ML18017C016

Forwards Amend 4 to FSAR

ML18017C016
Person / Time
Site:	Harris
Issue date:	08/31/1982
From:	Mcduffie M CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
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ML18017C017	List: ML18017C016
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NUDOCS 8209080197
Download: ML18017C016 (23)

Text

r REGULA T INFORMATION DISTR I BUT IO'STEM (R IDS)

ACCESSIOIV NBR: 8209080197 DOCI-DATE: 82/08/31 NOTAR'IZED':

YES FACIL:50-400 Shear ont Har ri s Nucl ear Power Pl anti Uni tr li Carol-ina 50-401 Shearon Harri s Nuc1 ear Power Pl anti Uni t 2i Carol tine<

AUTH.NAMEl AUTHOR AFFiILKAT ION MCDUFFiIEi'.M.A; Chroiliina Pbwer L L'ight Coi.

RECIP'.NAME RECtIPtIEIVTA AFFLLiIATION DENTONiH RE Office oift Nuclea'r Reactor Regulate oni Director" DOCKET 05000401r

SUBJECT:

Foraards Amend 0 tot FSAR.

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CXQE, Carolina Power & Light Company August 31, 1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C.

20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NOS.

1 AND 2 DOCKET NOS.

50-400 AND 50-401 FSAR AMENDMENT 4

Dear Mr. Denton:

Caroli'n'a'ower

& Light Company (CP&L) hereby:transmits-;three~;(3) originals and sixty (60) copies of Amendment No.

4 to the Final Safety Analysis Report (FSAR).

This information is being submitted in response to NRC letters dated May 7, and June, 14, 1982.

Included are the CP&L responses to the Quality Assurance (260 Series),

and the Initial Test Program (640 Series) questions.

Of the original (504)

NRC Safety Review Questions, 304 were answered on August 2, 1982; 104 are addressed in the attached Amendment No.

4 and the remaining 96 will be addressed in a separate letter by August 31, 1982.

As agreed in the July 15-16, and July 28, 1982 NRC/CP&L meetings, the 260 and 640 series questions have been answered in the form of an FSAR amendment, and submitted prior to August 31,

1982, so issuance of the Draft Safety Evaluation Report should suffer no delay.

Attachment Nos.

1 and 2 are indices to the responses for the Quality Assurance (260 Series) and Initial Test Program (640 Series) questions, respectively.

Also attached is Amendment No. 4.

Each revised page bears the amendment number.

Only those changes which are technical in nature are indicated by vertical bars.

Instructions for entering the revised pages are included.

8209080197 82083i PDR ADOCK 05000400 ville Street o P. O. Box 1551 e Raleigh, N. C. 2y602 K

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Harold R. Denton August 31, 1982 As required by Commission Regulations, this Amendment is signed under oath by a duly authorized officer of CP&L.

Yours very truly,,

M. A. McDuffie Senior Vice President Engineering 8 Construction PS/lr (3003C4T3)

Attachment cc:

Mr. E. A. Licitra (w/o att.)

Mr. G. F. Maxwell (NRC-SHNPP)

Mr. J. P. O'Reilly (NRC-RII)

(w/o att.)

Sworn to and subscribed before me this My commission expires:

October 4, 1986 Notary (Seal)pi<

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ATTACHMENT No.

1 INDEX TO CP&L'S RESPONSES TO NRC QUESTIONS ON SECTION 17.2 OF THE FSAR Question No.

Response

260. 1 Section 17.2.1 cross-references Section 13.1 which provides detailed organization charts of organizational elements which function under the cognizance of the QA program.

Figures 17.2.1-1 and 17.2.1-2 provide additional details in this area including designation of "onsite" and "offsite" organizational elements.

260.2 260.3 Revised Section 17.2.1 'addresses this question.

The QA and QC responsibilities of each of the organizational elements noted in the organization charts provided in Sections 13.1 and 17.2 are described in Sections 13.1 and 17.2.1.1.

Section 17.2.1 cross-references Section 13.1 for details on the CP&L organization responsible for the safe operation of the SHNPP.

