ML19256F302
| ML19256F302 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/07/1979 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Eric Turner HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 7912180465 | |
| Download: ML19256F302 (17) | |
Text
L pa arco UNITED STATES
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NUCLEAR REGULATORY COMMISSION 23 gk7(
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DEC 7 1979 Docket Nov.: STN 50-498/499 Mr. E. A. Turner Vice President Housten Lighting and Power Company P. O. Box 1700 Houston, Texas 77001
Dear Mr. Turner:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW 0F THE SOUTH TEXAS FINAL SAFETY ANALYSIS REPORT (FSAR)
As a result of our continuing review of the South Texas FSAR, we find that we need additional infomation to complete our evaluation. The specific information required is in the area of initial testing and is listed in the Enclosure.
Please inform us when you plan to submit your responses to thic request.
If you desire any discussion or clarification of the enclosed request, please contact us.
Sincerely, YN fr OTan D. Parr, Chief Light Water Reactors, Branch No. 3 Division of Project Management
Enclosure:
As Stated cc: See Next Page 1609 041 7 91218 0 4-f5
Y:
Mr. E. A. Turner
^
cc: Mr. D. G. Barker Mr. Troy C. Webb Manager, South Texas Project Assistant Attorney General C
Houston Lighting and Power Company Environmental Protection Div.
- he' P. O. Box 1700 P. O. Box 12548 Houston, Texas 77001 Capitol Station Austin, Texas 78711 Mr. M. L. Borchelt Central Power and Light Company Mr. R. Gordon Gooch, Esq.
P. O. Box 2121 Baker & Botts Corpus Christi, Texas 78403 1701 Pennsyl vania Avenue, N.W.
Washington, D. C.
20006
- f.,
Mr. R. L. Hancock i
City of Austin Director, Governor's Budget Electric Utility Department and Planning Office P. 0. Box 1088 Executive Of fice Building Austin, Texas 78767 411 W. 13th Street Austin, Texas 78701 Mr. J. B. Poston Assistant General Manager for Operations John L. Anderson City Public Service Board Oak Ridge f dtional Laboratory P. O. Box 1771 Union Carbide Corporation San Antonio, Texas 78296 Bldg. 3500, P. O. Box X 7
Oak Ridge, Tennessee 37830 Mr. Jack R. Neman, Esq.
Lowenstein, Newnan, Axelrad & Toll 1025 Connecticut Avenue, N. W.
Washington, D. C.
20036 Mr. Melbert Schwarz, Jr., Esq.
k-Baker & Botts F
One Shell Plaza Houston, Texas 77002 g
Mr. A. T. Parker CY.
Westinghouse Electric Corporation M.
P. O. Box 355 Q,
Pittsburgh, Pennsylvania 15230 Mr. E. R. Sc hni dt fC
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NUS Corporation NUS-4 Research Place Rockyil1e, Maryland 20850
- l.
Mr. J. H. Pepin 7'i.
Brown & Root, Inc.
P. O. Box 3 Houston, Texas 77001 1609 042
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ENCLOSURE REQUEST FOR ADDITI0flAL IflFORMATI0fi FOR THE REVIF'l 0F THE FSAR pqR THE SOUTH TEXAS PROJECT, UtlITS 1 Aato 2 s
1 1609 043 l
423-1 423.0 INITIAL TESTIf;G 423.11 nd staffin In order to complete our review of the organizaki n ile minimum Eual1tication for the test program, we require that you prov de t l
requirements (educational, overall technical experience, and nuclear experi-ence) for the following categories of personnel at the time they are as-signed to the task. Your response should address all personnel performing the tasks listed and should not be limited to only STP personnel (e.g.,
B&R and Westinghouse augmenting personnel). Note that ANSI N45.2.6, although applicable to some categories of personnel during the construction, preoperational, and startup phases, was not intended to cover personnel in the categories listed below.
(1) Personnel that supervise or direct the conduct of individual pre-operational tests.
(2) Personnel that review and/or apprcve preoperational test procedures.
(3) Personnel that approve preoperational test results.
