ML18032A432
| ML18032A432 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/13/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707210643 | |
| Download: ML18032A432 (33) | |
Text
'-E ~
REGULATl "Y INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR: 8707210643 DOC. DATE: 87/07/13 NOTARIZED: NO DOCKET FACIL: 50-259 Broens Ferry Nuclear Power Stations Unit ii Tennessee 05000259 50-260 Broens Ferry Nuc l ear Power Stat one i Unit 2. Tennessee 050002S0 50-296 Brogans Ferry Nuclear Poeer Stations Unit 3i Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION GRIDLEYe R ~ Tennessee Valley Authority RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Resubmits T estart test program based on refinements in program formal lg presented to NRC on 870312.
DISTRIBUTION CODE: IE26D COPIES RECEIVED: LTR ENCL SIZE:
TITLE: Startup Report/Refueling Report (per Tech Specs)
NOTES: Zeolinski 3 cg. 1 cg ea to: Axelradi Ebneteri S. Richardson'I 05000259 LiauJi G. Zechi i OIA.
Zeol insk i 3 cg. icy ea to: Axelrad Ebneteri S. Richardson'Ii 05000260 LlaUlz G Zechs
~ QIA.
Zeolinski 3 cg. icg ea to: Axelradi Ebneteri S. Richardson'I 050002m~
LiaUli G. Zecha I OIA.
REC IP IENT CQP IES REC IP IENT CQP IES ID CODE/NAME LTTR ENCL ID CODE/NAME, LTTR ENCL JAMERBONiC 1 0 PD 1 1 GEARS' 2 2 STANGt J 2 2 INTERNAL: ACRS 5 5 ARM CH ADV 1 1 NRR/PMAS/ ILRB 1 FI" '
02 1 REB DEP Y G I 1 FILE 01 1 1 RGN2/DRBB/EPRPB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTES: 12 12 TOTAL NUMBER OF COPIES REQUIRED: LTTR 32 ENCL 31
h P
TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE S7401 5N 157B Lookout Place .
JUL 1$ 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) REFINEMENT OF THE RESTART TEST PROGRAM This letter is to resubmit the Restart Test Program (RTP) that will be
, utilized at BFN. The October 7, 1986 submittal of the RTP contained the essence of the RTP to be utilized. A resubmittal of the program is believed warranted because of refinements in the program formally presented to NRC on March 12, 1987, at BFN.
In order to reduce NRC review time of the resubmitted RTP, significant changes to the October.7, 1986 submittal are addressed in attachment 2 of enclosure 1. Attachment 3 of enclosure 1 addresses TVA's response to NRC's formal comments on the October 7, 1986 submittal.
On March 20, 1987, in a telephone call with Al Ignatonis, and in formal correspondence dated April 7, 1987, TVA requested an extension to May 4, 1987, for submitting this response. Additional extensions have been obtained due to an expanded review and concurrence cycle for this submittal. The RTP is contained as enclosure 1 to this letter. A list of commitments is provided as enclosure 2.
Please refer any questions to M. J. May, Manager of Site Licensing, Browns Ferry Nuclear Plant, (205) 729-3566.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. Gridley, D'ctor Nuclear Safety and Licensing Enclosures cc: See page 2 8707210643 870713 PDR ADOCK 05000259 P
gpf An Equal Opportunity Employer
U.S. Nuclear Regulatory Commission JUL 18 1987 cc (Enclosures):
Mr. G. G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. A. Zwolinski, Assistant Director for Projects
'Division of TVA Projects Office of Special Projects U,S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O. Box 311 Athens, Alabama 35611
ENCLOSURE I BROWNS FERRY NUCLEAR PLANT UNIT 2 RESTART TEST PROGRAM
. INDEX A. Summary B. Restart Test Program Scope C. Joint Test Group D. System Test Specification E. Restart Test Program Test Instruction F. Administrative Control of Testing G. References Figure 1: Restart Test Program Organization Figure 2: Restart Test Program Activity Floe Chart : Restart Test Program System List : Changes in RTP Description From October 1986 Submittal to NRC : Responses to NRC Questions On October 1986 RTP Description
BROWNS FERRY UNIT 2 RESTART TEST PROGRAM DESCRIPTION A. Summar Pro ram Descri tion The primary purpose of the Restart Test Program (RTP) as defined in Volume 3 of the Nuclear Performance Plan is to verify that systems are capable, of meeting their safe shutdown requirements for unit 2 of Browns Ferry Nuclear Plant. The RTP organization is depicted in Figure l. As indicated, the Site Director is responsible for the overall RTP and for providing the necessary interface with other TVA organizations. The RTP test scope is comprised of the test requirements resulting from review by the Division of Nuclear Engineering (DNE) and reviews by the RTP test engineers.