260.4 260.5 Revised Section 17.2.1 addresses this question.

Inconsistencies between Sections 13 and 17 are reconciled in Amendment 4.

260.6, 7

8$

17

& 20 Revised Section 17.2.2.1 addresses these questions.

The response to question 260.51 resolves the issue addressed by question 260.6 regarding inspections performed by other than QA.

260.9

& 11 A new paragraph added to Section 17.2.1.1 addresses these questions.

260.10 260.12 260.13 Revised Section 17.2.1.1 addresses this question.

Revised Section 17.2.1.1 addresses this question.

The new Section 17.2.2-4, titled "Computer Codes",

addresses this question.

260.14 260.15 260.16 The new Section 17.2.19 addresses this question.

Revised Section 17.2.2.1 addresses this question.

Revised Section 17.2.11, as a result of question 260.10, addresses this question.

260.18 Revised Sections 17.2.1.1 and 17.2.2.1 address this question.

260.19 A new paragraph added to Section 17.2.1.1 addresses this question.

260.21 A new paragraph added to Section 17.2.2.2 addresses this question.

260.22 A new paragraph added to Section 17.2.2.i addresses this question.

260.23 260.24 Revised Section 17.1 addresses this question.

This question is addressed in revised Section 13.1.2.

Review and approval of procedures are addressed in Section 13.5.

System descriptions are handled in a similar manner to procedures.

260.25 260.26 Revised Section 17.2.3.1 addresses this question.

Revised Section 17.2.3 partially addresses this question.

QA is not in the review cycle for design drawings however the process of drawing development and review is audited by QA.

260.27 260.28 Revised Section 17.2.3 addresses this question.

The FSAR position on Regulatory Guide.l.64 and revision to Section 17.2.3 resolves this question.

260.29 The FSAR position and commitment to Regulatory Guide 1.64 and revision to Section 17.2.3 resolved this question.

260.30 260.31 260..32 260.33, 34, 35

& 36 260.37

Response

to question 260.13 resolves this question.

Revised Section 17.2.3 addresses this question.

Revised Section 17.2.4 addresses this question.

Revised Section 17.2.6 addresses these questions.

Sections 17.2.2, 17 2.7 and 17.2.18 address this question.

260.38 Sections 17.2.1, 17.2.2, 17.2.7 and 17.2.18 address this'question.

For engineered

items, when required, CP&L or its agents will prepare and implement shop surveillance plans that will delineate the criteria to be examined during the fabrication phase to ensure supplier compliance with contract requirements'

260.39 This question is addressed in Sections 17.2.1 and 17.2.2.

260.40

& 41 260.42 Revised Section 17.2.7 addresses these questions.

The FSAR position on Regulatory Guide 1.123 details certain QA programatic aspects not considered applicable to "off-the-shelf" items.

Other than these specified exceptions, "off-the-shelf" items are subject to the same controls as any other items.

260.43 CP&L evaluates supplier certificates of conformance as a portion of receipt inspection action and periodic audits.

260.44

& 45 260.46 260.47

& 48 260.49 Revised Section 17.2.8 addresses these questions.

Revised Section 17.2.9 addresses this question.

Revised Section 17.2.9 addresses these questions.

CP&L ensures during the procurement ordering process that the correct type of equipment is available for activities involving special processes.

Equipment qualification tests are not normally performed unless so dictated by codes and standards in which case qualification is accomplished in accordance with written procedures and done prior to use of the equipment on the actual work.

Records attesting to such qualification are maintained.

260.50

& 52 Revised Sections 17.2.10 and 17.2.12 address these questions.

260.51

& 54 260.53 Revised Section 17.2.10 addresses these questions.

Revised Section 17.2.10 partially addresses this question.

260.55 Test equipment used is under the controls of Section 17.2.12 which includes criteria for accuracy requirements.

Response

to question 260.50 also addresses this question.

260 56

& 57 260.58 260.59 260.60

& 62 260.61 Revised Section 17.2.12 addresses these guestions.

Revised Section 17.2.13 addresses this question.

Revised Section 17.2.14 addresses this questio Revised Section 17.2.15 addresses these questions.

