ML18031A138

Forwards Request for Addl Info Re Initial Tests & Operation

ML18031A138
Person / Time
Site:	Susquehanna
Issue date:	05/18/1979
From:	Parr O Office of Nuclear Reactor Regulation
To:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
References
NUDOCS 7906230162
Download: ML18031A138 (18)

Text

Distribution w Doc et Fa NRC PDR Local PDR LMR 83 File Docket Nos.

50-387 an@50-388 4

closure:

R.

Boy D. Ross D. Vassallo F. Williams

0. Parr S. Niner~(2)

N. Rushbrook R. tlattson S. Hanauer D. Knight R. Tedesco R.

DeYoung V; Moore

'jl: Kreger, h

M. Ernst.

R. Denise OELD

,IE (3)-

BCC:

JBuchanan

. 'Abernathy ACRS '(16) fg'f g 8.tg7g

Dear ftr. Curtis:

Mr. Norman tl. Curtis Vice President '- Engineering and Construction Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101

SUBJECT:

SUS(UEHANNA STEAN ELECTRIC STATION UNIT NOS.

1 AND 2-RE(VEST. FOR ADDITIONAL INFORMATION As a result of our review of your application for operating licenses for the Susquehanna Steam Electric Plant, we find that we. need additional information in the area of initial tests and operation.

The specific information required is listed in the Enclosure.

Please inform us within 10 days after receipt of this letter of the date when this requested additional information will be available for our, review.

Please contact us.if you desire any discussion or clar ification of the information requested.

Sincerely, Orlp~tpg Sten@j b'g 0- O'Pan.'

Olan,D. Parr, Chief Light Hater Reactors Branch Ho.

3 Division of Project Management

Enclosure:

As Stated'c w/enclosure:

See next page 790628 0t(g, CMSSASCa~

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hfAY 18 1979 Mr. Norman W. Curtis CC:

Mr. Earle M. Head

. Project Engineering Manager Pennsylvania Power

& Light Co'mpany 2 North Ninth Street Al 1 entown, Pennsyl'vani a 18101 Jay Si 1 berg, Esq.

Shaw, Pittman, Potts Trowbri dge 1800 H Street, N.

W.

Washington, D. C.

20036 Mr. William E. Barberich,

'uclear Licensing Group Supervisor Pennsylvania Power

& Light Company 2 North Hint h Street

., Al 1 entown', Pennsyl vania 18 101 Edward M. Nagel, Esquire

'eneral Counsel and Secretary Pennsylvania Power

& Light Company 2 North Ninth Street Al 1 entown, Pennsyl vani a 18101 Bryan Snapp, Esq.

Pennsylvania Power

& Light Company 901 Hamilton Street'llentown, Pennsylvania 18101..

Robert H.

Gal 1 o Resident Inspector P. 0.

Box 52 Shickshinny, Pennsyl vani a 18655 Susquehanna Environmental Advocates c/o Gerald Schultz, Esq.

500 South River Street Wi lkes-Barre.,

PA 18702 John L. Anderson Oak Ridge National Laboratory Union Carbide Corporation Bldg. 3500, P. 0.

Box X.

Oak Ridge, Tennessee

'7830 Hr. Robert J. Shovlin Project Yanager-Pennsylvania Povier and Light Co.

2 North Ninth Street Al 1 entown, Pennsyl vani a 18101 Alan R.

Yuspeh, Esq.

Shaw, Pittman, Potts

'Tro wbri d g'e 1800 M Street, N.

W.

Washington, D. C.

20036 Dr. Judi th K. Johns rud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State

College, PA 16801 Hr. Thomas M. Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Coranon>health of Pennsyl vania P.

0.

Box'2063 Harrisburg, PA 17120 Hs. Colleen Marsh Box 538A, RD¹4 Mountain Top, PA 18707 Mrs. Irene Lemanowicz, Chairperson The Citizens Against Nuclear Dangers P.

0.