le DNE, as part of the Design Baseline and Verification Program (DBVP),
generates test requirements necessary to verify system design functions utilized in satisfying the safe shutdown analysis. Additionally, a restart test engineer from the RTP will perform a system review to determine test requirements necessary for reliable system operation.
This system review addresses items such as past maintenance and operational history documentation, vendor recommended testing, the extent of modifications performed during the current unit. 2 cycle 5 outage, and licensing commitments. As a result of these review processes, some systems will require extensive testing while others will have no specific testing required. A system check list will be utilized on those systems with no testing requirements to determine their operational status.
Items such as system procedures, hold orders, temporary alterations, Engineering, Change Notices (ECNsO, and a system walkdown will be included in this checklist.
Restart test requirements will be compiled and documented 'in System Test Specifications (STS). The STS is a document which specifies the testing to be performed on selected systems for the RTP. From this document, a test instruction is written to implement the test requirements. The test requirements contain input from the DBVP and from the RTP system review (see figure 2 for a flow chart of RTP activities).
RTP Test Instructions will utilize existing site test procedures where available to satisfy testing requirements. Specific test'equirements not covered by existing plant instructions will require step-by-step test instructions to be written and included in the RTP Test Instruction. The test program, including STS, test, instruction development, test conduct, and test results review, will be controlled by approved administrative procedures.
A Joint Test Group (JTG) was created as a subcommittee of the Plant Operations Review Committee (PORC). PORC will maintain cognizance of JTG activities by review of JTG meeting minutes. The JTG will serve as a dedicated review group responsible for scope and technical adequacy of the RTP, and will make recommendations for approval to the Plant Manager, Members of the JTG include Engineering (DNE), Modifications,
Quality Assurance, Technical Support Services (Systems Engineering), a representative from the NSSS vendor (General Electric), and other plant groups. The formal mechanism to provide input into the RTP and associated test instructions for each of the represented groups comprising the JTG will be through their representative.
A certified test engineer, the test director, is assigned to each system covered by the RTF. This engineer is responsible for ensuring that the test requirements specified in the STS are satisfactorily completed in the test instruction. This is accomplished by any one or a combination of the following: witnessing test performance, review of test results, or actual performance of part of the test instruction.
Before a test instruction is performed, ECNs appli'cable to the system will be tabulated in the test instruction and their status documented.
This is a prerequisite to all- test instructions. The information will be utilized to establish the as-tested design configuration of the system when provided to DNE as part of the test results package.
When the test instruction is authorized to be performed the test director completes the prerequisites, holds pretest briefings, and explains the test'cope and any specific system information to the Operations'Shift Engineer. Operational control of the system remains with plant operations throughout the RTF. When the shift engineer considers plant conditions suitable to support the test instruction, authorization is given to commence testing.
Some test requirements specified in the STS will not be able to be completed before the required milestone for test completion (such as fuel load or startup) because of the need for nuclear steam or other plant conditions. These items will be documented as test exceptions and tracked as open items on the system punchlist.
After a test is completed, a test results package will be compiled which will include the test instruction, test results, the STS,'and other information determined pertinent by the RTP Manager. The test results package will be reviewed and recommended for approval by the JTG and approved by the Plant Manager.
After the test results package is approved, tracking responsibility for open punchlist items is transferred from the RTP. to the Technical Support Services Systems Engineering Section.