Revised Section 17.2.16 addresses this question.

260.63 This question is addressed in Section 16.2 (page 6-42).

260.64 Revised Section 17.2.18 addresses this question.

This question is also addressed by the FSAR commitment to Regulatory Guide 1.144.

Control of computer programs is just one of the many activities that are audited.

260.65 The Regulatory

Guides, addressed in Section 1.8, have been updated to the revision level requested by this question.

ATTACHMENT No.

2 INDEX TO CP&L'S RESPONSES TO NRC QUESTIONS ON SECTIONS 1.8, 3.9, 6.2, 6.4, 9.3, 10.2 and 14.2 OF THE FSAR Question No.

640.1 640.2

Response

Revised Table of Contents addresses this question.

Revised Section 3.9.2.4 and new test summary 14.2.12.1.69 address this question.

640.3 640.4 Sources of power to vital buses are tested in accordance with revised, test abstracts 14.2.12.1.5, 14.2.12.1.6, and 14.2.12.1.16.

Test abstract 14.2.12.1.59 has been modified to include manual loading of remaining ESF loads to ensure bus capacity.

Revised Sections 1.8, 6.5, and 14.2.7 address this question.

640.5 640.5.1.b (1) 640.5.1.d (9) 640.5.l.e (5) 640.5.1.e (10) 640.5.1.h (4)

See revised test summary 14.2.12.2.8.

See revised test summary 14.2.12.1.55.

See new test summary 14.2.12.1.76.

See new test summary 14.2.12.1.74.

See revised test summary 14.2.12.1.68 and revised Section 6.2.5.4.

640.5.1.h (5)

Cold water interlocks are not provided on Westinghouse Pressurized Water Reactors, that do not employ loop isolation valves.

Therefore, cold water interlocks are not applicable to SHNPP and are not included in the current plant design.

If plant operation with less than three reactor coolant pumps is approved and interlocks are required by design

change, the cold water interlock circuit will be tested.

640.5.1.h (9)

Containment recirculation fans will be operated during the containment integrated leak rate test and motor current monitored.

Determination fan operability during LOCA conditions will be accomplished by correlating data taken during the containment integrated leak rate test to LOCA conditions.

640.5.1.i (10)

See new test summary 14.2.12.1.67 and revised Section 6.5.1.4.

640.5.1.i 640.5.1.j (12)

(7)

\\

See revised test summary 14.2.12.1.57.

A leak detection system does not exist as a unique system.

However, a leak detection program is described in FSAR TMI Section III.D.l.l.

640.5.1.j 640.5.1-j (8)

See revised test summary 14.2.12.2.14.

A system to pressurize spaces between containment isolation valves is not provided.

Test connections for local leak rate testing of containment isolation valves are provided.

640.5.1.j 640.5.1.j 640.5.1.j 640.5.1.j (10)

(12)

(17)

(18)

See new test summary 14.2.12.1.75.

See new test summary 14.2.12.1.70.

See new test summary 14.2.12.1.74.

See revised Section 14.2.10.1.

640.5.1.j (19)

Reg.

Guide 1.68 (Rev.

2 August 78), Appendix A Section lj, states that "some of the tests can be conducted in conjuntion with the appropriate system level tests."

Each system having remote instrumentation and controls will have those instruments and controls pre-op tested at the system level or in conjunction with the Remote Shutdown Test Summary (14.2.12.2.20).

640.5.1.j (20)

If piping fails, the water normally flows through a

floor drain into a sump.

As the water level rises, a

level switch will cause one sump pump t'o begin operation and send Slow to a collection tank.

If one pump cannot handle the flow and the sump level continues to rise, another level switch starts the-second sump p'ump and causes an'alarm initiation on the WPCB.

This alarm initiation on the Waste Processing Control Board is the instrument that will be used to detect flooding.

640.5.1.j (22)

Instrumentation for the tracking of postulated accidents is listed in Section 7.5.

As a rule, this instrumentation is tested as a part of the appropriate system checkout.

Recent changes to regulatory requirements have resulted in changes to accident monitoring requirements.

