ML19261C469
| ML19261C469 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/28/1979 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Varga S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML111090060 | List:
|
| References | |
| FOIA-80-515, FOIA-80-555 NUDOCS 7903220514 | |
| Download: ML19261C469 (16) | |
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i FEB 2 81973 DISTRIBUTI0ft:
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MEMORAt1DUM FOR:
S. A. Varga, Chief, Light Water Reactors Branch No. 4, Division of Project Management f
FROM:
Walter P. Haass, Chief, Quality Assurance Branch, Division of Project Management i
l
SUBJECT:
STAFF POSITI0rls At1D RE0 VESTS FOR ADDITIOrlAL INFORMATI0ft:
i MIDLAtiD PLANT Ut1IT f1OS. 1 & 2, INITIAL TEST PROGRAM Applicant: Consumers Power Company (CPCo)
Licensing Stage: OL Responsible Branch: LWR #4
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Project Manager: Darl Hood l
Requested Completion Date: February 28, 1979 s
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The Quality Assurance Branch has reviewed the FSAR sections describing the initial test program through Amendment 57. The enclosure lists our staff positions and requests for additional infomation for Midland 1 and 2.
6 By copy of this meno, we are also forwarding the enclosure to the DSS branches who have secondary review responsibility for Section 14.2.
Any coceents or recemendations from the assigned reviewers in these branches should be addressed to R. McDermott of the QAB by March 16, 1979.
t Original signed by:
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J. W. Gilray Walter P. Haass, Chief Quality Assurance ~ Branch j
Division ~of Project Management
Enclosure:
Staff Positions and Regt'ests for Additional Infomation for Midland Plant Unit Mos. I and 2 79032205t4 cc w/ enclosure:
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Midland 423.0 QUALITY ASSURANCE BRANCH - INITIAL TEST PROGRAM 423.1 Our review of your preccerational test phase provided in (14.2)
Table 14.2-1 disclosed that several systems and design features may not be scheduled to be preoperationally tested. The staff's evaluation of your preoperational test phase was based on the following:
a.
Comparison of your proposed test program with applicable regulations cnd Regulatory Guides, including Appendix J to 10 CFR 50 and Regulatory Guides 1.20, 1.41, 1.52, 1.68, 1.68.2, 1.79, 1.80, and i.108.
b.
Comparison of your proposed test program with the structures, systems, components, and design features included in your facility design that:
(1) Will be relied upon for safe shutdown and cooldown of the reactor under normal plant conditions.
(2) Will be relied upon for safe shutdown and cooldown of the reactor under faulted, uoset, or emergency conditions.
(3) Will be relied upon for establishing conformance with safety limits or limiag conditions for coeration that will be included in the facilities' Technical Specifications.
(4) Are classified as engineered safety features or will be relied upon to support or assure the operation of engineered safety features within design limits.
(5) Are assumed to function and for which credit is taken in the accident analysis for the facility.
(6) Will be utilized to orocess, store, control, or limit tne release of radioactivity.
. The description provided in Section la of the FSAR of your preoperational test phase should be expanded or modified to address your plans relative to the following:
a.
Your plans relative to i'1-plant preoperational testing in accordance with Regulatory Guides 1.41, 1.68.2, 1.80, and 1.108. Your response should include both identification of any regulatory position contained in the above listed guides that you do not plan to follow and technical justi-fication for any exceptions taken. Your response should also specifically address items A.1.b.(4), A.4.b., A.S.d.,
A.S.q, A.7.d, A.10.c and A.10.e of Regulatory Guide 1.68 and provide a clear description of how you will satisfy the regulatory positions in Regulatory Guide 1.41 during preoperational testing of systems and components that are supplied onsite AC and DC emergency power.
The staff notes your position relative to Regulatory Guide 1.80 contained in Appendix 3A of your application and disagrees with your position. This guide is applicable since it is used as a source of air.for systems and components that provide a safety function. Therefore, modify your application to show thac your test program will be consistent with the guide or to show that you will conduct equivalent testing for the air system and supplied loads.