In addition to the individual system tests planned, integrated tests will be performed before fuel loading such as a loss of offsite power/loss of coolant accident (LOP/LOCA) test, integrated cold functional testing, and a backup control test. The RTP STS could require testing both before and during power ascension. Testing during power ascension could include continued system operational tests, dynamic control system tuning tests, and certain transient tests where required.
The following sections describe features of the RTP in more detail. The administrative procedures that implement the RTF are Site Directors Standard Practice (SDSP) 12.1, "Restart Test Program," and SDSP 12.2, "Development of System Test. Specifications." These procedures are available for HRC review upon request.
B. R~TP Sco e The RTP will address the systems necessary to support unit 2 operation and document their readiness for reliable and safe operation. These systems are categorized into one of three groups. The primary distinction between groups 1 and 2 is the scope of testing, requirements provided by the DBVP. The grouping is for convenience and clarification according to the following guidelines.
Group 1: Systems determined to be critical to safe shutdown of the plant. Testing requirements determined primarily by the DBVP.
An STS will be prepared and an RTP Test Instruction written and conducted. 'A test results package will be compiled for each system to document the test results and system readiness status.
Group 2: Systems which have few test requirements specified by the DBVP but. provide direct support to plant operation. The majority of the system is addressed by the RTP review to determine test, requirements. An STS will be prepared and an RTP Test Instruction written and conducted. A test results package will be compiled for each system to document, the test results and system readiness status.
Group 3'ystems not directly supporting plant operation or not important to safety will in general require no testing. No system test requirements are provided from the DBVP. This group will not have an STS or an RTP Test Instruction prepared, but will be addressed by the requirements of the System Checklist (SCL).
A system checklist will be used for all group 1, 2, and 3 systems and will record the status of a system and its documentation as a result of a review of items such as system procedures, hold orders, temporary alterations, ECHs, significant open maintenance requests, and a system walkdown.
The RTP addresses both groups 1 and 2 in the same manner. Attachment 1 contains a list of systems showing their initial group assignments.
Changes to this list will be made based on the system review process, and resulting changes approved and documented using site administrative procedures.
In addition to individual system testing, integrated tests will be performed. Although the total scope of integrated testing may change, the following tests will occur.
o LOP/LOCA Test Plant response to a simultaneous loss of all offsite power and a simulated LOCA will be demonstrated.
Backup Control Test A test of the controls required for "Shutdown from Outside the ~
Control Room," (Safe Alternate, Shutdown) by verifying proper operation of local control transfer switches and the functions of the Remote Shutdown Panels.
o Integrated Cold Functional Testing Systems will be operated per the operating instructions in an integrated manner as much as possible before fuel loading or restart to verify plant procedures, equipment, and to provide further operator training. For example, operators would pull condenser vacuum and operate the circulating water, condensate, and feedwater systems together.
Testing during power ascension will include the remaining system test requirements specified by the DBVP that require nuclear steam or other conditions not available before fuel loading. Other examples of the type testing performed during power ascension are dynamic control system tune-up tests and transient tests. Transient, tests may involve feedwater pump trips, main turbine trips, and reactor scrams. Details of testing during the period of power ascension are still being determined.
Joint Test Grou To evaluate the scope and adequacy of the program a dedicated review group called the Joint Test Group or JTG has been established for the RTP. The JTG functions as a subcommittee of PORC (Plant Operations Review Committee), reviews documentation developed by the RTP, and recommends approval to the Plant Manager. PORC maintains cognizance of JTG activities by reviewing JTG meeting minutes. The JTG membership and current charter are as follows:
Chairman - Unit 2 Superintendent
1 JTG members are obtained from the following BFN organizations.
Division of Nuclear Engineering (DNE)
Maintenance Modifications Operations Quality Assurance Restart Test Program Technical Support Services NSSS Vendor Representative (GE)
The JTG charter is to review and recommend approval of the following:.
RTP Test Instructions and Revisions RTP Test Results Packages System Checklists for Group 3 Systems System Test Specifications and Revisions The representative from DNE provides interface reviews for the DBVP.
D. S stem Test S ecification Develo ment The purpose of the System Test Specification (STS) is to document the scope of testing to be performed on a system and the basis for the test requirement. The RTP engineer will prepare an STS for all group 1 and 2 systems. There are two primary sources of test requirements the DBVP and a review of the system performed by the test engineer. The DBVP, conducted by DNE, will provide formal test requirement documents based on system design criteria and the safe shutdown analysis.