(4) Personnel that supervise or direct the conduct of individual startup tests.
(5) Personnel that review and/or approve startup test procedures.
(6) Personnel that approve startup test results.
Current staff reconnendations on qualification of these individuals are included in regulatory position 3 of proposed Revision 2 to Regulatory Guide 1.8, February 1979 (issued for comment). Revi e Section 14.2.2.8 accordingly.
423.12 Describe the training or indoctrination in administrative controls to be given to personnel who will participate in the initial test program.
423.13 Modify the test procedure format (Section 14.2.3.1) to include Environmental Conditions and Documentation of Test Results as described in Appendix C of Regulatory Guide 1.68.
423.14 In Section 14.2.4.4, 2(a), identify the " responsible supervisory personnel" who are authorized to approve minor changes.
423.15 Your response to question 423.4 is not entirely adequate. Revise Section 14.2.5 and Section 14.2.4.3 as necessary to indicate that a review of all proposed modifications and determination of retest requirements will be conducted by the original design organization or other designated design organization. Describe the review to be conducted after a work request has been returned to the Startup Group, and describe the reviews given an FREA by personnel other than the Startup Engineer.
M09 044
423-2 Describe the administrative controls that will ensure the required 423.16 continuity between the STP Startup Group and the STP Plant Staff in the transition between Phase II and Phase III testing.
Include the number of persons in the plant staff involved in Phase III testing, the aug-mentation of these persons from the Startup Group or outside contractors, and the. additional training that they will receive to familiarize them with previous test activities and administrative controls.
423.17 Section 14.2.7 indicates that exceptions have been taken to Regulatory Guides 1.52, 1.80, and 1.108. Modify this section to indicate the following:
(1) A review of the appropriate sections of Chapters 6 and 9 of your FSAR did not reveal any exceptions to the regulatory positions of Regulatory Guide 1.52 that deal with preoperational or start-up testing (Regulatory Positions Sa, b, c, and*d). Confirm that no exceptions have been taken to these positions. Exceptions to other portions of the regulatory guide will be evaluated by the cognizant NRC reviewer.
(2) Appendix A to 10 CFR Part 50, General Design Criterion 10 requires that the reactor ' core and associated coolant, control and protective systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of nomal operation, including the effects of anticipated operational occurrences.
In addition, Criterion 12 requires that control systems be designed to assure that power osci.llations that can result in conditions exceeding specified acceptable fuel design limits are not possible or con detected and suppressed. Therefore, we require that you conduct a test to confim that the response of the reactor and associated systems is consistent with the 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, "Preopera-tional Testing of Instrument Air Systems", Revision 0, June 1974 (3) Section 3.12 of the FSAR indicates that Regulatory Guide 1.108 is not applicable to your facility due to the implementation date.
The implementation section of Regulatory Guide 1.108, Revision 1, August 1977, clearly states that the guide represents current staff practice and will be used to evaluate applications. We therefore conclude that Regulatory Guide 1.108 is applicable to your facility.
Modify your FSAR to address how your initial test program will comply with Regulatory Positions C.2.a and C.2.b.
1609 045
423-3 423,18 Expand the information in Section 14.2.10.1, Initial Fuel Load, to address the following items, as indicated in Appendix C of Regulatory Guide 1.68:
(1) Composition, duties, and emergency procedure responsibilities of the fuel handling crew '2.a(1)
(2) Evacuation alarm and ventilation control - 2.a(2)
(3) Completion of fuel inspection - 2.a(4)
(4) Response checks of neutron monitors - 2.a(6)
(5) Status of vessel internals - 2.a(8) 423.19 Expand the information in Section 14.2.10.2, Initial Criticality, to indicate:
(1) That critical rod position and boron concentration will be calculated and what action will be taken if the estimates are exceeded.
(2) Required neutron instrument calibration and minimum count rate prior to beginning the approach to initial criticality.
423.20 Provide sufficient information in Section 14.2.11.2, Test Program Schedule, to ensure that the overlap of test schedules between Unit I and Unit 2 and the resultant shifting of Startup Engineers wiil not create significant divisions of responsibilities or dilutions of the testing staff (i.e., anticipated number of engineers shifted, whether they will work on both units simultaneously, and the organizational structure and administrative controls involved).