Box 377 RD¹l

Berwick, PA 18503 C$

~lW+

ENCLOSURE RE UEST FOR ADDITIONAL INFORMATION SUS UEHANNA STEAM ELECTRIC STATIGN DOCKET NOS.

50-387 AND 50-388

423. 0 Initial Tests and 0 eration 423,5 (14.2.4) 423.6 (14.2.6)

~

423.7 (14.2.7) 423.8 (RSP)

(14.2'.7) 423. 9 (14.2;4) 423.10 (14.2.12)

Describe your controls to assure that plant modifications and repairs identified as a result of plant testing are reviewed,

approved, and completed and to assure retesting following such y<ork is completed.

Describe your provisions for the retention of test records (Note: N45.2.9).

You state in response to question 423.2 that testing of safety-related structures,

systems, and components will

,be done according to Table 14.2-1 and that Subsection 14.2.7 of the FSAR has been revised to reference the correct table.

However, you state in 14.2.7 regarding conformance to Regulatory Guide 1.68 that "testing will be conducted...identified in Table 3.2-2." Please correct this inconsistency to conform to the position stated in question 423.2.

Your position to have approved test procedures available for NRC review at least 30 days prior to intended use is not acceptable.

Revision 1 to the Standard Review Plan

'as been revised to, among other items, state that these procedures should be suitable for review at least 60 days prior to their intended use.

Revise Section 14.2.7 to be consistent with this position.

The information provided in Section 14.2.4.3 states that "if necessary, procedures may be modified to complete testing."

This implies that the tests may not be conducted in a manner consistent with that described in your FSAR.

Your application should be modified to provide a clear commitment that the tests will be conducted as described or that the FSAR will be modified to reflect identified changes.

Provide test abstracts for the acceptance tests shown in Table 14.2-2 except for the following:

A-. 3.2 Station Ground System; A-8.1 Domestic Water System; A-9.1 River Water Makeup System; A-9.2 Intake Structure Compressed Air System; A-10.1 Screens and Screen Waste System except for the Emergency Service

Water, System;

423-2 A-20.1 Building Drains-Nonradioactive except for those'n the ESF equipment rooms; A-21.1 1<ater Pretreatment System A-27.1 Auxiliary Boiler System; A-27.2 River Intake Structure HSV System; A-28.4 Chlorination Bldg.

HSV System; A-28.5 Circulating llater Pumygfouse HKV=

System; A-29.1 Administration Bldg.

HSV System; A-29.2 Administration Bldg. Chilled Hater System; A-37.1 Demineralized Mater Transfer System; A-43.2 Condenser Tube Cleaning System; A-74.2 Bulk,Hydrogen System; A-85.1 Cathodic Protection System; A-95.1 H2 Seal Oil System; A-97.1 Stator Cooling System; A-98.1 Main Generator and Excitation System; and A-99.4 Personnel Access Monitors.

Note:

lie consider that the acceptance

tests, except as noted

above, should require the same reviews and approvals as your phase II tests.

Modify your FSAR to include these administrative controls.

423.11 (14.2.7) 423.12 (14.2.12)

You state that in your testing of containment recirculation fans that it may be possible that they will not be tested to verify that fan motor current is within design.

Provide a description of how you plan to verify fan motor currents at conditions representative of accident conditions or provide technical justification for'not conforming to the regulatory guide position.

Regulatory Guide 1.68, Revision 1 (January 1977) is the applicable guide for your. facility.

However, Revision 2 (August 1978) which incorporates additional industry and ACRS comments provides better guidance than Revision 1.

Therefore, we request that you address Revision"2.. Our review of your test program description disclosed that the operability of several of the systems and components listed in Regulatory Guide. 1.68 (Revision 2), Appendix A may =not be demonstrated by your initial test program.

Expand your FSAR to include appropriate test descriptions (or modify existing descriptions) to address the following items from Appendix A of the guide:

(1) reo erational testin l.a 4)

Pressure boundary integrity tests.

l.b 3)

Standby.liquid control system tests; verification of operability of heaters.

l.c

', Demonstration of redundancy, electrical, independence, coincidence, and safe 'failure on los's of power.

l.d(1)

Turbine bypass valves.