The RTP engineer performs a system review to determine any additional testing requirements based on considerations such as the following:
o The number of modifications performed on the system during the current outage o Operational and maintenance history o Vendor recommended tests o Licensing, commitments o Outstanding deficiency documents (i.e., CAQ Program).
If it is determined that a particular test of a system function is it will be documented in the required after a review of the above items, STS.
These test requirements define the amount of testing necessary to confirm that the system can safely support plant operation and shutdown.
E. RTP Test Instruction The scope of testing defined in the STS is evaluated to determine if existing site procedures can be utilized to meet portions of the test requirements. The RTP Test Instruction is written to meet the test requirements in the STS using either existing site procedures or new step-by-step instructions. Some examples of existing procedures that could be used include: Surveillance Instructions (SIs), Post Modification Tests (PMTs), and Electrical or Mechanical Maintenance Instructions (EMIs, MMIs). The RTP Test Instruction will be reviewed by the JTG and recommended for approval to the Plant Manager.
Administrative Control of Testin The RTP will be conducted per the requirements of SDSP 12.1, which specifies the features that ensure adequate test controls such as test logs, test exceptions, prerequisites, test changes, qualifications of test engineers, etc. The RTP Test Instructions will be conducted, witnessed, or reviewed by test engineers qualified to American National Standards Institute (AHSI), "Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants," H45.2.6. All test directors will be certified to Level II criteria as stated in this ANSI standard.
G. References TVA Nuclear Performance Plan, Volume 3, Part III Section 8.0 BFH Site Directors Standard Practice SDSP 12.1, Restart Test, Program" BPH Site Directors Standard SDSP 12.2, "Development of System Test Specifications"
I PIGURE I RESTART TEST PROGRAM ORGANIZATION BFN SITE QNP DIRECTOR ADVISORS DESIGN BASELINE AND VERIFICATIQN PROGRAM (DNE)
RTP ~ ~ ~ ~ ~ JOINT TEST NANAGER GROUP DBVP/RTP SYSTEN ENGR.
COORDINATOR SECT IQN SUPV.
ADJOIN- ASSISTANT 'LANNER/ SCHEDUI ER TEST ENGINEERS GROUP LEADERS - 3 OR 4 ENGINEERS APPROX.30 SPECIAL PROJECTS TOTAL P.82
Figure 2 RTP ACTIVITY FLOM CHRRT DBVP Develops Test Requireaents Based on RTP Develops Test Pequireaents Based on Safe Shutdown Systea Revie~
Analysis ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
Safe Shutdown Analysis I, Design Criteria Additional Systea Revie~
Test Req'ats. of Docuoents and Identified Nodifications DBVP Drafts Test Requireoents t
RTP ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
Review/Coraent Test Requireaents Issued as Test Scoping Docuaents Mrite Test Sunnary and
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Develc p Sys. Check List GPAOP 3 RTP Test Procedure Conpile RTP Test SYSTEItS Systea Test Deve lopaent Results Package Specification - Test Pesults Develop (STS) Developaent - Test Suraary Report Systeo
- STS Check List JTG Review t, - Systea Punchlist Pint. Ngr. Appvl. - Systea Check List Hrite RTP Test Instruction
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ JTG Peview of Pe!ults
'nd Open Iteas 3TG Revie~ Pe!elution of Co~aents Ilgr, Appvl. 'int.
and Test Exceptions
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
3TG Review I Pint. Ilgr. Approval.
Perforaance of RTP Tests~ SI's~ and Other Tests Per RTP Test Instructions RTP Results'ncorporated By DBVP RTP Systea Control Peleased to Other
- Site Prograas
ATTACHMENT 1 Page 1 of 3 RESTART TEST PROGRAM SYSTEM LIST Sys. Description Group No. No.
