ML20003F039
| ML20003F039 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/31/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8104200028 | |
| Download: ML20003F039 (13) | |
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4 Distribution Docket File NRC PDP, Local PDR LB 2 File MAR 311981 D. Eisenhut R. Purple y
Docket Nos. 50-352 R. Tedesco and 50-353 A. Schwencer
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Mr. Vincent Boyer IE (3)
Senior Vice President 00lb 6
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Nuclear Operations bcc: NSIC
%p Philadelphia Electric Company TERA 2301 Market Street ACRS (16) 9 Philadelphia, Pennsylvania 19101
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Dear Mr. Boyer:
SUBJECT:
ADDITIONAL INFORMATION RELATED TO CHAPTER 14 - LIMERICK GENERATING STATION We believe that it is important for us to complete our review and evaluation of your Operating License (OL) application dealing with the initial test program as early as possible so that this review does not impact your licensing schedule.
Since our review is based on Chapter 14 of your Final Safety Analysis Report (FSAR), changes to your test program or test procedures resulting from our review could impact the licensing schedule if action is required at a date near your proposed fuel load date. This is particularly true if the changes require that you (1) increase your staffing for the initial test program, (2) modify and rerun preoperational test procedures which may have already been completed, or (3) modify startup test procedures.
Based upon recent reviews of the initial test programs for OL applications of other plants, we have concluded that our review tfme could be significantly reduced if app 1tcants addressed and accounted for staff information requests on previous applications. All of our recent reviews have contained questions and positions that are largely identical, or similar, to those which had to be resolved during previous reviews.
If previous applicants had addressed all of these staff questions and positions in their original FSAR submittal, we believe that the review could have been shortened by 2 - 6 months.
l As an applicant for an operating license, we believe you should consider the questions and staff positions on Chapter 14 sent to other applicants. Inc'or-porating the resolution of these items into your initial FSAR or an early amendment will help to reduce NRC review time and should ensure that the review of your initial test program will not impact your schedule for fuel load or startup.
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Mr. Vincent Boyer I have attached the enclosure to the request for additional information that was sent to Washington Public Power Supply System (WPPSS) on its WPPSS-2 plant. This can be used as a guide in comparing the infomation already incorporated in your FSAR and the need for additional information.
If it is determined that additional information is required, it is requested that you provide that infomation in an early amendment to your FSAR. This will materf ally expedite the review of your initial test program.
If you have any questions call D. Sells, the Project Manager at (301) 492-7792.
Sincerely, ortsenet WM br anhat I. Tahom Robert L. Tedesco Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: See page 3
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"[ gj' 0,i NUCLEAR REGULATORY COMMISSION UNITED STATES WASHINGTON, D. C. 20555 s, m,
MAR 311981 Docket Nos. 50-352 and 50-353 Mr. Vincent Boyer Senior Vice President Nuclear Operations Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Soyer:
SUBJECT:
ADDITIONAL INFORMATION hELATED TO CHAPTER 14 - LIMERICK GENERATIMG STATION We believe that it is important for us to complete our review and evaluation of your Operating License (OL) application dealing with the initial test program as early as possible so that this review does not impact your licensing schedule.
Since our review is based on Chapter 14 of your Final Safety Analysis Report (FSAR), changes to your test program or test procedures resulting from our review could impact the licensing schedule if action is required at a date near your proposed fuel load date. This is particularly true if the changes require that you (1) increase your staffing for the initial test program, (2) modify and rerun preoperational test procedures which may have already been ccmpleted, or (3) modify startup test procedures.
Based upon recent reviews of the initial test programs for OL applications of oGer plants, we have concluded that our review time could be significantly reduced if applicants addressed and accounted for staff information requests on previous applications. All of our recent reviews have contained questions and positions that are largely identical, or similar, to those which had to be resolved during previous reviews.
If previous applicants had addressed all of these staff questions and positions in their original FSAR sutrnittal, we believe that the review could have been shortened by 2 - 6 months.
As an applicant for an operating license, we believe you should consider the questions and staff positions on Chapter 14 sent to other applicants.
Incor-parating the resolution of these items into your initial FSAR or an early amendment will help to reduce NRC review time and should ensure that the review l
of your initial test program will not impact your schedule for fuel load or startup.
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2-Mr. Vincent Boyer I have' attached the enclosure to the request for additional information that was sent to Washington Public Power Supoly System (WPPSS) on its WPPSS-2 plant. This can be used as a guide in comparing the information already incorporated in your FSAR and the need for additional information.
If it is determined that additional information is required, it is recuested that you provide that information in an early amendment to your FSAR. This will materially expedite the review of your initial test crogram.
If you have any questions call D. Sells, the Project Manager at (301) 492-7792.
Sincerely,
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Robert L. Tedesco Assistant Director for Licensing Division of Licensing
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Mr. Edward G. Bauer, Jr.
Vice President & General Counsel Philadelphia Electric Ccepany 2301 Mar.ket Street Philadelphia, Pennsylvania 19101 cc: Troy B. Conner, Jr., Esq.
