ML19270E735
| ML19270E735 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/16/1985 |
| From: | Chan E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Gassel D, Guild R CASSEL, D.W., GUILD, R. |
| References | |
| CON-#285-076, CON-#285-76 OL, NUDOCS 8505210322 | |
| Download: ML19270E735 (1) | |
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PSRB R/F Docket Hos. 50-424/425 DHFS R/F (2) gp 2 DLZiemann 8 70g4 GRMazetis RABecker HEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing Division of Licensing FROM:
William T. Russell, Deputy Director Division of Human Factors Safety
SUBJECT:
DRAFT SAFETY EVALUATION REPORT INPUT YOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 CHAPTER 14 - INITIAL TEST PROGPJd4 Georgia Power Company's description of its initial test program and response to TMI Action Plan I.G.1 for the Yogtle Electric Generating Plant test program have been reviewed through Amendment 9 to the FSAR. As indicated in the enclosed Draft SER input, there are items which require additional information from the applicant. We expect to have these items resolved in time for our June 1985 input to the SER, which will also include our SALP input. To date we have not had sufficient interface with the applicant to provide meaningful SALP input.
The review of the Vogtle Electric Generating Plant initial test program is being performtd with assistance from Battelle Pacific Northwest Laboratories personnel.
R. Becker, Senior Nuclear Systems Engineer (X29689), is the PSRB reviewer for the Vogtle Electric Generating Plant initial test program. Questions regarding this evaluation should be directed so him. The reviewer is not aware of any " Differing Professional Opinions" for the initial test program.
3,m 14 R Smwer At William. T. RusseTF, Deputy Director Division of Human Factors Safety
Enclosure:
DSER - Chapter I4 8410190444 840928 CF ADDCK 05000424 Initial Test Program CF cc w/ enclosure:
E. Adensam M. Miller
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V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DRAFT SAFETY EVALUATION REPORT 14'0 INITIAL TEST PROGRAM The initial test program encompasses the scope of events that begins with completion of system construction and ends with the completiert of power ascension testing.
The initial test program consists of the preoperational and the startup test programs. At the conclusion of these test programs a unit is ready for routine power operation.
The preoperational test program begins with system / component turnover from the construction organization to the operations organization, and ends with the beginning of fuel loading. These tests demonstrate, to the extent practicable, the capability of structures, systems, and components to meet performance requirements, and to satisfy design requirements. To the extent practicable, the objectives of the preoperational test program are:
(I) to document the performance and operability of equipment and systems, (2) to provide bu: 'ine test and operating data on equipment and systems, (3) to operate new equipment for a sufficient time to identify and correct design, manufacturing, and installation defects, (4) to ensure integrated systems operation, (5) to familiarize plant operating, technical, and maintenance personnel with facility operation, and (6) to confirm the adequacy of nonnal operating and emergency operating procedures.
The startup test program begins with fuel loading, is followed by zero power and low power testing, and ends with the completion of power ascension testing. These tests confirm the design bases, and demonstrate to the extent practicable that the plant operates and responds to transients as designed.
Startup testing is sequenced to ensure that the safety of the plant is not dependent upon the performance of untested structures, systems, or components. The objectives of the,cartup test program are:
(1) to accomplish a controlled, orderly, and safe initial core loading, (2) to accomplish a controlled, orderly, and safe initial criticality, (3) to conduct low power testing sufficient to ensure that design parameters are satisfied, and that safety analysis assumptions are correct or conservative, (4) to perform a controlled, orderly, and safe power ascension with requisite testing, terminating at pla7t rated conditions, and (5) to confirm codes and analytical models used in the reactor design.
The staff review of FSAR Chapter 14 concentrated on the administration of the test program and the completeness of the proposed preoperational and startup tests. The review consisted of the follcwing parts. The SER-CP was reexamined to determine the principal design criteria fcr the plant and to identify any specific concerns or unique design features that would warrant special test consfderation.
FSAR Chapters 1 through 12 were examined for familiarization with the facility design and nomenclature.
FSAR Chapter l' was examined to ident,ify assumptions pertaining to performance characteristics that should be verified by testing and to identify all structures, systems, components and design features that were assumed
. to function (either explicitly or implicitly) in the accident analyses.
Licensee Event Report Summaries for operating reactors of similar design were examined to identify potentially serious events and chronic or generic problems that might warrant special test consideration. The Standard Technical Specifications were examined to identify all structures, systems, and components that would be relied upon for establishing conformance with safety limits or limiting conditions for operation.
Post-TMI related testing requirements were examined in confc,rmance with:
NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident;" NUREG-0694, "TMI-Related Requirements for New Operating Licenses;" and NUREG-0737, " Clarification of TMI Action Plan Requirements." And finally, startup test reports for other similar type plants were examined to identify problem areas that should be a
emphasized in the initial test program.
