.2.r, regarding Recirculation System Startup Test 830, indicates that a simultaneous trip of
'oth recirculation pumps is not performed at 100 percent of rated power.
You state, in Section 15.3.1 of the FSAR that your analysis of this event indicates there is not any decrease in the minimum critical power ratio (MCPR) and, therefore, it does not involve an approach to any safety margin or operating limit.
- However,
. in'he startup test description, you state that a simultaneous trip of both recirculation pumps without transfer to LFMG set power supply will be made near rated flow and power level conditions.
In, contrast, you indicate in Table 14.2-4 that the two pump trip is scheduled for TC-3 (i.e., at 50 to 75 percent power and 80 to 100 percent flow).
Accordingly, modify Section 14.2.7.2 to incorporate and justify this exception.
Alternatively, include a simultaneous trip of both recirculation pumps test at TC-6.
14.
For Loss of Turbine-Generator and Offsite Power Startup Test 831, modify your test description to:
a.
Provide assurance that the condition representing a loss of offsite power will be maintained for a least 30 minutes to demonstrate that the equipment, including controls and appropriate
/indication, necessary to remove decay heat from the core using only emergency power supplies and distribution systems are available following a station blackout.
b.
Verify that your acceptance criteria include proper start and load times for the diesel generators.
16.
Cooling Water Systems Startup Test f73:
t a.
Modify the acceptance criteria in this test to state whether they are Level 1 or Level 2.
Revise your test description to ensure that criteria which are not applicable are so 1 abel 1 ed.
b.
Include the standby service water (SSW) system in an expanded test description.
Alternatively, provide technical justification for not testing that system.
423-17 c.
Verify that the reactor pressure acceptance criterion is based on a realistic prediction of the test conditions.
15.
Modify your test description in Residual Heat Removal System Startup Test 871 to specify the mimimum power level at which the test will be conducted.
Indicate how power history and test scheduling will be coordinated to adequately demonstrate the heat exchanger capacity.
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17.
In Off-gas System Startup Test f74, your test description states that if sufficient, measurable radioactive gases from direct fission products and radioactivity from fission daughter products are present in the off-gas, decontamination factors across several charcoal beds will be determined.
Expand your test description to state how the decontamination factors will be determined if sufficient levels of radioactivity are not attained.
Provide or modify those test descriptions which will verify that:
(1) the plant's ventilation systems are adequate to maintain all engineered safety feature (ESF) equipment within its design temperature range during normal operations; and (2) the emergency ventilation systems are capable of maintaining all ESF equipment within their design temperature range with the equipment operating in a manner that will produce the maximum heat load in the compartment.
If it is not practical to produce maximum heat loads in the compartment, describe the methods that will be used to verify the design heat removal capability of the emergency ventilation systems.
In this regard, you should note that it is not apparent that post-accident design heat loads will be produced in ESF equipment rooms during the power ascension test phase.
Accordingly, simply determining that area temperatures remain within design limits during this period will probably not demonstrate the design heat removal capability of these systems.
Accordingly, it will be necessary to include in your test procedures measurements of air and cooling water temperatures and flows, including your extrapolations which you will use to verify that th'e ventilation systems can remove the postulated post-accident '-
heat loads.
Modify Figure 14.2-4 or Section 14.2.12 of the FSAR to correct the items noted below:
1.
The CRD Installation Equipment System Preoperational Test listed in this figure is not described in Section 14.2.12.1 while several test descriptions listed in that section are not contained in this figure (i.e., Sections 14.2.12.1.2,
-.3, -.15, -.17, and -.30).
2.
The test phase of the 480 Volt Distribution System Preoperational Test is not shown being accomplished concurrently with the testing phases of the 230/115 KV, 6.9 KV, and 4.16 KV distribution system although they are all tested during the same test (i.e.,
Loss of Power and Safety Testing Preoperational Test 837).
Reference the test conditions of Table 14.2-2 and Table 14.2-3 of the FSAR to those regions defined in Figure 14.2-3.
The test titles in Table 14.2-3 do not correspond to those listed in Section 14.2.10.3(12).
Correct the title listing inconsistencies.
Provide preoperational test descriptions to verify that each ESF pump operates in accordance with the manufacturer's head-flow curve.
Alternatively, modify the existing descriptions.
In responding to this
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- request, incl in the test description the ba s for the acceptance criteria.
Our position is that the bases you provide should consider both flow requirements for ESF functions and the net positive suction head (NPSH) requirements of the pumps.
I Your response to Item 423.8c is not acceptable.
The staff position in Section c.8 of Regulatory Guide 1.68 states in part that "... hold points should be established...to ensure that relevant test results are evaluated and approved...prior to progressing with the power-ascension test phase".
Provide justification for not complying with this staff guidance or propose an acceptable procedure.
Alternatively, modify Section 14.2.5.3 of the FSAR to reflect our guidance on this matter.
In your response to Item 423.11, you state that both preoperational and startup tests are under the direction of a test engineer.
Our position is that you should modify the minimum qualifications for a test engineer stated in Section 14.2.2. 10 of the FSAR to match those of individuals who direct or supervise the conduct of individual startup tests as outlined in Item 423.11.
Provide a reference for Figure 14.2-6 of the FSAR.
Indicate the units applicable to the horizontal axis.
Figure 14.2-2 of the FSAR shows your test and startup organization which includes the test group supervisor position.
Modify Section 14.2.2.3.3 to include a description of the test group supervisor's responsibilities.
Your response to Item 423.13g is not acceptable.
Accordingly, modify the Reactor Protection System Preoperational Test to account for the delay time of process-to-sensor hardware (e.g.,
instrument lines,
- valves, flow limiters) in your testing of response time.
Modify the test description to state how you will account for this delay time.