1 MAIN STEAM SYSTEM 1 2 CONDENSATE/DEMINERALIZERS 1 3 FEEDWATER 1 5 EXTRACTION STEAM 2 6 HEATER DRAINS AND VENTS 3 8 TURBINE DRAINS 3 10 BOILER DRAINS AND VENTS 2 12 AUX BOILER 3 18 FUEL OIL 2 20 CENTRAL LUBE OIL 3 23 RHR SERVICE WATER 1 24 RAW COOLING WATER 2 25 RAW SERVICE WATER 2 26 HIGH PRESSURE FIRE PROTECTION 2 27 CONDENSER CIRCULATING WATER 2 28 WATER TREATMENT "3 30 DIESEL GENERATOR BLDG 6 RX BLDG VENTILATION SYS 2 31 CONTROL BAY HVAC 2 32 CONTROL AIR 2 33 SERVICE AIR 2 34 VACUUM PRIMING 3 35 GENERATOR COOLING 3 37 GLAND SEAL WATER TREATMENT 3 39 C02 STORAGE AND FIRE PROT. 2 40 BLDG. DRAINS 3 43 SAMPLING AND WATER QUALITY 2 aa BUILDING HEATING 3 a6 FEEDWATER CONTROL 2 a7 TURBINE/GEN CONTROL 2 50 SODIUM HYPOCHLORITE INJECTION 3 51 RAW WATER CHLORINATION 3 53 DEMINERALIZER BACKWASH AIR 3 55 ANNUN. AND SEQUENTIAL EVENTS RECOR. 3 56 TEMPERATURE MONITORING 3 57 ASSOC. ELECTRICAL (SEE 200-SERIES) 1/2/3 63 STANDBY LIQUID CONTROL 64A PRI CONT/PRI CONT ISOLATION 64B REACTOR BUILDING VENTILATION 64C SECONDARY CONTAINMENT 65 STANDBY GAS TREATMENT 66 OFFGAS 67 EMERGENCQ EQUIP, COOLING WATER 68 REACTOR WATER RECIRCULATION 69 REACTOR WATER CLEANUP
0 ATTACHMENT 1 0
Page 2 of 3 RESTART TEST PROGRAM SYSTEM LXST Sys. Description Group No. No.
70 REACTOR BLDG CLOSED COOLING WATER 2 71 REACTOR CORE ISOLATION COOLING 1 73 HIGH PRESSURE COOLANT INJECTION 1 74 RESIDUAL HEAT REMOVAL 1 75 CORE SPRAY 1 76 CONTAXNMENT INERTING 2 77 RADWASTE 2 78 FUEL POOL COOLING 2 79 FUEL HANDLING AND STORAGE 2 80 PRIMARY CONT. COOLING 3 82 STANDBY DIESEL GENERATOR 1 84 CONTAINMENT ATMOS. DILUTION 2 85 CONTROL ROD DRIVE 1 86 DIESEL STARTING AIR 1 90 PROCESS RADIATION MONITORING 1 92 NEUTRON MONITORING 1 94 TRAVERSING INCORE MONITOR 1 96 'EACTOR RECIRC FLOW CONTROL 1 99 REACTOR PROTECTION 1 202 4KV UNIT BOARDS 1 203 4KV COMMON BOARDS 1 204 4KV UNIT START BD AND BUS 1 3 205 4KV COOLING TOWER SWITCHGEAR 3 210 4KV BUS TIE BOARD 2 211 4KV SHUTDOWN BOARDS AND BUSES 1 215 480V COMMON BOARDS 3 219 480V DIESEL AUX BOARDS 1 225 480V UNIT BOARDS 3 231 480V SHUTDOWN BOARDS 1 236 MAIN TRANSFORMER (500,'0.7KV) 3 237 SERVICE BUXLDING MAIN BOARD 3 239 480V LXGHTING BOARDS 3.,
240 480V WATER SUPPLY BOARD 3 241 161KV SWITCHYARD 3' 242 =
500KV SWITCHYARD AND GEN. 1, 2, 3 243 UNIT STA SERV TRANS (20.7, 4.16KV) 3 244 COMMUNICATION 1 245 COMMON STA SERV TRANS (161, 4.16KV) 3 246 COOLING TOWER TRANS (161, 4.16KV) 3 247 LIGHTING 3 248 250V DC UNIT BATTERIES 1 248 250V DC SHUTDOWN BATTERIES 1 249 PLANT PREFERRED 120V AC 3
ATTACHMENT 1 Page 3 of 3 RESTART TEST PROGRAM SYSTEM LIST Sys. Description Group No. No.