423-3 l.d.(3) l.d.(4) l.d.(g) l.d,(11 l.e.(5) l.e.

6) l.e.(8) l.e.(10 l.e.(11 l.e.(12 l.f.(1) l.f.(2) l.f.(3) 1 g (1) l.g. (2) l.h.

l.h.(1) l.h.(2) l.h.(3) l.h(8)

l. i (1) l.'i(2) 1 i(3) l.i(4) l.i(S) l.i(e) l.i(7) l.i(8) l.i(g) l.i(10)

Relief valves.

Safety valves.

Condensate storage system.

) Cooling water system.

Steam extraction system.

Turbine stop, control, bypass, and intercept valves.

Condensate system.

) Feedwater heater and drain systems.

) Makeup water and chemical treatment systems.

)" Main condenser auxiliaries used. for maintaining vacuum.

Circulating water system.

Cooling towers and associated auxiliaries.

Raw water and service water cooling systems.

Normal A.C. power distribution system.

Emergency A.C. power distribution system.

Tests of structures and equipment (e.g., watertight

hatches, walls, floor drains) that protect engineered safety features from flooding (internal and external).

(d) Demonstration of operability of interlocks and isolation valves provided for overpressure protection for low pressure cooling systems connected to the reactor coolant system.

Auto depressization

system, including such items as operability using alternate power and pneumatic supplies.

Containment post-accident heat removal system testing of'he containment spray nozzles, spray headers, and demonstration that piping is free of debris.

Tanks and other.sources of water used for ECCS (e.g.,

condensate storage tanks and suppression pool),

Containment design overpressure structural tests.

Containment isolation valve functional and closure timing tests.

Containment isolation valve leak rate tests.

Containment penetration leakage tests.

Containment airlock leak rate tests..

Integrated containment leakage tests.

Main steam line leakage sealing systems.

Primary and secondary containment isolation initiation logic tests.

Containment purge system tests.

Containment vacuum-breaker tests (drywell/wetwell).

423-4 l.i(13) l.i(15) l.i(17) i.i'(1S) l.i(21) 1 j(2) l.j (7) 1 j (S) 1 j.(10) 1.gl.j l,j l.j 1 j.(18) i.j.(iS) 1.>. 21) l.j. 22) l.j.(24) l.j.(25) l.k.(2) i.k.(3) 1;k.(4) i.i(2) 1.1(3)

Containment inerting system tests.

Containment penetration pressuri zation system tests.

Secondary containment system ventilation tests.

Bypass leakage tests on the pressure suppression containment, Containment penetration'cooling system tests.

Feedwater control system.

Leak detection systems to detect failures in ECCS.

Pressure control systems used to maintain design differential pressures to prevent leakage across boundaries (feedwater leakage control).

Seismic instrumentation.

Traversing incore probe system.

Failed fuel detection system.

Hotwell level control system.

Feedwater heater temperature,

level, and bypass control systems.

Auxiliary startup in'strument tests (neutron response checks).

Instrumentation and controls used for shutdown from outside the control room.

Reactor mode switch and associated functions.

Instrumentation that can be used to track the course of postulated accidents such as containment'ide-range pressure indicators, reactor vessel water level monitors, pressure suppression level monitors, high-range radiation detection

devices, and humidity monitors.

Annunciators for reactor control and engineered safety features.

Process computers.

Personnel monitors and radiation survey instrument tests.

Laboratory equipment used to analyze or measure radiation levels and radioactivity concentrations.

High Efficiency Particulate Air (HEPA) filter and charcoal adsorber efficiency and in-place leak tests.

Gaseous radioactive waste handling systems.

Solid waste handling systems.

Solidification system tests should include verification that no free liquids are present in packaged wastes.

1.1.(5) 1.1.(6) 1.1.(7) 1.1.(8) l.m.(1) l.m.(3) l.m.(4) l.m.(5) l.m.(6) l.n.

