ML19209B502
| ML19209B502 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/19/1979 |
| From: | Baer R Office of Nuclear Reactor Regulation |
| To: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 7910090808 | |
| Download: ML19209B502 (7) | |
Text
mc::::
~
~~
necu UNITED STATES
[
8
( ( },
NUCLEAR REGULATORY COMMISSION
/
g E
WASHINGTO N, D. C. 20555 t
8 g, ' v+...f SEP g 1979 Docket Nos. 50-445 and 50-446 Mr. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Byran Tower Dallas, Texas 75201
Dear Mr. Gary:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION AND STAFF POSITIONS FOR COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 Enclosed is a request for additional information which we require to complete our evaluation of your application for operating licerses for Comanche Peak Steam Electric Station, Units 1 and 2.
This request'for adgitional information and staff posi.tions is the result of our review by the Quality Assurance Branch of the information in Section 14.2, " Initial Test Program," of your FSAR.
Please amend your FSAR to include the information requested in the Enclosure.
Your schedule for. responding to the enclosed request for additional information should be submitted within four weeks.
Based on your schedule for response and our workload, we wiP c'?.termmc any licensing review schedule adjustments and inform you of any significant changes.
Since ely, Y kr Robert L. Baer, Chief Light Water :eactors Branch No. 2 Division of Project Management
Enclosure:
Request for Additional Information and Staff Positions ces w/ enclosure:
See next pages 4010090708 1120 m9
Mr. R. J., Gary.
Mr. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Bryan Towers Dallas, Texas 75201 Nicholas S. Reynolds, Esq.
Debevoise & Liberman 1200 Seventeenth Street Washington, D.C.
20036 Spencer C. Relyea, Esq.
Worsham, Forsythe & Sampels 2001 Bryan Tower Dallas, Texas 75201 Mr. Homer C. Schmidt Project Manager - Nuclear Plants Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Mr. H. R. Rock Gibbs and Hill, Inc.
393 Seventh Avenue New York, New York 10001 Mr.... T. Parker Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 Richard W. Lowerre, Esq.
Assistant Attorney General Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 Mrs. Juanita Ellis, President Citizens Association for Sound Energy 1426 South Polk Dallas, Texas 75224 Geoffrey M. Gay, Esq.
West Texas Legal Services 406 W.T. Waggoner Building 810 Ho;ston Street Fort Worth, Texas 76102 l
/
i Mr R. J'. Gary' Ms. Na.y Holdam Jacobson Citizens for Fair Utility Regulation 1400 Hemphill Fort Worth, Texas 76104 Mr. Richard Fouke 1668-B Carter Drive Arlington, Texas 76010 I120 021 9
ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION Af.D STAFF POSITIONS COMANCHE PEAK STEAM ELECTRIC STATICd, UNITS 1 AND 2 TEXAS UTILITIES GENERATING COMPANY MCKET NOS. 50-445/50-446 420.0 QUALITY ASSURANCE
?0tR 04 423.21 Your response to item 423.7 is not accepteM e.
ANSI Standard (14.2)
"45.2.5 was not intended to cover personr.s~ who direct or su;. rvise the conduct of preoperational t sts or personnel
..ho review preoperational or startup tes procedures or results.
Our current position is that these individt.als should hold the quali-fications stated in regula R position 3 of proposed Revision 2 to Regulatory Guide 1.8, February 1979 (issued for ccment).
State that your minimum qcalification requirements will be in accordance with this regulatory position or provide justification for requiring any lesser qualifications.
423.22 The response to item 423.8 is not totally acceptable.
(14.3) 1.
Your response indicates that the turbine ceitrol arm taypass valves, feedwater control system, and condenser circulating water system will not be included in the preoperational test program because they "are not required for safety."
It is our position that these components and systems are importar.t to. safety as described in General Design Criteria 12,13, and 44 of Title 10, Part 50, Appendix A of the Code of Federal Regulations and are also listed in items A.4.d, A.4.e, and A.4.f of Regulatory Guide 1.68, November 1973, as items that should be included in the preoperational test program.
Therefore, these components and systems should be tested as a part of the preoperational test phase of the initial test program.
Provide summaries of each test for our review.
2.
The response states that you do not intend to perform a natural cicculation test and that you will reference tests conducted at similar plants such as Zion and Trojan.
Provide your justification for utilizing this approach.
Specifically, provide (1) a description of all differences in reactor coolant system geometry (including reactor internals) and core pc';er level and geometry, (2) an explanation of why the test on the reference plant is applicable to Comanche Peak 9'ven these differences and (3) a description of flow (without pumps) and temperature data that will be compared with that from the reference plant to verify that they are comparable.
1120 022 3.
It is our position that you conduct a 100% generator load rejection by opening the generator breakers in a manner such that the turbine-generator will be subjected to the maximum credible overspeed.
Your response to item D.l.2 states that you will not conduct this demonstration because of potential for equipment damage.
The Chapter 15 analysis of this transient does not indicate that any damage is expected.
Describe in detail what damage you expect to sustain and provide technical justification for not conducting this test.
423.23 Modify Figure 14.2-3 to make it consistent with the response (14.2) to item 423.10 and modify section 14.2.7 :o make it consistent with the response to item 423.12, part 11.
423.24 Your response to item 423.12, part 10, refers to testing of the (14.2) electric hydrogen recombiners used for combustible gas control.
The question referred to the catalytic recombiner that is used for gaseous waste processing.