423.21 Provide assurance in Chapter 14 that, insofar as practical, the test requirements will be completed prior to exceeding 25% power for systems relied on to prevent, to limit, or to mitigate the consequences of postulated accidents, and that the safety of the plant will not be totally dependent on the performance of untested systems.
423.22 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 test description to address the following listed items:
1.
Preoperational Testing.
1.a(2)(a) - Pressurizer 1.a(2)(b) - Pumps, motors, and associated power sources 1.a(2)(c) - Steam generators 1.a(2)(d) - Pressurizer relief valves and supports and restraints 1.a(2)(e) - Main steam isolation valves 1609 046
423-4 423.22 1.a(2)(g) - Instrumentation used for monitoring system perfomance (Cont'd) or perfonning permissive or prohibit interlock functions.
1.a(2)(h) - Reactor vessel and internals
,1.a(2)(1) - Safety valves 1.a(3)-
Vibration tests 1.a(4) -
Pressure Boundary Integrity Test 1.d(1) -
Turbine bypass valves Steamline atmospheric dump valves 1.d(2 1.d(3 Relief valves 1.d(4 Safety valves 1.d 9) -
Condensate storage system
- 1. e 1 ) -
Steam generators 1.e 5) -
Steam extraction system 1.e(10) -
Feedwater heater and drain systems 1.h(1)(c) - ECCS demonstration 1.h(1)(d) - ECCS interlocks and isolation valves 1.h(4) -
Containment combustible gas control 1.h(8) -
Tanks and other sources of water for ECCS 1.h(10) -
Ultimate heat sink 1.j(1) -
Pressurizer pressure and level control 1.j(6) -
Loose parts monitoring 1.j(7) -
ECCS leak detection systems 1.j(8) -
Automatic reactor power control system, Tavg control system 1.j(9) -
Seismic instrumentation 1.j(17) -
FW heater temperature, level,and bypass control 1.j(20) -
Flooding detection 1.j(22) -
PAMS 1.j(25) -
Process computers 1.k(2) -
Personnel monitors and radiation survey instruments 1.k(3) -
HEPA filter and charcoal absorber inplace tests 1.k(5) -
Isolation of condenser off gas 1.k(0) -
Isolation of HVAC systems 1.k(7) -
Isolation of liquid radwaste effluent 1.n(10) -
Purification and cleanup of RCS 1.n(14) -
HVAC systems (specifically Containment Subsystems other than RCFC, Purge, and Isolation Valve Cubical HVAC, Fuel Handling Building HVAC, and Supplementary Fuel Pool Cooling) 1.n(18) -
Heat tracing and freeze protection 1.o(l) -
Crane load tests 1.o(2) -
Component handling interlocks 1.o(3) -
Safety devices on fuel handling equipment 4.
Low Power Testing 4.h -
Chemical and radiochemical tests to demonstrate chemical control and analysis systems 4.1 Rod withdrawal inhibit and interlock 4.k -
Operability of steam driven equipment Operability of MSIV's and branch steam line valves at 4.1 rated temperature and pressure 4.n -
Control room computer Demonstration of pressurizer and main steam relief 4.p valves at rated temperature 1609 047
423-5 423.22 4.t -
Performance of natural circulation test (Cont'd) 5.
Power Ascension Tests 5.1 ECCS demonstration RCS demonstration 5.m Loose parts monitoring baseline data 5.n RCS leak detection 5.o Verification of computer inputs and calculations 5.q MSIV and branch line isolation valves 5.u 5.v Main steam and feedwater verification 5.aa -
Chemical and radiochemical control demonstration 5.bb -
Neutron and gamma surveys 5.cc -
Radwaste demonstrations 5.11 -
Reactor Coolant Pump Trip tests 5.kk -
Loss of feedwater heater tests 5.mm -
MSIV closure test 5.nn -
Load rejection test 5.00 -
Piping movement, vibration and expansion 423.23 We could not conclude from our review of the preoperational test phase description and the test summaries provided in Section 14.2.12.2 that comprehensive testing is scheduled for several systems or components.