1) l.n.(2) 1:n'.(5) l.n.(6) l.n.(7) l.n.(8) 1.n.(9) l.n.(ll) l.n.(13) l.n.(14) l.n.(15) l.n.(18) l.o.(1) 423-5

,n Isolation features for condenser offgas systems.

Isolation features for ventilation systems.

Isolation features for liquid.radwaste effluent systems.

. Plant sampling systems.

Spent fuel pit cooling system teSZs, including the testing of antisi phon devices, high radiation

alarms, and -1'ow water level alarms.

Operability and leak tests of sectionalizing devices and drains and leak tests of gaskets or bellows in the refueling canal and fuel storage pool.

Dynamic and static load testing of cranes,

hoists, and associated lifting and rigging equipment, including the fuel cask handling crane.

Static testing at 125/ of rated load and full operational testing at 100Ã of rated load.

Fuel transfer devices.

Irradiated fuel pool or building ventilation system tests.

Service water cooling system.

Turbine building cooling water systems.

Sampling systems.

Chemistry control systems for the reactor coolant system (condensate demineralizers).

Fire protection systems.

Seal water systems.

Vent and drain systems for contaminated or potentially contaminated systems and areas and drain and pumping.systems serving essential

areas, e.g.,

spaces housing diesel generators, essential electrical equipment, and essential pumps.

Compressed gas systems.

Communication systems.

Heating, cooling, and ventilation systems serving the following:

(a)

Diesel generator buildings.

(b)

Turbine building and radioactive waste handling building.

Shield cooling systems.

Heat tracing and freeze protection systems.

Dynamic and static load tests of cranes,

hoists, and associated lifting and rigging equipment (e.g., slings and strongbacks used during refueling or the preparation for refueling).

Static testing at 125K of rated load and full operational testing at lOOX of rated load.

423-6 l.o.(2)

Demonstration of the operability of protective devices and interlocks.

l.o.(3)

Demonstration of the operability of safety devices on equipment.

(2) initial fuel loadin and recritical tests 2.d.

2.h.

Final test of the reactor coolant system to verify that system.leak rates are within specified limits.

l/echanical and electrical tests of incore monitors, including traversing incore monitors, if installed.

(4) low 4.d.

4.e.

4.g.

4.i.

4.1.

4.m.

4.r.

ower testin Verification that proper operations of associated protective functions and alarms provide for plant

.protection in the low-power range.

Flux distribution measurements.

Determination of proper response of process and effluent radiation monitors.

Demonstration of the operability of rod inhibit or block functions.

Demonstration of the operability, including stroke times, of branch steam line valves and bypass valves.

Demonstration of the operability of main steam line isolation valve leakage control system at hot standby conditions.

Demonstration of the operability of reactor condensate cleanup system.

(5) ower-ascension tests 5.a.

5.c.

5.g.

5.1.

5.m.

Demonstration that power vs. flow characteristics are in-accordance with design values.

Control rod pattern, the exchange demonstration.

Demonstrate that control rod sequencers, control

, rod worth minimizers, and rod withdrawal block functions operate, in accordance with design.

Demonstrate design capability of turbine bypass valves.

Demonstrate that-the reactor coolant system flows, pressure

drops, and vibrations are in accordance with design for. various operating modes.

423-7 5.o.

5.t.

5.u.

5.w.

5.x.

5.z.

5.c.c.

5.f.f.

5.h.h.

5.i.i.

5.1.1.

Calibration of instrumentation and demonstration of proper response of reactor coolant leak detection systems.

Verify, as appropriate, response times and setpoints...

for'ain steam line relief valves.;-turbine bypass valves; and turbine stop, intercept, and control valves.

Verify response times of branch steam line isolation.

Demonstrate adequate performance margins for shielding and penetration cooling systems capable of maintaining temperatures of cooled components within design limits with the minimum design capability of cooling system components available (1001).

Demonstrate adequate beginning-of-life performance margins for auxiliary systems required to support the operation of engineered safety features or to maintain the envi'ronment in spaces that house engineered safety, features.