Test abstracts for the above issues should be provided or modified, as appropriate.
b.
Your plans relative to in-plant preoperational testing of the following. Test abstracts should be provided or modified, as appropriate.
(1) Borated water storage tank auxiliaries including systems used for temperature control and indication and alarm functions.
(2) Leakage tests of ECCS and containment spray systems and testing of leak detection and alarm systems provided to control leakage from these systems.
(3) Testbg of valves located in drain lines from rooms housing citical equipment to assure leak tightness and correct failure mode.
. (4) Auxiliary building crane, (5) Ventilation systems, caustic scrubbers and sump pumps (at Dow) for mitigation of chlorine spills.
(6) Leakage tests of guard pipe around suction lines from the containment sumps.
(7) Service water cooling towers and auxiliaries.
(8) Equipment and controls for remote shutdown from outside the control room.
(9) Reactor coolant system low temperature overpressure protection features.
423.2 The staff's review of your individual preoperational test (14.2) descriptions disclosed.that the information provide in several of these descriptions is not sufficient for the staff to conclude that adequate testing will be performed on the systems and components covered.
Expand and/or modify the test abstracts to provide the following:
(1) 14A.l.1 Main Steam Isolation Valves - Expand the abstract to show that redundancy of initiating logic, correct failure mode, and combined closure response times for instrumentation and valves will be verified. Confirm that the valves will be tested at approximately normal operating temperatures or justify testing at other conditions.
(2) 14A.l.2 Main Turbine System - Expand the abstract to show that appropriate tests will be conducted for turbine non-return, intercept and intermediate stop values.
Also show that the turbine overspeed protection system will be tested.
Identify the portions of the test that will not be completed prior to fuel loading and state when the tests will be completed relative to a milestone in the test prograni.
(3) 14A.l.3 Condensate and Condensate Demineralizer Systems -
Identify the portions that will not be completed prior to fuel loading and state when they will be completed.
(4) 14A.l.4 Feedwater System - Expand the abstract to show that condensate and feedwater heater controls, valves,
. and pumps will be appropriately tested. Also confirm that main feedwater pump trip interlocks will be tested, that response times of feedwater isolation sensors, logic and valves will be demonstrated, and that system redundancy will be demonstrated for the feedwater isolation function.
Identify the portions of the test that will not be completed prior to fuel loading and state when these portions will be ccmpleted.
(5) 14A.l.5 Auxiliary Feedwater System - Expand the abstract to show that the F.0.G.G. system will be tested to assure it operates per design, that the instrumentation and valves associated with the protection of the suction lines to the AFW pumps will be tested to assure redundancy, correct assignrant of power supplies (electrical indepen-dence), response times within design and leak tightness of system valves.
Confirm that the steam driven AFW pump will be tested over the design range of inlet steam pressures to assure the pump head / capacity will satisfy design. Address system response times.
(6) 14A.l.8 Process Steam Evaporators System - Expand the abstract to identify the testing planned for protective interlocks associated with supply and cross-tie valves from both Units 1 and 2 to the Process Steam System.
(7) 14A.1.10 Pressurizer Safety Valve Test - It is our position that the safety valves be tested in place under hot plant conditions or that justification be provided for bench testing including correlations between bench test methods and expected valve performance in service conditions.
(8) 14A.l.ll Decay Heat Removal System - Expand the abstract to show that testing will be accomplished to assure proper operation in all design modes of system operation.
Also confirm the overpressure protection and isolation capability (sensors, logic and valves) from the reactor coolant system will be tested to confirm redundancy and correct assigr. ment of power supplies (electrical indepen-dence).
(9) 14A.l.12 Lcw-Pressure Injection Engineered Safety Features Test - Expand the test abstract to describe how the injecticn ficw rate into the reactor coolant systen will reach steady-state values before the system beccmes solid.