Therefore, clarify or expand the description of the preoperational test phase to address the following:
(a) 2.
Unit Standby Transformers - Expand the test description and acceptance criteria to include testing to ensure that ESF bus voltage will not be degraded if the standby transformers are subjected to the transient produced if, while carrying the
.ull load of one unit, the ESF loads of the second unit are automatically switched to a single standby transformer.
(b) 4.
Plant Lighting - Specify that both AC and DC emergency lighting will be tested and verify that DC lighting will be available for a minimum of four hours.
(c) 17.13.8KV Emergency Gus - Modify the test description to specifically describe testing of the undervoltage relays and the breaker inter-locks that prevent supplying the transfonner from two sources.
(d) 18. Heat Tracing - Modify the test description to identify the systems on which heat tracing will be tested.
(e) 19. Communications - Modify the test description to ensure that all systems assumed to function in the emergency plan (radios, telephone circuits, as well as in-plant systems) function properly.
Include testing of the in-plant systems in high noise areas to ensure that they can be heard over the maximum operational noise level in the: area.
(f) 21.125VDC Battery Bus and Bus Channels I, II, III, and IV - Expand the test description to confirm that individual cell limits are 1609 048
423-6 423.23 (Cont'd) not exceeded during the design discharge test and specify the minimum acceptable teminal voltage.
Demonstrate that DC loads will function as necessary to assure plant safety at a battery terminal voltage eaual to the acceptance criteria that have been established for minimum battery terminal voltage for the discharge test. Describe your plans to demonstrate proper calibration and trip settings of protective devices, alams, and ground detection devices.
(g)
- 22. 4.16KV Class lE Switchgear
- 23. 480V Class lE Switchgear
- 24. 480V Class lE MCC Modify these tests as necessary to include verification of under-voltage protection devices and that connected loads will function as necessary to assure plant safety at the minimum bus voltage that can exist prior to bus trip.
(h) 26. 120VAC IE Bus, Channel I, II, III, and IV - Expand the test description to include operation of connected loads from the alternate 120V single phase regulated supply and testing of the interlocks which prevent connecting the alternate supply while the inverter is powering the bus.
Include acceptance criteria to ensure that the 120VAC supply will maintain 60t 0.5HZ and ll5V t 2% as described in your FSAR.
(i) 28. Containment HVAC Nomal and Supplementary Purge Subsystem -
Expand the test description to include testing of the isolation features to verify isolation times.
(j ) 29. Containment HVAC RCFC System - Describe how testing will verify that the RCFC can maintain temperatures inside containment at 0
6120 F during normal operation.
(k) 31. Containment HVAC Isolation Valve Cubicle Subsystem - Expand the test description to include testing of the system's ability to maintain temperatures in the AFW pump areas within design limits with design heat loads produced in the areas.
(1) 32. MAB HVAC - Expand the test description to include testing to demonstrate propar operation of lab and sample room exhaust fan bypass and seal line dampers.
(m) 33. EAB HVAC - Expand the test description to specifically address control room subsystems, including makeup requirements, pressuri-zation of the air intakes between dampers, makeup ACU's, switch-over from MAB to EAB chilled water, fire damper operation, pressure controller operation, and isolation on detection of actaldehyde and vinyl acetate. Also describe testing to ensure that upon failure of the battery rooms' centrifugal exhaust fans, discharge through transfer ductwork will be sufficient to main-tain hydrogen concentration below 2%.
1609 049
423-7 423.23 (n ) 34. Diesel-Generator Building HVAC - Expand the test description (Cont'd) to include testing of the Fuel Tank Room heating and ventilat-ing system and purge. Also, describe testing of the oil bath inlet filters and operation of the temperature controllers and dampers.
(o) 40. EHC System - Expand acceptance criterion b.2 and method d.1 to identify the valves to be tested and provide assurance that quantitative acceptance criteria will be established. Provide the basis for the quantitative acceptance criteria.