250 PLANT NON-PREFERRED 120V AC 3 251 48V DC POWER 3 252 UNIT PREF 120V AC 1 253 120V AC INSTRU AND CONT POWER 1 254 DIESEL 125V DC 1 255 DATA LOGGER 3 258 OPERATION RECORDER 3 261 COMPUTER 3 262 GENERATOR BUS 2 265 480V REACTOR BUILDING VENT BDS 1 266 480V CONTROL BAY VENT BDS 1 267 480V TURBINE BUILDING BDS 3 268 480V REACTOR MOV BOARDS 1 269 480V TURBINE MOV BOARDS 3 270 480V CONDENSATE DEMIN BDS 3 271 480V AUXILIARY BOILER BDS 3 272 480V WATER AND OIL STORAGE BDS 3 273 480V RADWASTE BOARDS 3 276 480V POWER CABINETS 3 278 240V DIST. CABINETS (500KV SW YD) 3 280 BATTERY BOARDS 1, 2, 3, AND 4 1 281 250V DC REACTOR MOV BOARDS 1 282 250V DC DISTR. BOARDS 1 283 24V DC POWER 3 L/L LOSS OF POWER/LOSS OF COOLANT ACCIDENT TEST NA BUC BACKUP CONTROL TEST NA ICF INTEGRATED COLD FUNCTIONAL TESTS NA
ATTACHMENT 2 Page 1 of 2 CHANGES IN RTP DESCRIPTION FROM OCTOBER 1986 SUBMITTAL TO NRC Addition of Joint Test Group (JTG): The earlier RTP description stated that, PORC would review and approve all documentation. The present RTP utilizes a dedicated JTG, conducted as a subcommittee of PORC, to more efficiently and effectively monitor the progress of the RTP. In addition, the JTG membership includes representatives from DNE and Modifications, not normally PORC members, who are closely associated with the RTF activities. PORC maintains cognizance of JTG activities by reviewing the JTG meeting minutes.
System Groups 1, 2, and 3: The earlier RTP addressed only the systems that were covered by the DBVP Test Requirements. The readiness of other systems would have been covered by the operations organization using the standard process of returning systems to service after an outage. The present RTP categorizes these other systems as group 3, and the readiness of systems in, this group will be documented with a system checklist. The BFN systems required to support safe and reliable power operation are addressed by the RTP.
SDSP 12.1, "Restart Test Program" and 12.2, "Development of System Test Specifications:" At the time of the earlier submittal to NRC, no detailed procedures had yet been written to control the RTP. Currently, SDSP 12.1 and 12.2 are the administrative procedures that cover site-wide support of the RTP. In addition, several section instruction letters that implement certain requirements of the SDSP are in place or being developed to control activities of the RTP section. Several administrative aspects of the RTP are now different than described in the earlier submittal.
o The STS will not be a "checklist" to specify and track existing site test instructions to be conducted for the RTP; this is now done in the RTP Test Instruction.
o Special test instructions as addressed in the October submittal will not be used. SDSP 12.1 specifies the test procedure format, conduct, and administrative control of RTP Test Instructions.
o Test engineers qualified to ANSI N45.2.6, as required by the present RTP, were not previously addressed.
o Previously, the system review was to cover "outstanding deficiencies such as SCRs, NCRs, CARs, and DRs." Because of the new TVA QA program for Conditions Adverse to Quality (CAQ), the CAQ data base will encompass these types of outstanding deficiencies. Future cAQs will replace the above deficiency documents and others; the RTP will address the CAQ Program and CAQ Reports.
I' ATTACHMENT 2 Page 2 of 2 o The RTP had intended to review modification workplans for postmodification test adequacy. There is an open TVA commitment to review all unit 2 cycle 5 modifications for adequate retest that is being addressed by the Post Modification Test Section; this effort will not be duplicated by the RTP.