State hcw redundancy and electrical independence will be demonstrated; for system sensors, logic, and valves, state that system response times will be verified to be within design values; state that the " piggy-back" mode of operation with the high pressure injection system will be demonstrated; and define what NPSH measurements will be obtained. Also explain or ciarify test method item 3.1 and modify the acceptance criteria to provide upper and lower bourds for injection flow capability to assure injection flow capability sufficient to satisfy safety assumptions and also assure that pump ficw remain below values that could compromise NPSH.
(10) 14A.l.13 Makeup, Purificaticn, and Chemical Addition System - Expand the abstract to show that system valves will be demonstrated to operate per design to an RAS signal and that associated sensors, initiating logic, and valves wi D be tested to assure redundancy and electrical independ,ence. Also indicate that redundancy and electrical independence will be demonstrated for protection features for isolation of thc letdown cooler and that associated valves meet design closure times.
(11) 14A.l.14 High Pressure Injection Engineered Safety Features Test - Expand the abstract to provide test objectives, methods and acceptance criteria for:
(a) " piggy-back" mode of operations, (b) demonstrating redundancy and electrical independence
- and, (c) thorough checkout of the swing pump and auxiliaries using both electrical power sources.
Describe how steady-state flow conditions can be established and confirmed for the proposed plant status.
(Section 2 of the test prerequisites.) Also provide acceptance criteria for system response times.
(12) 14A.1.lS Core Flooding System - Expand the abstract to establish that instrumentation, controls and alarms will be verified to function in accordance with design.
(13) 14A.l.16 Reactor Building Spray System - Expand the test abstract to provide assurance that redundancy, electrical independence and response times will be verified.
Also provide assurance that system respor.se to RAS will be demonstrated to function in accordance with design.
(14) 14A.l.17 Borated Water Storage Facility Test - Expand the abstract to provide assurance that redundancy and electrical independence will be. demonstrated for the isolation valves and controls in the BWST recirculation system. Also provide assurance that heat tracing for the tank vent works as designed.
(15) 14A.l.18 Reactor Building Local Leak Rate Tests - Expand or provide an additional abstract to describe tests planned for the Penetration Pressurization System and the Containment Isolation Valve Seal Water System.
Your response should include objectives, methods and acceptance criteria sufficient to assure that these systems work in accordance with design including redundancy, electripal independence, response times, and capacities.
(16) 14A.l.19 Main Condenser and Condenser Evacuation System -
Expand the abstract to identify the portions that will not be completed prior to fuel loading and specify the milestones when the delayed portions will be completed.
(17) 14A.l.22 Service Water Cooling System - Expand the abstract to provide assurance that (1) Redundancy and electrical independence will be demonstrated.
(2)
Intake screens, sluice gates and level sensors and other actuation signals will be verified to function per design including redundancy and electrical independence.
(3) The " swing" pump and associated auxiliaries will be demonstrated using both power sources.
(4) Cooling tower isolation features will be demonstrated to function per design including redundancy and electrical independence.
(5) Intake screen auxiliaries and system strainers will be tested.
(6) Sensors, logic and isolation valves on the turbine building service water system function per design.
(7) Adequate margins for NPSH and vortex ca.itrol are verified for the pumps at or below the level in the pump pit at which the sluice gates are designed to open automatically.
(18) 14A.l.23 Fuel Pool Cooling and Purification System -
Expand the abstract to provide objectives, methods and acceptance criteria for the siphon breakers.
(19) 14A.l.24 Component Cooling Water System - Expand the abstract to provide assurance that (1) Design heat removal capability will be verified for all heat exhangers.
(2) The " swing" pump and auxiliaries will be demonstrated to function in'accordance with design including redundancy and electrical independence.
(3) Sensors, logic and isolation valves for low surge tank levels function in accordance with design including redundancy and electrical independence.