(p)
- 41. Containment Hydrogen Monitors - Expand the test description to indicate that the alarm function at 3.5% hydrogen concentration will be tested.
h). 42. Solid-State Protection System (SSPS) - Identify the specific subsystems to be tested and relate them to their specific technical specification limits.
Specify how the response time testing of reactor trip signals will verify time response from when the variable makes a step change from 5% below to 5% above the trip setting to the point where the rods are free, as described in your FSAR. Modify the acceptance. criteria to ensure that the response times of protection channels account for the response time of the associated hardware between the measured variable and the input to the sensor (snubbers, sensing lines, flow limiting devices, etc.) for all channels for which response time limits are included in your technical specifications.
(The delay times of instrument lines may be accounted-for analytically.)
(r) 43. ESFAS Train A, B, and C - Modify the test description to identify the subsystems which will be tested and describe the testing to be performed to verify system response times.
Describe testing of the ESFAS inputs from the Solid State logic Protection System and testing of the ESFAS test cabinet.
In Method stcp d.2),
identify the " required conditions" to be simulated.
(s ) 44. RCPB Leakage Detection System - Modify the acceptance criteria to correspond to the test method in Section d.
Describe the testing that will confirm the ability to detect intersystem leakage into.
systems that interface with the RCS.
(t) 48. Boron Concentration Measurement System - Verify that actual reactor coolant will be sampled by the system and the indicated concentration compared with samples analyzed in the laboratory.
(u) 50. Process and Area Radiation Monitoring System - Specify whether the isolation features of the RCB stack, GWPS discharge, spent fuel pool ventilatiorr exhaust, Boron Recycle System distillate, LWPS discharge, CCW system, and turbine generator building drain monitors, as described in Section 11.5 of your FSAR, will be tested in this test or in the individual test descriptions for 1609 050
423,8 423.23 (Cont'd) these systems. Modify the appropriate test descriptions as necessary. Describe testing to ensure that sample paths and flow rates to detectors, as appropriate, are in accordance with design requirements.
(v) 51. Fire Protection Systems (Water Subsyste.n) - Ensure that. testing will be done to verify that the diesel driven pumps wi)1 start from cold conditions.
(w) 62. Primary Sampling System - Expand the test description to include verification that sample accuracies are sufficient to verify technical specification requirements.
Describe the testing to verify that sample line isolation valves function as assumed in the accident analysis.
(x) 65. Main Feedwater System - Modify the acceptance criteria to ensure that feedwater isolation valves close in less than 5 sec. and that instrument time delays are less than 1.5 sec. as assumed in the FSAR.
(y) 68. Circulating Water System - Modify the test description to include testing of the traveling screens and screen wash system.
(z) 71. Instrument Air System - In accordance with question 423.17b.,
modify the test description to conform to Regulatory Guide 1.80.
Provide a description of testing to be conducted. on the Station Air system to ensure that it can supply a sufficient quantity of clean, dry air to the instrument air system, if required.
Include testing of the automatic controls that link the syrtems on low pressure in the instrument air header.
(aa) 72. Chemical Feed System - Identify the systems and chemicals included in this test.
(bb) 73. RCS Hydrostatic Test - Rename the test to indicate that it is a cold, integrated system test not a hydrostatic test. Expand the test to include integrated testing of auxiliary sy2tems as per Regulatory Guide 1.68, Appendix A, Section 1.a(1).
(cc) 75. Pressurizer Relief Tank - Describe the testing to be conducted to verify operation of the internal spray and to verify tank temperature and pressure following a design blowdown (110% of pressurizer steam space volume).
(dd) 76. Safety Injection System Train A, B, and C - Expand the test description, especially the acceptance criteria, to include the tests committed to in Section 6.3 of your FSAR.
Expand the test description to include both the hot and cold tests described in Regulatory Guide 1.79, and to ensure that instrumentation tests, 1609 051
423-9 423.23 (Cont'd) test initiation methods, component vibrations, system ficws, and response times are included.
Describe testing to verify accumulator N2 pressurization functions properly.