Any additional accident monitoring instrumentation incorporated into the design will be added in a future revision to the FSAR which will include any necessary changes to

Section 7.5 and testing abstracts, as well as any additional test abstracts that may be necessary.

640.5.1.3 (23)

See new test summary 14.2.12.1.68.

See 640.5.1.h (4) response.

640.5.l.n (2) 640.5.1.n (5) 640.5.1.n (9)

See new test summary 14.2.12.1.71.

See new test summaries 14.2.12.1.77 and 14.2.12.1.78.

Section 14.2.12.1.40.c.l is the item in the preoperational test for the liquid Waste Processing System that deals with the testing of each floor drain, equipment drain, and oil drain to ensure they

/

drain to the appropriate sump.

For non contaminated drain and pumping systems, see the response to 640.5.i.j. (20).

640.5.1.n (15)

A Shield Cooling System is not part of the plant design.

See 640.5.5.w response.

640.5.1.n (17)

See revised test summary 14.2.12.1.57.

640.5.1.o (1)

See test summaries 14.2.12.1.72 and 14.2.12.1.73.

Fuel handling equipment is addressed in 14.2.12.1.35.

640.5.1.o (2)

Demonstration of the operability of protective devices and interlocks is addressed in the test summary or component checkout dealing with the equipment concerned.

640.5.1.o (3) 640.5.2.c See response to 640.5.1.o (2).

The operability of the Reactor Protection System is demonstrated during the Logic test (14.2.12.1.10),

during the Response Time test (14.2.12.1.11),

during the Integrated test (14.2.12.1.59) performed gust prior to fuel load and during the Rod Control System test (14.2.12.2.8).

The above tests adequately demonstrate the proper operation of the Reactor Protection System prior to fuel load and control of field changes provide assurance of proper operation after fuel load.

640.5.2.d 640.5.2.g See test summary 14.2.12.2.25.

The source range instrumentation will be calibrated prior to fuel loading.

There is no requirement, nor is it necessary, for the source ranges to be recalibrated after fuel loading.

The calibration of

'he source ranges will be performed in accordance with the vendor's technical manual.

The requirement for calibration has been added to test summary 14.2.12.1.15 as a prerequisite.

640. 5-3 640.5.4.d See Section 14.2.10.2 as revised by Amendment 3 of the FSAR.

See revised Section 14.2.10.3.

640.5.4.f 640.5.4.g See revised Section 14.2.10.4.

Operability of the Radiation Monitoring system will be verified prior to low power testing by the Preoperational Test described in Section 14.2.12.1,14.

640.5.4.k The Auxiliary Feed Pump is the only piece of steam driven plant auxiliary equipment, and it is covered by test summary '14.2.12.1.34.

640.5.4.t Licensed operating supervisors will participate in or observe natural circulation operation during this test.

Data obtained will be utilized to validate the training simulator modeling of natural circulation operation.

Training, consistent with Section 13.2.1 will be conducted on the simulator.

640'.5.f The possibility of an excessive power overshoot occurring during a rod drop event has been discussed in:

Reference (1).

Letter from T.

M. Anderson, Westinghou'se, to A. T. Schwencer, NRC, dated Nov.

28, 1979 NS-TMA-2167.

Reference (2).

Letter from E.

P. Rake, Jr.,

Westinghouse, to L. S. Rubinstein, NRC, dated Aug.

18, 1981 NS-EPR-2504.

Reference (3).

Letter from R. L. Whitney, Westinghouse, to L. I. Loflin, CP&L, dated Nov.

13, 1981 CQL-6632.

As a result of Reference (1) Westinghouse recommended that when operating above 90% of full power in the Automatic Mode that Bank D should be withdrawn to

)215 steps.

Reference (2) and (3), based on a more detailed review of the dropped rod methodology, removed the Ref (1) recommendation.

In conclusion, no power overshoot will occur if a rod drop event occurs.

640.5.5.q 640.5.5.r See new test summary 14.2.12.2.23.

See new test summary 14.2.12.1.60.

640.5.5.s The test abstracts for this question are covered in Section 14.2.12.2.