Engineered safety features will be capable of performing their design functions over the range of design capability of operable components in these auxiliary systems (50Ã, 100/).

Demonstrate that process and effluent radiation monitoring systems are responding correctly.

Demonstra'te that gaseous and liquid radioactive waste processing,

storage, and release systems operate in accordance with design.

Demonstrate that the ventilation system that serves the main steam line tunnel maintains temperature within the design limits.

Demonstrate that the dynamic response of the plant to the design load'wings for the facility.

Demonstrate that the dynamic response of the plant is in accordance with design for closure of reactor coolant system flow control valves.

Demonstrate that the dynamic response of the plant is in accordance with design requirements for turbine trip.

423.13 (14.2.12)

Expand your test abstracts of Section 14.2.12 and those provided in answer to questions 423.10 and 423.12 to describe in more detail the test objectives, prerequisites, test method, and acceptance criteria in regard to applicable parameters and functions (e.g.,

pressure, temperature, flow, valve operability, valve opening and closure times, controls, logics, and interlocks).

423.14 (14.2.7) 423.15 (14.2.4) 423-8 Me note your position relative to Regulatory Guide 1.80 contained in Section 14.2.7 of the FSAR and disagree with your position.

This guide is applicable since the instrument air system is used for a source of air for systems and components that. provide a safety function..-/edify youl application to show that your test program wjll be con-sistent with the guide or-show that you will conduct equivalent testing for the air system and supplied loads.

Me could not conclude from our review of the preoperational test phase and the test abstracts provided in Table 14.-2 that comprehensive testing is scheduled for several of the described tests.

Therefore, clarify or expand the description of the preoperational test phase to address the following:

, (1) Modify the individual A.C. and D.C. distribution system test descriptions or provide an integrated test description to verify proper load group assignments -(reference Regulatory Guide 1.41).

(2) Class lE 125 Volt D,C.

System Preoperational Tests-State your plans for demonstrating the following:

(a) that emergency loads are in accordance with battery sizing assumptions; and (b) that each emergency load can operate at the minimum voltage level at which it can be postulated to operate.

(3) State how operability of emergency loads using offsite power will be demonstrated during A.C. and D.C. system tests.

(4) Identify testing that will be accomplished to verify drywell floor bypass leakage 'and'rovide quantitative acceptance criteria.

(5) State your plans for assuring that the effects of interfacing hardware (e.g.,

snubbers, pulse dampers) located between measured variables and the input to the sensors for the-Reactor Protection System do not compromise the channel response time requirements.

(6) Control Room HVAC System Preoperational Test - Expand the test description to include a demonstration that outleakage from the control room is in accordance with design assumptions when the system is on the emergency outside air supply.

423-9 423. 16 (14.'2) 423.17 (14.2) 423.18 (14.2) 423.19 (14.2) 423. 20 (14.2;12)

Describe your tests to demonstrate that the core spray flow distribution header provides adequate cooling flow to each fuel assembly.

Provide a description of the electrical lineup for Unit No.

2 '.

during preopera'tional tests that will be coodiicted to satisfy regulatory positions in Regulatory Guide 1.41 for Unit No. l.

Provide a description of the lineup for both plants during similar preoperational testing on Unit No.

2 subsequent to initial criticality of Unit No.

1.

The descriptions should

, address both normal and emergency A.C. and D.C. power distribution systems.

Provide assurance that crossties will not exist which could cause loss of emergency bus power to one unit due to testing of the other unit.

Provide a commitment to include in your test program any design features to prevent or, mitigate anticipated transients without scram (ATWS) that may be incorporated in your plant design.

Provide preoperational test descriptions (or modify existing descriptions) to assure that each engineered safety feature pump operates in accordance with the manufacturer's head-flow curve.

Include in the description the bases for the acceptance criteria.

(The base's provided should consider both flow require-ments for ESF functions and pump NPSH requirements.)