Additional integrated system testing before startup: The earlier RTP description mentioned the loss of power/loss of coolant accident test.
The present RTP intends to perform two additional integrated tests; the backup control test and an integrated cold functional test,.
ATTACHMENT 3 Page 1 of 2 RESPONSES TO NRC QUESTIONS ON OCTOBER 1986 RTP DESCRIPTION
REFERENCE:
Letter from G. G. Zech, NRC, to S. A. White, TVA, dated March 3, 1987, "NRC Comments to Browns Ferry Unit 2 Restart Test Program Plan."
Comment 1: Provide the documentation and the bases that will be used for declaring systems operable that:
will not be included in the Restart Test Program Plan will not have a system test specification developed receive minimal or no testing,
RESPONSE
The revised RTP description and the revised SDSP 12.1, "Restart Test Program,"
provide for systems to be categorized into three groups. Group 3 systems will not be tested, but their readiness to support plant operation will be formally reviewed and documented using a system checklist. The basis for putting a system into group 3 is that it is not required to be tested as a result of the safe shutdown analysis by the DBVP, i.e., no test requirements were issued by DBVP.
Systems in group 3 will be verified to be ready to support plant operation using a system checklist (SCL). The SCL will also address group 1 and 2 systems and will record the status of a system and its documentation as a result of a review of items such as system procedures, hold orders, temporary alterations, Engineering Change Notices, drawing status, significant open maintenance requests, and a system walkdown.
Comment 2: Section II.A lists plant systems for which test specifications will be written, provide justification for not includingsystem. ECCS initiation signals, and the automatic depressurization
RESPONSE
Emergency Core Cooling System (ECCS) initiation signals, consisting of instrumentation for vessel level, vessel pressure, drywell pressure, and system logic relays, is specified to be tested in the following system test, specifications: System 74, Residual Heat Removal; System 75, Core Spray; System 73, High Pressure Coolant Injection; System 3, Feedwater; and System 64, Primary Containment. In addition, the LOP/LOCA Test will demonstrate integrated ECCS response to a simulated LOCA signal with and without an actual loss of offsite power.
The automatic depressurization system is specified to be tested in the main steam (system 1) system test specification.
ATTACHMENT 3 Page 2 of 2 Comment 3: The establishment of those administrative controls which will be used to conduct the test program and document test results are not well defined in your RTP plan. The program should address, in sufficient detail, attributes that are specifically germane to a test program. Examples of these are, but not limited to:
Test organization Preparation, review, and approval of test documents and test results Interface between licensee organizations Controls for handling test interruptions, test discrepancies, corrective actions, and test requirements Existing plant administrative controls that will be applicable to the restart te'st program Controls for scheduling test activities
RESPONSE
The administrative controls referred to are found in SDSP 12.1, "Restart Test Program," and SDSP 12.2, "Development of System Test Specifications." Current revisions of these procedures are available for review by the NRC Resident Inspectors who will be monitoring RTP progress. All of the above aspects are addressed within the procedures except as explained below.
The RTP Manager reports to the Site Director who provides interface with other TVA organizations. Other features of the RTP organization are shown in the attached organizational chart (figure 1).
I Controls for scheduling test activities are implemented by the Planning and Scheduling Section organization onsite. The schedule for testing is developed and maintained by the RTP using the Project 2 Schedule Program whi.ch schedules and tracks site activities related to the current outage and to the unit 2 restart efforts, including the RTP activities. Weekly status meetings are held to discuss progress, restraints, and support requirements with various organizations.
ENCLOSURE 2 LIST OF COMMITMENTS
'he resubmittal of the Restart Test Program contains a commitment not addressed in Volume III of the Nuclear Performance Plan (NPP). The commitment required TVA to add a member of the Joint, Test Group from the NSSS Vendor, General Electric.
NOTE: Procedures SDSP 12.1 and BF 1.10 are required to be revised. These revisions are scheduled to be complete by July 31, 1987.
The Restart Test Program is included in the NPP, Volume III, Section 8.0. The commitments in this submittal, except as indicated in (A), are addressed by this section of the NPP. I NOTE: Procedures SDSP 12.1 and 12.2 implement the requirements of the NPP.