The tests will be performed at the applicable power levels in accordance with Westinghouse start-up and test guidelines.

640.5.5.v 640.5.5.w See new test summary 14.2.12.2.27.

Penetration coolers are not used on hot containment penetrations.

Test methods and acceptance criteria pertaining to concrete temperatures surrounding Type I and applicable Type III mechanical penetrations are being developed.

(The required test summaries will be added to the FSAR in a future amendment).

640.5.5.x Auxiliary systems supporting ESF are tested by the applicable individual system test summaries.

640.5.5.z Operability of the Radiation Monitoring System will be verified prior to Power Ascension Testing by the Preoperational Test described in Section 14.2.12.1.14.

640.5.5.a.a Testing of chemical and radiochemical control systems during the Power Ascension Phase will be performed using permanent plant operating procedures which will verify the capability to maintain required water chemistry parameters.

640.5.5.b.b 640.5.5.e.e See test summary 14.2.12.2.28.

SHNPP does not have Primary Containment inerting and purge systems.

There is a containment purge system which is part of the Containment Ventilation System.

Operability of

'he Ventilation system will be verified prior to Power Ascension Testing by the Preoperational Test described in Section 14.2.12.1.57.

640.5.5.1@.1@

See new test summary 14.2.12.2.29.

This test represents a credible casualty and will produce plant response data that can be compared to predicted plant responses for more severe transients as analyzed in Section 15.1.

640.5.5.m.m See revised Test summary 14.2.12.1.50 and new test summary 14.2.12.2.30.

Plant dynamic responses will be verified during power ascension tests such as the Turbine Trip Test or the Loss of External Electrical Load test, which are more severe plant transient tests.

These have been fully analyzed in Section 15.2.3.2.

6.40.6 See revised test summary 14'.2.12.2.20.

640.7 Reg.

Guide 1.80 has been replaced by Reg.

Guide 1.68.3.

See Loss of Instrument Air Test Summary (14.2.12.1.79),

Section 14.2.7,'nd Section 1.8.

Safety-related valves (accumulators) are tested in accordance with test summary 14.2.12.1.79.

640.8 Revised Section 14.2.7, and revised test summary 14.2.12.1.58 address this question.

640.9 Revised Section 14.2.7, and revised test summary 14.2.12.1.16 address this question.

640.10 Although we are not committed to Regulatory Guide 1.128 Rev.

1, test abstract 14.2.12.1.6 has been modified to require the check for maximum hydrogen concentration.

This check, in addition to our previously listed testing,'rings us into compliance with Reg.

Guide 1.128 Rev.

2 for testing.

" 640.11 SHNPP is not committed to Regulatory Guide 1.139

however, the RHR system testing intent of this guide is accommodated by the following considerations:

1)

The preoperational and initial start-up testing program for the RHR system is in accordance with Regulatory Guide 1.68.

Refer'o Test Summaries 14.2.12.1.28 and 14.2.12.1.29.

2)

RHR system isolation valve and interlock circuit operability may be tested on-line while the RHR system is operating.

This is accomplished by testing one train of the system while the other train continues to remove decay heat.

640.12 Revised Sections 1.8 and 9.4.1.4 address this question.

640.13 640.14 Revised Section 14.2.10.1 addresses this question.

Features specifically designed for ATWS have not been identified for SHNPP.

The Westinghouse design has inherent features which mitigate the consequences of ATWS and which will be tested as part of the standard Westinghouse plant start up.

For future ATWS

features, in the process of normal plant modification testing, appropriate test procedures will be developed and incorporated.

640.15 Tests described in Section 14.2.12 are intended to be performed on both units except as indicated below.

In the event that evaluation of test results from Unit 1

indicates that a test need not be repeated for Unit 2, the appropriate FSAR change and justification will be submitted.

Test Justification 14.2.12.1.66 (Containment Recirculation Sump)

Model test for Unit 1

with flow verification tests for both units (See FSAR Section 14.2.7.g.)

The appropriate pre-operational test titles were corrected to be consistent.

The Index for Start-Up Tests has been moved to Section 14.2.12.2.