Incit.de testing tc ensure that ESF pumps will perform satisfactorily when run for extended periods of time on the recirculation lines (i.e., do not overheat, cavitate, etc.).
(ee ) 78. RHR System - Expand the test method and acceptance criteria to identify the design point at which pump performance is determined, to specifically describe testing of isolation interlocks and controls which prevent system over pressurization, and to verify operation to transfer water from the RWST to the refueling cavity.
(ff ) 79. Containment Spray System - Describe the testing planned to verify the system response time from spray initiation on Hi2 or Hi3 con-tainment pressure and spray flow transit time.
Identify the design point at which pump operation will be verified.
Ensure that the point at which air will be introduced in the spray nozzle test is upstream of the valves used to isolate the nozzels from pump discharge flow when verifying system flow to the RWST (i.e.,
the test boundaries should overlap).
( gg)
- 80. CVCS'- Expand the acceptance criteria to more specifically relate to the test method.
Identify the design point at which charging pump perfomance will be verified. Describe testing of pump mini-flow recirc and recirc isolation, auxiliary. spray flow, adjustment of pump-seal flow, diversion of letdown or pump suction on VCT levels, operation in Automatic, Dilution, Al-ternate Dilution, Boration, and Manual modes, and the interlock to prevent injection while in manual mode.
( hh)
- 81. Standby Diesel Generator - Modify the test description in accordance with question 423.17c.
(jj)
- 85. Auxiliary Feedwater System - Expand the test to include verification that maximum and minimum flows are within the design range and that response time for flow initiation is less than assumed.
Include testing that will ensure that the APA pumps will perform satisfactorily when run for extended periods of time on the recirculation lines (i.e., do not overheat, cavitate, etc.).
( kk)
- 86. Fuel Handling Equipment - Identify the cranes, hoists, and equip-ment that will be included in the test.
( 11)
- 87. Spent Fuel Pool Cooling System - Expand the test description to include testing of the skimmer loop, antisiphon holes, and liner leak detection and alarm.
1609 052
423-10
- 88. Essential Cooling Water System - Expand the test description 423.23 (m )
(Cont'd) to include testing of the compartment water tight doors and the Include interlocks that prevent opening more than one door.
testing of the pump auto starts on diesel generator and CCW initiation.
Identify the pump design raint.
- 89. Component Cooling Water - Expand the test description to include (nn) testing of the auto-isolation of non-ESF loads on SIS, the auto-matic isolation of the surge tank vent on high radiation, and ver ification of w. ster chemistry.
Identify the pump design point.
(30) 93. Containment Integrated Leak Rate T?st - Expand the test description to include Type A, B, and C testina in accordance with Appendix J to 10 CFR Part 50 or reference appropriate sections of your FSAR.
Include the test method, duration of stabilization and test periods, method of isolation valve closure, and tests of personnel and equip-ment air locks.
(pp) 94. Radioactive Equipment and Floor Drain Sump System - Expand the test description to include the 10 ft. of water or 5 psig air test described in the FSAR.
(qq) 95. Solid Radioactive Waste - Expand the test program to include testing of cement metering, chemical neutralizer operations, and sonic probes and level switches on mixing tank and containers.
Include testing to ensure that free liquid is not present following solidification.
(rr) 98. R',5 Hot Functional Test - Several test descriptions (AFW, Main Steam, ECCS, etc.) contain notes on tests to be conducted during hot functional testing.
Either expand the individaul test descriptions or the Hot Functional Test description to provide test methods, test objectives, and acceptance criteria for these tests.
Ensure that testing will demonstrate heat exchanger and cooling water systems performance at design load or at conditions that can be extrapolated to design conditions.
423.~24 Recently, questions have arisen concerning the operability and dependability of certain ESF pumps in PWR's.
Upon investigation, the staff found that some completed preoperational test procedures did not describe the test conditions in sufficient detail.
Provide assurance that the preoperational test procedures for ECCS and containment cooling pumps will require recording the status of the pumped fluid (e.g., pressure, temperature, chemistry, amount of debris) and the duration of testing for each pump.