Our review of the power test abstracts provided in your FSAR disclosed that they are not sufficiently descriptive to conclude that comprehensive testing is planned or that satisfactory test acceptance criteria have been established.

The individual test abstracts should be modified as indicated below.

(1) Modify your acceptance criteria for test PT-l, Chemical and Radiochemical, to provide a level 2 acceptance criteria of design basis for your condensate demineralizers and RWCU.

(2) Your acceptance criteria for test PT-2, Radiation Measurements, is not consistent with the design objectives of ALARA.

Therefore, revise your acceptance criteria to be consistent with your plant design objectives.

(3) Modify your test abstract for Full Core Shutdown Margin

. to specify the value R.

In addition, specify a quantitative value for your level 2 criterion and that value be considered a level 1 criterion.

423-10 (4)

(5)

Revise all power test acceptance criteria where you use the term "specified value" to provide a specific numerical value for those acceptance criteria.

Test PT-4, Full Core Shutdown t1argin - Provide the temperature'f the core for the shutdown" ihargin test.

Test PT-5, Control Rod Drive System - The level 1

acceptance criteria for control rod withdrawal speeds are inconsistent and nonconservative in respect to the times assumed in your accident analyses.

Resolve this inconsistency.

Also, this test abstract should be expanded to provide'ssurance that dash-pot performance will be in accordance with design require-ments and acceptance criteria should be provided for control rod scram times.

(7) Test PT-9, Water Level measurement Revise Figure 14.2-5 to include water level measurement tests at Test Conditions 1, 3, 4, 8

5 in addition to those already specified.

Test PT-10, IRN Performance

- Revise the acceptance criteria to include a check of the IRH scram trip point.

(9) Test PT-14, RCIC System - State your plans to demonstrate the capability of the system to start from the "cold" condi tion.

Also, clari fy or jus tify the Level 1

acceptance criteria provided in paragraph 4.

Based on operating experience to date, the apparent reliability of the reactor core isolation cooling system (RCIC) in BWR plants has been poor.

Because it appears that many of the causes for the failure should have been detected and corr'ected during initial testing of the RCIC system, this system should be given a very thorough checkout during the initial testing program.

Your current test proposal does not appear adequate to establish confidence in the reliability of the system for your facility.

Your application should be modified to show that several consecutive successful cold starts of the RCIC system will be demonstrated during your power ascension phase.

(10) Test PT-15, HPCI System - Based on operating experience to date, the apparent reliability of the high,Pressure core injection system (HPCI) in BWR plants has been poor.

Because it appears that many of the causes for the failure should have been detected and corrected during initial testing of the HPCI system, this system should be given a very thorough checkout during the initial testing program.

Your current test proposal

423-11

(>>)

does not appear adequate to establish confidence in the reliability of the system for your facility.

Your application should be modified to show that several consecutive successful cold starts of the HPCI system will be demonstrated during your pointer,ascension phase.

Test PT-16, Selected Process Temperatures

- Modify your level 1 acceptance criteria to include the pump in an idle loop; and your level 2 acceptance criteria to relate to loop temperature.

. (12)

Test PT-18, Core Power Distribution - Revise your test method to specify how many sets of TIP data will be taken to determine the overall TIP uncertainty.

(i3)

(i4)

Test PT-22, Pressure Regulator - Specify the mode of control (auto or manual) of each of the other principal control systems at each test condition.

Test PT-23, Feedwater System Modify your test objectives to include the loss of a feedwater heater.

Specify the mode of con'trol (auto or manual) of each of the other principal control systems at each test condition for the feedwater control setpoint changes.

Also, the test description should be modified for the feedwater heater trip to specifically identify: (a) the type of trio to be initiated; (b) the feedwater heater(s) involved; and (c) a discussion of how the planned trip relates to the worst case limiting event for your design that could result from a single equipment fa'ilure or operator error.

Modify your test method to include the loss of all feedwater flow.

Provide justification for performing the feedwater pump trip in Master Manual Flow Control Mode rather than Automatic Flow Control

, Mode for feedwater pump trip and for feedwater heater loss.