Expand the summary of the gaseous waste processing system (sheet 22) to describe testing of the recombiner.
423.25 Your response to item 423.12, part 14, states that the Diesel (14.2)
Generators Test Summary (sheet 34) has been expanded to conform to positions 2.a and 2.b of Regulatcry Guide 1.108 (Rev.1, 7-77 ).
It is not clear from the sumary that you will tert in accordance with positions 2.a(5) and 2.b.
Expand the test summary. to state that the full-load temperature demonstrations and the simultaneous starting test will be conducted.
423.26 Your response to item 423.12, part 18, states that preoperational testing of your compressed air system will not be conducted because it serves no :.afety function. Appendix A to 10 CFR Part 50, General Design Criteria 10 requires that the reactor core and associated cuolant control and pro-tective systems shall be des _igned with appropriate margi,n to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.
In addition, Criterion 12 requires that control systems be designed to assure that power oscillations that can result in conditions exceeding specified acceptable fuel design limits are not possible or can be detected and suppressed.
Therefore, we require that you conduct a test to confirm that the response of the reactor and associated systems is consistent with requirements of General Design Criteria 10 and 12 on a loss of the compressed air system. The staff guidelines for preoperational testing of the compressed air system are given in Regulatory Guide 1.80, "Preoperational Testing of Instrument Air Systems."
It is our position, in accordance with the provisior of 10 CFR Part 50, Appendix A, that you include testing of your compressed air system as ider.tified in Regulatory Guide 1.80, Revision 0, June 1974, in your preoperational test program.
1120 023
423.27 The response to item 423.12, part 19, is not totally acceptable.
(14.2)
Ycur eccident analysis assurptions for reactor protection system r 'ponse time include the time interval between the time that the process variable exceeds its trip setpoint until the time that the undervoltage coil on the reactor trip breaker is deenergized.
Your test summary (sheet 42) does not include a portion of this time interval in your test method.
It is our position that your test methods and acceptance criteria must account (analytically or experimentally) for the delay time of tr.a hardware between the measured variable and the sensor input.
(This hardware may include cuch items as instrument lines, snubbers, and flow limi.ing devices.) Modi fy your test sumr.ary to state how you will cccount 'or this delay time.
423.28 We have noted on other plant startups that the capacities of (14.2) pressurizer or main steam power-operated relief valves (PORV's) are sometimes in excess of the values assumed in the ac;ident analyses for inadvertent opening of these valves.
Provide a desc-iption of the testing that demonstrates that the capacity of these valves is consistent with jour uccident analysis assumptions.
423.29 The response to item 423.12, part 28, indicates that the process (14.2) computer will not b tested under the preoperational test program because it is not " safety related."
In most operating plants the process computer is used during normal operations for establishing conformance with limiting conditions for operation included in the technical specifications. Therefore, the computer is important to safety.
It is our position that you either (1) conduct tests which demonstrate correct inputs and outputs and c~ rect operation of hardware and sof tware under your preopera cional test program, and provide test surmlaries for the tests, or (2) provide technical justification for omitting this test from the preoperational test program.
423.30 The response to item 423.13 is not totally acceptable.
It is (14.2) our position that your snubber inspection progs am be expanded to include snubbers in high energy systems that are not
" safety related" (e.g., feedwater and main steam).
If the systems for which snubbers are being inspected will not be subjected to significant transients prior to fuel loading, then you should conduct inspections following the startup transient tests.
423.31 The response t: item 423.16, part 3, is not acceptable in that
/1.2) it only states who determines which RCCA is most reactive, and not hcw it is selected.
Is this rod determined to be the most reactive one experi antally or analytically?
- 1. ?. '. n, '.i
~?~
\\
.~
423.32 Your response to item 423.16, part 8, states thit the test (14.2) summary (sheet 21) has been expanded to thcw that the tes; will be in accordance with Regulatory Guide 1.68.2, Revisien 1, July 1978.
Modify the acceptance criteria to clarify :nat the ability to perform a safe shutdo,;n and to Ech',: eve and maintain hot standby condit: ens from "outside" the control room will be demonstrated.
423.33 The response to item 423.16, part 9, is not acceptable.
The (14.2) acceptance critecia in the Turbine Trip Test Sunmary (sheet 23) do not provide verification that plant anc control system response are in accordance with design; and the rc ponse does not ' ite what data will be compared to predicti
.it for the test case or what the. acceptance criteria will be for them.
It is our position that you (1) provide assurMr 2 that this data will include traces of important plant pa.emeters such as RCS pressure and temperature, pressurizer level, steam pressure, and power; and (2) provide a commitment that if any of the observed transients are more limiting than those predicted for. the test case, you will perform analyses as necessary to justify them or to adjust control system settings and repeat the test.
423.34 Your response to item 423.18 is not acceptable.
On FSAR (14.2) page 8.2-6 you state that "in the event one startup trans-former (e.g., XST1, a preferred source) becomes unavailable to its normally fed class lE buses, power is made available from the other startup transformer (e.g., XST2, an alternate source) by an automatic transfer (fast or slow transfer)."
Our concern is that this transfer might overload a startup transformer resulting in a degraded voltage situation on the ESF buses and failure of ESF equipment.
(See Power Systems Branch item 040.44).
It is our position that you demonstrate the capability of each startup transformer s a carry tha maximum load that it is postulated to carry during any mode of plant operation (including configurations where other transformers have failed and loads are automatically transferred to it).
Provide a summary of this test.
1120 025