In determining the acceptability of the applicant's test program, the crit ia of SRP Section 14.2 were used. The staff review process includes verl.ication of the following features of the initial test program:
(1) The applicant will develop test procedures using input from the nuclear steam supply system (NSSS) vendor, the architect-engineer, its engineering staff, and equipment suppliers and contractors. Operating experiences at similar plants will te factored into the development of the test procedures.
(2) The applicant will conduct tests using approved test procedures.
Administrative controls will cover (a) the completion of test prerequisites, (b) the completion of necessary data sheets and other documentation, and (c) the review 'nd approval of modifications to test procedures.
Administrative prc:eaures wil? also cover implementation of modifications or repair requirements identified as being required by the test; and any necessary retesting.
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4-(3) The applicant will review the results of each test for technicel adequacy and completeness by review groups including the NSSS vendor and architect-engineer as appropriate.
Preoperational test results will be reviewed prior to fuel loading and the startup test results from each test condition or power level will be reviewed prior to proceeding to the next test condition or power level.
(4) The applicant will use its normal operating procedures and emergency operating procedures to the extent practicable in performing the initial test program, thereby verifying the correctness of the procedures.
(5) The applicant's schedule for conducting the initial test program allows adequate time to conduct all preoperational and startup tests.
Preoperational test procedures will be available for NRC regional personnel review at least 60 days prior to scheduled implementation.
Startup test procedures will be available for review not less than 60 days prior to the scheduled fuel loading date.
(6) An abstract of each test is presented in FSAR Chapter 14.
The staff verified that there are test abstracts for those structures, systems, components, and design features that:
(a) will be used for shutdown and cooldown of the reactor under normal, transient, and accident conditions and for maintaining the reactor in a safe shutdown condition for an extended period of time; (b) will be used for establishing conformance with safety limits or limiting conditions for operation that will be included in the facility technical specifications; (c) are classified as engineered safety features or will be relied on to support or ensure the operations of engineered safety features within design limits; (d) are assumed to function or for which credit is taken in the accident analysis of the facility, as described in the FSAR; or (e) will be used to process, store, control, or limit the release of radioactive materials.
. (7) The test objectives, prerequisites, test methods, and acceptance criteria for each test abstract are in sufficient detail to establish that the functicnal adequacy of the structures, systems. components, and design features will be demonstrated.
(8)
Exceptions to RG 1.68, "Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors," Revision 2, are identified and adequately justified.
The staff was unable to verify all of the above; therefore, additional information was requested from the applicant (letter from E. G. Adensam, NRC, to D. O. Foster, Georgia Power Company, dated April 30,1984). The applicant responded to tnis request in FSAR Amendments 5 through 9.
Since some of the responses were incomplete, there are open items that the staff has identified in Table 14-1.
On the basis of its review, the staff has concluded that once the open items identified in Table 14-1 are resolved, the initial test program described in the FSAR will meet the acceptance criteria of SRP Section 14.2 and the regulatory requirements of:
(1) 10 CFR 50.34(b)(6)(iii) that requires inclusion of plans for preoperational testing and initial ope ations in the FSAR, (2) 10 CFR 50, Appendix B, Section XI, that requires a test program to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents, and
. (3) NUREG-0737, Item I.G.1, which requires additional testing and training during the initial test program.
This review and evaluation was performed with the assistance of Battelle Pacific Northwest Laboratories personnel.
Attachment:
Table 14-1
TABLE 14-1 OPEN ITEMS QUESTION NUMBER STATUS 640.03 The Service Air System Preoperational Test (FSAR Subsection 14.2.8.1.56), the Instrument Air System Preoperational Test (FSAR Subsection 14.2.8.1.57), or other test abstracts should be modified to demonstrate that the values identified ir. FSAR Table 9.3.1-2 (Safety-Related Pneumatically Operated Valves) fail to the safe position on loss of instrument air in accordance with position c.8 of Regulatory Guide 1.68.3, Preoperational Testing of Instrument and Control air Systems.
640.04 The ruponse to Item 640.04, Part B, should reference the Pressurizer Heater and Spray Capability and Continuous Spray Flow Verification Test (FSAR Subsection 14.2.8.2.2) since part of the tests referenced in the response are accomplished in this test abstract.
6a0.07 The Power Coefficient Determination Test (FSAR Subsection 14.2.8.2.26) should be modified to provide appropriate test prerequisites.
640.08 A.
Appropriate acceptance criteria should be provided for the following:
1.