(16)

Test PT-25, Main Steam Isolation Valves - Provide clear acceptance criteria for relief valve and RCIC performance during this transient.

Test PT-26, Relief Valves - Describe your test method and acceptance criteria for bypass valve flow calibration and capacity.

Modify your acceptance criteria to include openina times (to full caoacitv) of relief valves.

,423-12 0

(17)

Test PT-27, Turbine Trip and Generator Load Rejection-Modify your test abstract to: (a) identify the method of tripping the main generator breaker; (b) identify the conditions for each trip planned; (c) identify the variables or parameters to be monitored jeer each trip (d) provide assurance that test results will be compared with predicted results for the actual tests to be run (for each trip); (e) provide quanti tati ve acceptance criteria and their bases for the required degree of convergence of a'ctual test results with predicted results for the monitored variables and parameters for each trip; and (f) provide acceptance criteria for grid stability, voltage and frequency following generator load rejection trips.

(18)

(19)

(2O)

(21)

Test PT-28, Shutdown From Outside the Main Control Room-State whether the plant's electrical system will be aligned for normal full power operation and provide acceptance criteria for the, performance of plant equipment and the variables or parameters to be monitored during the test.

Test PT-29, Recirculation Flow Control - Specify the mode of control (auto or manual) of each of the other principal control systems at each test condition.

Test PT-30, Recirculation System - Modify the test abstract to define the types of trips to be conducted at each test condition and the manner by which the pumps will be tripped.

Also, modify the test description and provide quantitative acceptance criteria for flow coastdown and trip of both the recirculation pumps.

Also, provide stability criteria for plant performance following the trips.

Test PT-31, Loss of Turbine-Generator and Offsite Power-Modify the test abstract to: (a) describe the initial plant conditions'for the test, including the lineup of the plant's electrical system; (b) describe the type of trip to be conducted; (c) identify the variables, parameters, and plant equipment to be monitored; (d) provide assurance that test re'suits will be compared with predicted results for the actual test case; (e) provide quantitative acceptance criteria and their bases for the required degree of convergence of actual test results with predicted results for the monitored variables and parameters; and (f) provide functional acceptance criteria for plant equipment that should function during or following the test.

Also, correct the level 1 acceptance criteria to be consistent with your facility design.

423-13 (22) Test PT-32, Containment Atmosphere Circulation System-Nodify your acceptance criteria to include level 1

criteria based on concrete temperatures.

(23) Test PT-35, Recirculation System Flow Ca]jbration - l1odify -.

the test method to add calibrations at Cej t conditions 2

and 5.

423. 21 (14.2.4) 423.22 (14.2) 423. 23 (14.2. 12) 423.24 (14.2)

You state in Subsection 14.2.4.6 that the completion of Phase II on safety-related systems is a prerequisite for commencement of the Power Test Program.

Describe any preaperational tests shown in Tables 14.2-1 and 14.2-2 that you consider need not be completed prior to the commencement of the Power Test Program.

Describe any preoperational and startup tests that you will conduct on Unit No.

1 that you may not conduct on Unit Ho. 2.

Provide a test description to provide for the integrated testing of reactor vessel isolation on low water level.

Your answer to parts (a) and (b) of question 423.1 regarding the qualification requirements for persons performing the functions of preoperational test directors and startup test directors are not satisfactory.

We consider that the minimum qualifications for persons that direct or supervise the conduct of preoperational tests include a bachelor's degree in engineering or the physical sciences or the equivalent and one year of applicable power

'lant experience.

Included in the one year of experience should be at least 3 months of,indoctrination/training in nuclear power plant systems and component operation in a nuclear power plant that is substantially similar in design to the type at which the individual will perform the function.

We consider that the minimum qualifications for persons that direct or supervise the conduct of individual startup tests should include a bachelor's degree in engineering or the physical sciences or the equivalent and two years of applicable power plant experience, at least one year of which should be applicable nuclear power plant experience.

Revise your FSAR to indicate conformance to the staff position.