Also, modify Test Procedure Item c of this test description to make it clear that your peroperational test will include all channels of each trip function for which response time tests are required by the Technical Specifications.
Figure 14.2-3 of the FSAR requires modification to improve its read-ability and use in conjuction with the startup test descriptions.
Accordingly:
1.
Modify the description for TC-1 to indicate the percent power boundaries, shown in this figure as approximately 5 to 20 percent.
2.
Label the following:
(a) the 50 percent Rod Line; (b) the Analytical Lower Limit of Master Power Flow Co'ntrol (E);
and (c) the Analytical Upper Limit of Master Power Flow Control (F).
3.
Label and provide definitions for the maximum allowable core flow lines.
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4.
Your operating license will not allow operation at a power level greater than the rated thermal power.
Accordingly, modify your definition of Test Conditi'on 7 And locate this test condition on the map.
Your response to certain portions of Items 423.19 and 423.20, regarding compliance with certain items of Regulatory Guides 1.41, 1.68, 1.80, and 1.108, is not acceptable.
Accordingly, provide the information requested below or provide test descriptions of the equivalent alternative testing that will be performed.
1.
Regulatory Guide 1.41:
I a.
Verify that all sources of power supply to vital buses are full-load tested.
b.
Verify that testing is conducted with only one power source
, at a
time.'.
Verify that buses not under test are monitored to ensure the absence of 'any voltage.
2.
Regulatory Guide 1.68:
a.
Provide a test description for the chemical control system (1.b(2)).
b.
Provide testing using air to verify that containment spray
- nozzles, headers, and piping are free of debris and verify that this air testing overlaps the tests for obstructions done with water (1.h(3)).
c.
.Provide a preoperational test description for the containment combustible gas control system (1.h(4)) which will serve:
i.
To demonstrate the capability of the combustible gas control system to operate in response to post-LOCA requirements.
ii.
To demonstrate that the post-LOCA hydrogen monitors function properly.
iii.
To demonstrate the operability of the vacuum breakers.
d.
Provide a preoperational test description of a test of containment penetration coolers.
On those penetrations where coolers are not used, provide a startup test description which will demonstrate that concrete temperatures surrounding hot penetrations do not exceed design limits (1.i(21)).
Provide a test description for seismic instrumentation (1.>(10)).
423-20
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f.
Modify the Reactor Building Crane Preoperational Test (¹53) to include static testing at 124 percent of rated load and full operational testing at'100 percent of rated load (1.m(4),
1.o(1)).
g.
Modify the Standby Service Water System Preoperational Test to demonstrate adequate net positive suction head (NPSH) and the absence of vortexing over a range of basin levels from the maximum level to the minimum level calculated to occur 30 days following'a postulated LOCA.
Verify that the overflow lines are unobstructed(1.n(1)).
h.
Modify the Radwaste Building HVAC System Preoperational Test
(¹30) to verify that the radwaste building is maintained at a slightly negative pressure and that the air-flow patterns are such that air will flow from relatively clean areas to areas of progressively greater contamination potential (1.n. (14)(e) ).
Verify operability of the solid liquid radwaste system by testing with representative chemical waste streams.
The acceptance criterion for the solid radwaste system should require that there be no free liquid in the solidification sample (5.c.c).
3.
Regulatory Guide 1.80, Positions c.(8),
(9) and (10):
Modify the Primary Containment Instrument Air Preoperational Test
(¹34) or describe other tests to show conformance with the loss-of-air testing requirements of this guide.
Alternatively, propose acceptable procedures.
4.
Regulatory Gude 1.108, Positions c.2.1(3), (5), (9), and c.2.b:
Modify the Standby AC Power System Preoperational Test (¹43) to address the full-load carrying capacity, the capacity at full-load temperature, the consecutive valid starts, and the redundant starting requirements of this guide.
Alternatively, propose acceptable procedures.
423.42 The startup test program described in Table 14.2-4 of the FSAR is not acceptable.
Accordingly, modify Table 14.2-4 as follows:
1.
Incorporate lines bracketing tests to aid in determining which symbols refer to which test conditions.
2.
The markedtest conditions for STI ¹5, reference note 2 which states that test 5 should be done at test conditions 5 (STI ¹27) and 2 (STI ¹31), neither of which are given in STI ¹5.
Modify these notations to remove this discrepancy.
3.
Label STI-7, STI-8, and STI-32 "Not Applicable>" as is STI ¹15.
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l 4.
Modify STI-16 such that the appropriate measurement is made at 100 percent core flow as stated in the test description.
Correct all typographical errors.
5.
Modify STI-17 to reference pre-heatup conditions when initial measurements are made, and TC ¹6 which would represent the extreme steady-state condition.
6.
7.
STI-25 states that a simultaneous full closure of all MSIVs will be conducted at approximately 100 percent.
Remove note 10 which indicates the test may be performed at 75 percent power.
Also, "0" should be "8".
8.
STI - 27 "BP" should probably be "SP".
9.
STI-30 on Table 14.2-4 references TC-1 (Refer to the definition on Figure 14.2-3).
10.
STI-35 states that flow calibration is made at TC-2, between TC-2 and TC-3, at TC-3, at TC-5, between TC-5 and 6, and at TC-6.
Modify STI-35 if this is not the intended calibration schedule.
11.
STI-36 through STI-69 should be labelled "Not Applicable" if that is the intention.
12.
Consideration should be given to performing STI-71 at TC-6, in light of decay heat load problem (Refer to page '14.2-145).
13.
The test description for STI-73 states that data will be taken following intial heatup (add TC-1) and at selected power levels (add TC-3).
14.
Modify Table 14.2-4 to include or delete the followi'ng unassigned notes. ¹1, ¹9, ¹11, SE.
15.
Note 1 "14.2-1" should be "14.2-3".
423-22
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