The apropriate start-up test titles have been changed to be consistent.

The following list gives the appropriate FSAR Sections where requested changes were made:

Item 640.19(1) 640. 19(2) 640.19(3) 640.19(4) 640.19(5) 640.19(6) 640.19(7) 640.19(8) 640.19(9) 640.19(10) 1.1 1.62 2.'5

1. 44

1. 63

2. 19

l. 25

l. 37

l. 61 2.2 1.16 1.51 1.52 1 ~ 16 1.3 1.4 1.6 1.36 1.50 1.24 1.25 1.44 1.49 test 1.3 1.4

1. 26 2.1 1.6

l. 56

1. 60 (deleted summary)

FSAR Section 14.2.12.

(

)

640.19(11) 640.19(12) 640.19(13) 640.19(14) 640.19(15) 640.19(16) 640.19(17) 2.7

2. 11

l. 13 1.50 1.5 1.6 1.8 1.25 1.34 1.63 1.63 1.8 1.45 (deleted test summary) 1.47

l. 66 The requested modifications to the acceptance criteria have been made as denoted by the following list:

Item FSAR Section 640.20(1) 640.20(2) 640.20(3) 640.20(4) 640.20(5) 640.20(6) 640.20(7)

14. 2. 12. 1. 4 FSAR Amendment 2

14.2.12.1.20 14 2 12.1.28 14.2.12.1.37 14 2.12.1.51 14.2.12.1.66 Test Summaries 14.2.12.1.25 and 14.2.12.1.28 verify that the engineered safety feature pumps (charging/safety injection (CSIP) and residual heat removal (RHR) pumps) operate in accordance with the manufacturer's head flow curve.

Verfication of the pump NPSH requirements is included in test summaries 14.2.12.1.25, 14.2.12.1.28, and 14.2.12.1.29.

During the test described in Section 14.2.12.1.58, sufficient data will be taken to verify that the systems can remove the postulated post-accident heat loads without the support of ventilation systems with the use of only offsite power.

The recorded data will be extrapolated to confirm this capability.

Tests described in Section 14.2.12.1.58 are to verify'basic design criteria.

These design criteria are based on postulated post-accident heat loads.

Inspection for avoidance of dirt, moisture and other abnormal conditions inside instrumentation and electrical components are a part of system turnover, initial component checkout and operation, and flushing requirements.

The details of these inspections are prescribed by the Start-up Manual Section 6, 8, and 9.

Sensing lines for instrumentation, etc. will be flushed (water or air as required) as part of the associated system flush described in the response to 640.23.

Systems are designed such that no cross ties can exist between emergency buses of separate units.

Start-up transformer 1A energizes Unit 1 safety train A component loads and start-up transformer 1B energizes Unit 1 safety train B component loads.

Also, each separate unit's safety train A and B are designed so as to prevent cross ties between them.

Cross ties between normal buses are prevented by mechanical and electrical interlocks.

Section 14.2.12.1.3.a (1) demonstrates that the 6.9KV emergency buses can be energized from both the preferred (normal) and alternate sources.

The transfer capability between sources is also tested.

The preferred source is the 230KV switchyard via the start-up transformers with the alternate source being the diesel generators.

Two separate start-up transformers are provided per unit and no cross ties exist in the secondaries of either.

It is noted that one of the three start-up transformers received a full load test at the manufacturer's facility; however, test abstract 14.2.12.1.2 will be modified to include an ESF load test for connected transformers.

Refer to response 640.3 for additional discussion.

Discharge testing of the batteries will be performed in accordance with IEEE Standard 450-1975.

The Standard calls for shorting cells approaching the polarity reversal voltage.

A precautionary statement will be inserted in Pre-operational Test No. 1-5232-P-01 to cover cell Polarity. reversal.

Test Summary 14.2.12.1.6 has been modified accordingly.

The design of the class lE DC system for SHNPP provides battery chargers capable of recharging the battery to full charge in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after an emergency discharge while applying 100% of the normal continuous load on the DC bus.

A discussion of the design base and exception to Paragraph c.l.b of Regulatory Guide 1.32 appears in Section 8.3.2.2.1.3.