Mr Vincent Boyer Conner, Moore & Corber Senior Vice President 1747 Pennsylvania Avenue, N. W.
Nuclear Ocerations Washington, D. C.
20006 Philadelsnia Electric Company 2301 Market Street Deputy Attorney General Philadelpnia, Pennsylvania 19101 Room 512, Main Capitol Building Harrisburg, Pennsylvania 17120 Karl Abraham Public Affairs Cfficer Mr. Robert W. Adler Region I, OIE Assistant Attorney General U. S. Nuclear Regulatory Commission Bureau of Regulatory Counsel 631 Park Avenue 505 Executive House King of Prussia, PA 198C6 P. O. Box 2357 Harrisburg, Pennsylvania 17120 Honorable Lawrence Coughlin House of Representatives Congress of the United States Washington, D. C.
20515 Roger 3. Reynolds, Jr., Esq.
324 Swede Street Norristown, Pennsylvania 19401 Lawrence Sager, Esq.
Sager & Sager Associates 45 Hign Street Pottstown, Pennsylvania 19464 Joseph A. Smyth Assistant County Solicitor ~
County of Montgcmery Courthouse Norristown, Pennsylvania 19404 Eugene J. Bradley
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Philadelphia Electric Company Associate General Counsel 2301 Market Street Philadelphia, Pennsylvania 19101 Mr. Jacque curr Resident Reactor Inspector U. S. Nuclear Regulatory Commission P. O. Box 47 Sanatega, Pennsylvania 19464 l
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RECUEST F1R ADDITIONAL INFORMATION WASHINGTON NUCLEAR PROJECT NO. 2 423.11 Your replies to questions 423.2, 423.6, and 423.7 do not clearly identify the level of particioation of GE, Burns &
Roe, and WpPSS personnel, other than members of the Test Working Group and Plant Operating Committee, in the prepara-tien, conduct, and review of preoperational and startup tests and do not provide for qualification of all personnel involved in precaration, conduct or review of tests. Your response should clearly establish minimum qualification requirements for supervisory and review positions. Our position in this respect is that, in general, the minimum qualification requirements listed below are appropriate for typical organi:ations.
3 The minimum qualifications of individuals that direct or supervise the conduct of individual precperational tests are (at the time that the individual is assigned to the task):
1.
A bachelor's degree in engineering or the physical sciences or the equivalent and one year of applicable pcwer plant experience.
Included in the one year of experience should be at least three months of indoc-trination/ training in nuclear power plant systems and component operation of a nuclear power plant that is substantially similar in design to the type at which the individual will perform the function er, 2.
A high school diploma or the equivalent and four years of pcwer plant experience. Credit for up to two years of this four year experience may be given for related technical training on a one-for-one time basis.
Included in the four years of experience should be at least three months of indoctrination / training in nuclear power plant systems and component operation of a nuclear power plant i
that is substantially similar in design to the type at which the individual will be emoloyed.
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Minimum qualifications of individuals that direct or supervise i
the conduct of individual startup tests are (at the time of assignment to the task):
I 1.
A bachelor's degree in engineering or the physical sciences or the equivalent and two years of applicable power plant experience of which at least one year shall be applicable nuclear power plant experience or, 2.
A high school diploma or the equivalent and five years of applicable power' plant experience of which at least two
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years shall be applicable nuclear power plant experience.
Credit for up to two years of non-nuclear experience may
, be given for related technical training on a one-for-one time basis.
2 Minimum qualifications of individuals assigned to grcups responsible for review and approval of preoperational and startup test procedures and/or review and approval of test results are (at the time the activity is being perfonned.)
1.
Eight years of applicable power plant experience with a minimtsn of two years of applicable nuclear power plant experience. A maximum of four years of the non-nuclear experience may be fulfilled by satisfactory completion of academic training at the college level.
423.12 Several sections including 14.2.4.4,14.2.5.2, and 14.2.6.1 reference the WPPSS Test and Startup Program Manual. To.
allow review of tne material, the appropriate information should
.t be incorporated into the FSAR.
423.13 Describe the approximate numbers by job position and approximate schedule, relative to fuel loading, for providing test personnel.
423.14 In reply to our question 423.4, you modified Section 14.2.4.1.5 to address significant modifications or repairs to safety-related sys tems.
Define significant modifications and repairs and designate the group or individuals authorized to detemine the significance of a modification or repair and to detemine retest requirements. Also, specify how modifications and repairs that are not considered significant are to be controlled.
423.15 Revise Section 14.2.11 to ensure that test procedures will be available not less than 60 days prior to fuel leading.
423.16 Section 14.2'.7 addresses confonnance of test programs with Regulatory Guides. This section should also address confomance with Regulatory Guides 1. 52, 1. 56. 1. 68.1. 1. 68.2, 1.30, and I
l.108. Also, modify the appropriete test descriptions to reflect the infonnation in the Regulatory Guides.