(20) 14A.l.25 Chilled Water and Safeguards Chilled Water Systems - Expand the abstract to provide assurance that (1) Heat exhangers will be verified to satisfy design requirements.
(2) Redundancy and electrical independence for the system will be demonstrated.
(21) 14A.l.26 Ventilation Systems - Expand the abstract to provide objectives, methods and acceptance criteria that are sufficient to assure (1) Redundancy and electrical independence will be demonstrated where appropriate.
(2) Response times for systems and isolation devices will be verified to be in accordance with design where appropriate.
(3) Air and water flows for the reactor building /r
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tion system will be in accordance with design for both normal operations and simulated accident conditions.
(4) Design heat removal capability will be verified.
(5) The control room pressurization system will be tested to verify design pressure control and capacity.
(6) The sensitivities of sensors for control room isolation will be verified to be in accordance with design.
(22) 14A.l.27 HEPA Filter and Charcoal Adsorber Test - Expand the abstract to identify the specific systems or filters to be tested.
(23) 14A.l.28 Containment Combustible Gas Control - Expand the abstracts to provide objectives, methods and acceptance criteria to assure that redundancy and electrical indepen-dence will be demonstrated.
(24) 14A.l.29 Gaseous Waste Management System - Expand the abstract to describe the testing planned for the isolation valves between the tanks and the nitrogen. makeup and compressor interlocks and hydrogen detection system.
Also provide acceptance criteria for the above.
(25) 14A.l.33 Emergency Diesel fuel Oil Storage Transfer System - Expand the abstract to provide objectives, methods and acceptance criteria to assure that proper load group assignment will be demonstrated for electrically powered equipment and instrumentatior..
(26) 14A.l.40 Non-Class IE AC Power Distribution Test - It is the staff's position that appropriate tests should be conducted to demonstrate the capability of offsite power sources (including internal distribution systems) to assume emergency loads. Modify the abstract to provide objectives, methods and acceptance criteria to assure that this capability will be demonstrated and that voltage levels on class IE buses remain within design values.
(27).14A.l.42 Emergency Diesel Generator System - Expand the abstract to provide objectives, methods and acceptance criteria to assure operation in accordance with design for diesel generator operations following a simulated
-9 start failure signal. Also confirm that design heat removal capability will be verified for system auxiliaries.
(28) 14A.l.43 Integrated Engineered Safety Features Actuation Test - Expand and/or clarify the abstract to (1) Confirm that both 'he Class IE AC and DC distribution systems not under test will be completely de-energized (step 3.1.e).
(2) Confirm that all emergency conditions will be simulated using only a single energized Class IE AC and DC train with all other plant AC and DC distribution systems de-energized, e.g., refueling accident, control room isolation, containment isolation, letdown cooler isolation, steam and feedwater line break, and auxiliary feedwater actuation.
(29) 14A.l.44 Class IE Preferred AC Power Supply - Expand the abstract to include the 120 VAC Class IE Instrumentati and Control (I&C) bus or provide another abstract to describe tests planned for this system. Also provide objectives and acceptance criteria to confirm that correct failure modes / response of supplied loads from loss of both the preferred and I&C buses will be verified by testing.
(30) 14A.l.45 Class IE DC Power System - Expand the abstract to provide objectives, methods and acceptance criteria to provide assurance that (1) A discharge test will be conducted for each battery and the results of the tests remain within design limits.
(2) Actual system loads are verified to be within design assumptions.
(3) Supplied loads will function in accordance with design at a battery terminal voltage equivalent to the acceptance criteria for the discharge load test.
(31) 14A.1.48 Vibration Monitoring - Expand the abstract to more specifically define the test objectives, test methods and acceptance criteria for the testing planned.
. (32) 14A.l.49 Plant Sampling Systems - Expand the abstract to describe the testing planned to assure that installed excess-flow check valves function in accordance with design.