Test Summary 14.2.12.1.11 provides the methods to be used to verify that the overall reactor trip and engineered safety features activation times, as defined in Section 7.1.0 and NUREG 0452, Revision 3, are within the accident analysis assumptions.

The

overall response time will be a summation of measured values and/or assumed values which are then proven to be conservative.

This is the method prescribed by Westinghouse.

The response time of each individual sensor need not be determined if the overall loop response time is acceptable (eg.,

a hydraulic actuator plus sensor is less than the maximum acceptable sensor response time) or if the sensor can be shown to be within the assumed values.

Per FSAR Section 15.0.6, the "nominal trip setpoints" (those referenced as the acceptance criteria for the subject test summary),

represent an allowance for instrumentation channel error and setpoint error.

The process to sensor coupling response

times, except for the bypass RTDs which will be tested in test summary 14.2.12.2.19, are all impulse lines which, by virtue of calculation and test at other similar plants, provide negligible response times.

These times are adequately consumed in the tolerance provided between the limiting and nominal trip, points such that an extensive test program to measure the negligible response time is not required to assure an adequate safety margin.

Therefore, it is SHNPP's and Westinghouse's positions that the process to sensor coupling response

times, except as noted for the bypass RTDs, are too minute to be considered in light of the conservatively selected sensor response time limits used for the SHNPP accident analysis.

Revised Section 14.2.12.1 provides the missing test abstracts.

Revised test summaries 14.2.12.1.39 and 14.2.12.1.40 address this question.

Revised test summary 14.2.12.1.44 addresses this question.

The Ebasco specifications for the main steam power operated relief valves (PORV) and turbine bypass/steam dump valves require that the relief capacity of each valve shall not exceed 970,000 ibm/hr. at 1185 and 1200 psig respectively.

This is the same valve used in the accident analysis as the maximum capacity of any single main steam relief valve.

The manufacturers have certified that maximum flow capacity of:

a) the PORV is 461,500 ibm/hr 9 1200 psig, b) the Steam Dump is 705,000 ibm/hr 9 1200 psig.

The flow capacity was determined using flow coefficients and calclational methods in accordance with ANSI/ISA approved standards, and verified with actual flow tests by the manufacturer.

Due to the significant margin between the actual valve used in the accident anlysis, no capacity testing is to be performed.

The design capcity of the Pressurizer PORV is 210,000 lb/hr at 2350 psig.

The maximum possible flow through the valve at full stroke at a

AP of 2485 psi is LATER This is significantly less than the design safety valve capacity of 380,000 lb/hr and safety valve failure is defined in Section 15.6.1.1 as a more limiting accident conition.

Since the manufucturer has determined valve capacity by approved methods and certified this capacity, testing of the pressurizer PORV is not required.

All post-fuel loading tests described in Section 14.2 are essential toward the demonstration of conformance with design requirements with the exception of the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warranty run.

Revised test summary 14.2.12.2 1 addresses this question.

Revised test summary 14.2.12.2.10 addresses this question.

The present test method is prescribed by Westinghouse and deviations from this method require Westinghouse concurrence.

Test Summary 14.2.12.2.17 has been modified to permit power increases and decreases

~ within the limits approved by Westinghouse procedures.

The prescribed procedure follows the design step load change capablity defined by Section 1.2.2 4.1.

Revised test summary 14.2.12.2.18 addresses this question.

In Section 14.2.12.2.18 and 14.2.12.2.19, the Test Methods, specifically Item c.3 and Item c.l respectively, state that required plant parameters/variables will be monitored.

The monitored points are in accordance with Test Procedures supplied by Westinghouse in the NSSS Start-Up Manual.

In Section 14.2.12.2.18 and 14.2.12.2.19, the Test Methods, specifically Item c.4 and Item c.2 respectively, state that control system setpoint will be adjusted if necessary, to obtain optimal/-

satisfactory response.

The control system response shall be in accordance with Test Procedures supplied by Westinghouse in,the NSSS Start-Up Manual.

Revised test summary 14.2.12.2.22 addresses this question.

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