Preoperational test abstract numbers (FSAR Subsection 14.2.8.1):
2, 7, 8, 11, 14-26, 28, 31, 32, 34, 41, 47-50, 53, 59, 63, 64, 71, 74, 76, 80, 84-86, 89-91, 93,95-100, and 102-110 (2, 47, and 80 are to be provided later).
2.
Startup test abstract numbers (FSAR Subsection 14.2.8.2):
2-5, 7, 9, 10, 14, 15, 24, 25, 27, 35, 36, 43-48, 52 and 53.
C.
Preoperat !cnal test mod"ications to FSAR Pai agraphs 14.2.8.1:
1, 2, 27, 33, 35-40, 42, 44-47, 51, 52, 54, 58, 78, 79, 82, 83, 87, 92, and 94 to be made later.
640.09 Response to be provided later.
640.11 Response to be provided later.
640.12 The Ventilation Capability Test (FSAR Subsection 14.2.8.2.58),or other test abstracts, should be modified in accordance with the response to this item.
640.14 Response to be provided later.
640.20 B.
The 125-V de preoperational test abstracts (FSAR Subsections 14.2.8.1.69 and 14.2.8.1.74) should be modified to demonstrate that testing of de loads necessary for safe shutdown is conducted at minimum dc system voltace or that the voltage drop at load to these components is measured to verify that tne dc loads are supplied with appropriate voltage under minimum battery voltage conditions.
640.22 Response to be provided later.
640.30 1.
Operability of main steam bypass valves will be described in a future amendment.
2.
The Reactor Coolant System (RCS) Preoperational Test (FSAR Subsection 14.2.8.1.7) should provide a test method and acceptance criteria regarding testing of pressurizer safety valves.
3.
Testing should verify that the capacity of pressurizer and steam generator power-operated relief valves are in accordance with the accident analysis assumptions for maximum valve capacity (FSARSubsections15.6.1and15.1.4).
640.32 FSAR Subsection 14.2.8 (Ind'vidual Test Descriptions) shou'c be expanded to address the following systems listed in Regulatory Guide 1.68, Revision 2, Appendix A:
1.
Main stop, control, intercept, and intercept stop valves will be addressed in a future amendment (1.e.6).
2.
Feedwater heater temperature, level, and bypass control systems will be addressed in a future amendment (1.j 17).
3.
Isolation features for ; team generator blowdown will be addr4. sed in a future amendment (1.1.4).
4.
Isolation features for several ventilation systems will be addressed in a future amendment (1.1.6).
5.
The Fuel Building Hoists and Elevator Preoperational Test (FSAR Subsection 14.2.8.1.60) and the Fuel Transfer System Preoperational Test (FSAR Subsection 14.2.8.1.61) should be modified to include verification of the performance of the dynamic (100%) and static (125%) load tests of cranes and hoists associated with fuel handling and storage in accordance with the response to this item (1.m.4).
. 6.
Turbine plant water sampling systems will be addressed in a future amendment (1.n.5).
7.
The Fuel Hsndling and Vessel Servicing Preoperatior.el Test (FSAR Subsection 14.2.8.1.59) should be modified to include verification of the perfonnance of the dynamic (100%) load tests of the polar crane.
8.
Containment ventilation operability with the reat tor coolant system at ratec' temperature will be addressed in a future amendment (4.j).
9.
Operability of the gross failed fuel detector should be demonstrated at 25% and 100% power (5.q).
- 10. Operability of the gaseous and liquid radwaste systems should be demonstrated during the power ascension test phase (5.c.c).
- 11. Ventilation and air conditioning systems will be addressed in a future amendment (5.f.f). The response to Part 5.f.f should reference the Ventilation Capability Test (FSAR Subsection 14.2.8.2.58) since this abstract addresses the concerns of this item.
- 12. FSAR Subsection 1.9.68.2 should be modified to provide justification for exception to the loss of or bypass of feedwater heaters test (5.k.k).
OTHER ITEMS 14.A The RCS Leak Rate Preoperational Test (FSAR Subsection 14.2.8.1.10) was modified to delete the test objectives relating to ter. ting of the coatainment cooler condensate measuring system. The test objectives are new part of the containment, Auxiliary, Control, and Fuel Handling Building Drains Sys'em Preocerational Test (FSAR Subsection 14.2.8.1.54).
The test objectives, test method, and acceptance criteria for the containment ccoler condensate system should be included as a whole in either test abstract, rather than arbitrarily separated.
14.B FSAR Tables 14.2.1-1 (Preoperational Test Procedures) and 14.2.1-2 (Starte.n Test Procedures) should be updated to include FSAR Subsection 14.2.8.1.107-110 snd 14.2.8.2.57-58, respectively.