423.25 Cur review of recent licensee event reports disclosed that a significant number of reported events concerned the operability of hydraulic and mechanical snubbers.
Provide a description of the inspections or tests that will be performed following system operation to assure yourself that the snubbers are operable.
These inspections or tests should be performed preoperationally if system operation can be accomplished prior to generation of nuclear heat.
1609 053
423-11 423.26 Provide test descriptions or modify existing test descriptions to assure that tests will be perfomed to demonstrate (1) that the plant's ventila-tion systems are adequate to maintain all ESF equipment within its design temperature range during normal operations and (2) that the emergency ventilation systems are capable of maintaining all ESF equipment within its design temperature range with the equipment operating in a manner that will produce the maximum heat load in the compartment.
If it is not possible to operate equipment to produce maximum heat loads, describe how the tests performed satisfy the objectives listed above. Also include testing in accordance with Regulatory Guide 1.52 or 1.140, as applicable.
423.27 (1) Provide descriptions of the electrical lineups of both units during preoperational testing of Unit 1 in accordance with Regulatory Guide 1.41.
Include an evaluation of how this lineup precludes inadvertently powering Unit 1 busses from Unit 2 sources. Address both normal and emergency power distribution systems.
(2) Provide descriptions of the electrical lineups of both units during preoperational testing of Unit 2 in accordance with Regulatory Guide 1.41 s# equent to initial criticality of Unit 1.
Provide assurance that crossties between the units that could result in loss of power to any Unit 1 emergency bus due to testing of Unit 2 do not exist. Address both normal and emergency power distribution systems.
(3) Provide a test description for integrated electrical system testing to accomplish these objectives.
423.28 Mooify the test descriptions for all 3,ystems that peietrate enntainment and will be operated in post-accident conditions, to eraure that leak-rates are in ac:ordance with design and release limits.
423.29 Describe the testing to be conducted to verify that the capacity of pressurizer and steam generator power operated reliefs and steam dump and turbine bypass valves are within the minimum and maximum values assumed in the accident analysis.
423.30 Identify any of the initial startup tests described in Section 14.2.12.3 that are not essential towards the demonstration of conformance with design requirements for structures, systems, components, and design features that:
( 1) will be relied upon for safe shutdown and cooldown of the reactor under normal plant conditions and for maintaining the reactor in a safe condition for an extended shutdown period; or
( 2) will be relied upon for safe shutdown and cooldown of the reactor under transient (infrequent or moderately frequent events) conditions and postulated accident conditions, and for maintaining the react'or in a safe condition for an extended shutdown period following such conditions; or (3) will be relied upon for establishing conformance with safety limits or limiting conditions for operation that will bp frh /
L J 7dr3the
$ der l facility technical specifications; or iU
423-12 423.30 (4) are classified as engineered safety features or will be relied (Cont'd) upon to support or assure the operations of engineered safety features within design limits; or (5) are assumed to function or for which credit is taken in the accident analysis for the facility (as described in the Final Safety Analysis Report); or (6 ) will be utilized to process, store, control, or limit the release of radioactive materials.
423.31 Your response to' question 423.5 is inadequate.
If any test summarized in Section 14.2.12.2 of your TSAR will not be completed prior.to fuel loading, identify it and provide the infomation requested in 423.5.
423.32 Section 14.2.5 identifies the plateaus for the power ascension testing.
Indicate either in each test summary or elsewhere in Section 14.2 (a table or figure) which tests will be conducted at each plateau. Test power levels should be consistent with Regulatory Guide 1.68, Rev. 2, Appendix A.
Also, indicate in Section 14.2.5 that test results for each test conducted at a given plateau will be evaluated prior to proceeding to the next level.
~
423.33 We could not conclude from our review of the startup test summaries in Table 14.2-3 that all of the tests will be comprehensive.
Therefore, clarify or expand the summaries to address the following:
(a )
1.
Moveable Incore Detector - Describe testing which will verify detector response to actual flux.
(b) 2.
Rod Position Indicators - Expand the test description to include testing of the bank insertion monitor, deviatior, alams, and rod bottom bistable setpoints and alarms.
(c) 3.