(33) 14A.l.52 Engineered Safety Features Actuation System -
Expand the abstract to specifically 'dentify all ESFAS subsystems to be tested. Also provice objectives, methods and acceptance criteria to provide assurance that (1) Response times including final control devices (valves, etc.) are in accordance with design.
(2) Response to loss of power supplies is in accordance wii.h design.
(34) 14A.l.53 Reactor Protection System - Expand the abstract to identify any RPS channels that are not scheduled to be tested preoperationally and provide acceptance criteria t'at assures that the total channel response times including sensors and delays associated with the process to sensor coupling (sensing lines, etc.) will be in accordance with limiting assumptions used in your safety analysis report.
(35) 14A.l.60 Reactor Building Leak Rate Test - Expand the abstract to provide objectives and acceptance criteria for Type B and C tests.
It is our position that these tests be included in the preoperational test phase.
Also describe the sequence to be followed in Type A testing at peak and reduced pressures.
If reduced pressure testing will follow peak pressure testing, a suitable time period (m12 hours) should be provided at the reduced possure to assure that out-gassing from structu m and components yill not affect test results.
Ua.
Ia1.
.s 3 Turbine Bypass System - The abstract title use are inconsistent and need correction.
i J ECCS Dump to Sump Flow Test - Expand the abstract
,.< ovide assurance of redundancy and proper load 1
n:passignment for system instrumentation, controls, ard valves.
423.3 Our review of your proposed startup testing phase provided (14.2) in Table 14.2-2 disclosed that several tests described in Regulatory Guide 1.68 may not be scheduled to be perfocmed.
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Describe your plans and provide test summaries (or justifi-cation for nonperformance) of tests identified in items C.l.a. C.l.h, C.l.J. D.1.h and 0.1.i of Regulatory Guide 1.68.
Our basis for ~1cluding the generator trip test in Regulatory Guide 1.68 was :o assure that the turbine generator would not exceed its design speed and to establish that the plant's electrical system would perform as designed for this transient test during which the system may be subjected to frequencies in excess of 60 liz.
To acccmplish the test objectives, the generator should be disconnected from the transmission system in a manner that will result in the calculated maximum overspeed condition.
Normally, this is accomplished by opening of the generator output breaker in a manner that will require a turbine generator overspeed condition to initiate closure of the, steam admission or stop valves.
It is our understanding that typical designs of the trip logic for the generator output breakers will, for certain sensed plant conditions, result in a direct and simultaneous trip of the turbine stop valves. There usually are additional trips that will also open the generator output breakers without directly tripping the turbine stop valves. Therefore, the latter type of trio should be simulated to initiate the transient.
Modify Section 14.2 and the test descriptions as necessary to clarify that the generator trip test will be performed as intended by Regulatory Guide 1.68 and to either state that the turbine trip test will be performed at 100% power or provide technical justification for conducting the test at a different power level.
423.4 Our review of startup test abstracts disclosed that the (14.2) following require amplification or clarification:
(1) 14A.2.3, Reactor Coolant Flow and Flow Coastdown Test -
Provide or reference specific quantitative acceptance criteria for the flow coastdown tests. Also establish specific quantitative acceptance criteria for maximum and minic.um system flow rates with all pumps operating.
(2) 14A.2.4 Control Rod Drive Assembly Trip Test - It is our position that control rods be scram tested under clant conditions approximatino extremes of temperature and flow at which the technic 11 specifications will allov control rod withdrawal.
It is also our position that the performance of the control rods dash-pots be verified to be in accordance with design. !iodify the abstract to specifically define the temperature and flow conditions and provide acceptance criteria for dash-pot performance.
Also provide acceptance criteria for axial power shaping rods performance during scram testing.
(3) 14A.3.1 Initial Criticality - Provide specific acceptance criteria.
(4) 14A.3.2 Law Power Physics Test - Expand the abstract to, (1)
Identify the rod groups where reactivity worth will be determined.