Rod Control System - Identify the "various modes" to be tested.
(d) 5.
Rod Drop Time Measurement - Describe the additional testing that will be conducted for the rods falling outside the two-sigma limit at each test condition.
Also describe the tests planned to demonstrate proper operation of the decelerating devices.
b) 6.
RCS Flow Test - Describe your ple.ns for vibration monitoring and operation of pump anti-reverse rotation devices.
(f) 8.
RTD Bypass Flow Verification - Modify the test description to include the RTD accuracy comparisons described in Section 7.3 of your FSAR.
( g) 9.
Reactor Trip Circuit - Expand the test description to incl ide testing to ensure that control rod drive latching mechanisras will unlatch upon opening of the trip breakers; that simulated 1609 055
423-13 423.33 (Cont'd) trip signals will open the trip breakers; that if the associated trip breaker bypiss3 is shut, opening of the trip breaker does not cause a reactor trip; and that interlocks to prevent closing of both reactor trip bypass breakers simultaneously function properly. Also describe testing you have planned to demonstrate operation of rod motion blocks and turbine runbacks.
(h)
- 12. Zero-Power Physics Tests - Revise acceptance criterion 3, dif-ferential boron worth, to relate to values assumed in the FSAR such as maximum CVCS reactivity insertion rates. State how yor will determine the most reactive RCCA.
(i) 14. Nuclear Instruments - Expand the test to include detennination that excore instrumentation can detect axial flux differences and fuel pin and core barrel movement as assumed in the FSAR.
(j)
- 15. Effluent Radiation Monitors - Modify the test description to include demonstration of proper operation of Effluent, Process, and Area Radiation Monitors under operating conditions.
Provide acceptance criteria for verification by performing independent laboratory or other analyses.
(k)
- 19. Plan.t Response to Load Changes - Modify the acceptance criteria to specifically relate to each test to identify the specific control actions expected to occur or not to occur.
Specify the modes that major control systems will be tested in.
Expand the acceptance criteria to address acceptable overshoot, undershoot, or oscillation.
(1) 20. Rod Control System At-Power - Modify the acceptance criteria to identify " unacceptable overshoot."
(m) 22. Turbine Trip - Expand the test summary to identify the parameters to be recorded and control functions which will be observed. The acceptance criteria should be expanded to ensure that the recorded parameters and observed transient results will be compared with predicted results for the actual test case, and quantitative values should be provided for the required convergence of actual test results with predicted values. The basis for these criteria should be provided.
(n) 23. Loss of Offsite Power - The test should demonstrate for approximately 30 minutes that the necessary equipment, controls, and indications are available following the station blackout to remove decay heat from the core using only emergency power supplies.
Verify that opening the switchyard circuit breakers results in the maximum credible turbine oversp,eed condition.
(o) 24. Shutdown from Outside the Control Room - Expand the test description to more completely discuss compliance with Regulatory Guide 1.68.2.
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423-14 423.33 (Cont'd)
Include commur.ication with and responsibility of control room observer, control of transferred components, number of persons conducting the test, duration of test, and cold shutdown demon-stration.
Update your comitment in Section 3.12 to indicate compliance with Revision 1 to Regulatory Guide 1.68.2 (July 1978) which is applicable to your plant.
(p) 26. Static RCCA Drop and RCCA Below-Bank Position Measurements - Modify acceptance criterion 2 to indicate that excore or incore instru-mentation will detect a misaligned RCCA when the misalignment is outside the technical specification limits. Modify acceptance criterion 4 to conform to technical specification 3/4.2. 4.
Indicate in the test method tnat a high worth RCCA will be inserted. Expand the test method and acceptance criteria to include returning the rod to its proper bank position.
(q ) 27. Pseudo Rod Ejection Test - Modify acceptance criterion 2 to indicate that excore or incore instrumentation will detect a misaligned RCCA when the misalignment is outside the technical specification limits.
423.34 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.
423.35 Provide assurance that acceptance criteria will be established for startup tests based on realistic analysis of transients rather than accident analysis assumptions and that test results will be compared with the results of these analyses.
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