If all banks are not planned to be measured, provide acceptance criteria for individual bank worths and total measured worth of rod groups that'if exceeded, will require additional rod worth measurement tests.
(2) Provide test objectives and acceptance criteria for differential and integral group rod worths.
(3) Provide acceptance criteria and their bases for parameters 3.2.a. c, d, e and f.
(4)
Provide acceptance criteria and a description of the test method for determining maximum stuck rod worth.
(5) 14A.4.2 Reactivity Coefficients at Power Test - Clarify the test purpose and provide (or reference) specific quantitative acceptance criteria. The acceptance criteria should provide assurance that the measured values, when corrected for measurement uncertainty, do not exceed values used in the safety analysis.
(6) 14A.4.4 Integrated Control System Tests - Expand and clarify the abstract to specifically identify the testing planned for cross-connected plant operation.
The abstract should clearly describe the initial testing and transients planned for Unit 2 and the testing, including transient tests planned for Units 1 and 2
. when operating in all of the various operating modes.
Limiting transient tests should be proposed with acceptance criteria for Units 1 and 2 (when supplying the Unit 1 TG or process steam loads) that provide assurance that the plants will operate in accordance with design. Also, power levels for transient tests should be clearly defined.
(7) 14A.4.6 Power Imbalance Detector Correlation Test -
Define the " prescribed conditions" in item 3 and clarify the proposed acceptance criteria.
(8) 14A.4.8 Loss of Offsite Power Test - It is our position that this test be conducted from an initial plant condition (for both units) of > 10% generator output and that a total AC power blackout condition be simulated on the non-class IE distribution systems for a period of approximately 30 minutes.
Expand and modify the test method and provide acceptance criteria for this position.
(9) 14A.4.10 Pseudo Dropped Rod Test - Modify the abstract to, (1) Describe the plant conditions when the test will be conducted.
(2) Describe the length of time the rod will remain fully inserted.
(10) 14A.4.ll Pseudo Ejected Rod Test - Modify the abstract to, (1) Define the plant conditions when the test will be performed.
(2) Clarify the test method (item 3.1).
(11) 14A.4.12 Shutdown From Outside the Control Room - The test abstract should be modified to be consistent with Regulatory Guide 1.68.2.
(12) 14A.4.14 Process Steam Startup Test - Modify the abstract to describe when the testing will be conducted (relative to fuel load dates for both units). Also describe the testing planned and provide acceptance criteria for testing the operability of valves (under simulated operating conditions) in steam supply lines to the high and low pressure evaporators and condensate return lines from the process steam system.
. 423.5 Identify any of the post-fuel loading tests described in (14.2)
Section 14.2 which 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 main-taining the reactor in a safe condition for an extended shutdown period; (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 reactor in a safe conditicn for an extended shutdown period following such conditions; (3) will be relied upon for establishing conformance with safety limits or limiting conditions for operation that will be included irt the facility technical specifications; (4) are classified as engineered safety features or will be relied upon to support or~ assure the operations of engineered safety features within design limits; (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); and (6) will be utilized to process, store, control, or limit the release of radioactive materials.
423.6 Table 14.2-4 lists power levels where power ascension tests (14.2) will be conducted. The table is inconsistent with regulatory positions in Regulatory Guide 1.68.
The table should be modified to agree with Regulatory Guide 1.68 positions or technical justification provided for exceptions.
423.7 For the staff to complete its review of the organization and (14.2) staffing of the test program, the following additional or clarifying information will be required:
(1) The minimum qualifications requirements (educational, experience, and nuclear experience) for the following categories of personnel at the time they are assigned to the task. Your response should address all personnel
. performing the tasks listed and should not be limited to only CPC personnel (e.g., Test Working Group members and 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 li'ted categories.
(1) Personnel that supervise or :irect the conduct of individual preoperational tests.
(2) Personnel that review and/or approve 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.