I 423.17 Section 14.2.10.1.4, Master Startup Checklist, refers to preoperational testing listed in Table 14.2-4.
Table 14.2-4 is a list of startup tests. Correct the reference.
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423.18 Several preoperational tes: prerequisites include the requirement that supc:;rt systems must have readiness verification, Provide a description of readiness verification and specify which individuals or groups are authorized to n:ake this determination.
423.19 Our review of your preoperational test phase disclosed that several systens and design features may not be scheduled to be preoperationally tested. The staff's evaluation of your preoperational test program was based on a comparison of your proposed test program with the structures, systems, components, and design features included in your facility design that:
1.
Will be rebibon for safe shutdown and cooldcwn of the reactor under normal plant conditions; 2.
Will be relied upon for safe shutdown and cooldown of the reactor under faulted, upset, or emergency conditions; 3.
Will be relied upon for establishing confomance with safety limits or limiting conditions for operation that will be included in the facility's technical specifications; 4.
Are classified as engineered safety features or l
will be relied upon to support or assure the operation 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; and l
6.
Will be utilized to process, store, control, or limit the release of radioactivity.
The description of your preoperational test phase shculd be expanded or modified to address your plans relative to preoperational testing of the following:
1.
Logic, controls, valves, and components used in the condensate and feedwater heating systems.
2.
Auto Depressurization Valves, including demonstrations of operability using all alternate pneumatic supplies and demonstration of operability of pneumatic air supply systems (reference Regulatory Guide 1.80).
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ATWS logic, controls, and final control elements.
4.
Leak tightness of Control Room.
5.
Diesel Generator Air Starting System.
6.
" Keep-full" systems for HPCS, LPCS, and RHR pumps.
7.
Automatic transfer of suction from the CST to the suppression pool for the HPCS System.
8.
Temperature control of the Condensate,Surage 'T'a'nk.
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Manual isolation capability between the main condenser and the off-gas system.
- 10. Manual operations (1ocal-manual) of all valves or dampers (that are provided with manual operators) for systems classified as engineered safety features. Your response should indicate whether this will be done as a part of each individual preoperational test, as a test pre-requisite, or as a construction acceptance test.
- 11. Timing tests for Recirculation System flow control valves.
- 12. Leak tightness tests for ECCS Systems.
- 14. Response time testing of Engineered Safety Features including initiating logic.
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redundancy.
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Heating, Air Conditioning and Ventilating Systems in the following areas: Main Control Room / Cable Spreading Rcom/ Critical Switchgear Area, Emergency Diesel Generator Building, Diesel-Generator Cable Area Corridor Radwaste Building, Reactor Building Emergency Cooling and Critical Electrical Equipment Area Cooling System.
- 18. MSIV Leakage Control System.
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- 19. Oriented Spray Cooling System.
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423.,20 We could not conclude frem our review of the preoperational test phase and the test abstracts provided in Table 14.2 that compre-hensive testing is scheouled for several of the described tests.
Therefore, clarify or expand the description of the preoperational test phase to address the following:
1.
Modify the individual AC and DC distribution system test descriptions or provide an integrated test description to verify pro er load group assignments.
(Reference Regulatory Guid 1.41 2.
State your plans to verify that DC loads are in accordance with battery sizing assumptions and to verify the supplied loads remain operable at the minimum battery tenninal voltage equivalent to the initial and periodic load discharge tests.
Modify the 250 VDC,125 VDC, and 24 VDC system test descrip-tions to include this testing and provide acceptance criteria for the tests.
3.
State how operability of emergency loads using offsite power will be demonstrated during AC and DC system tests.
4.
Modify the Primary Containment Leak Rate test description to address the progression of test pressures and the method of closure of the containment isolation valves. Also, clarify whether local type B&C leak tests will be conducted as a part of construction testing or preoperational testing.
5.
Identify testing that will be accomplished to verify drywell floor bypass leakage and provide quantitative acceptance criteria.
6.
State your plans for testing the Primary Containment Isolation System, including response times of the containment isolation valves.
7.
State your plans for assuring
! that the effects of inter-facing hardware (e.g., snubbers, pulse dampers) located between measured variables and the input to the sensors for the Reactor Protection System do not compromise the channel response time requirements. Modify the Reactor Protection System test description and provide acceptance criteria that reflect the effect of these interactions.
8.
Modify the Reactor Recirculation System and Control test description to demonstrate correct operation of Recir-culation Flow Control Valve rate limiters on flow controllers and demonstrate that individual control valve stroke s
rates do nort exceed safety analysis assumptions. Provide quantitative acceptance criteria for the above.
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. 423.21 Our review of your proposed startup testing phase disclosed that scme tests may not fully conform to regulatory positions described in Regulatory Guide 1.68.
Describe your plans relative to positions C.2.f and 1. D.2.a (for your high pressure core spray system),
D.2.k (operation of a bypass valve), 0.2.o, D.2.s (trip of two i
recire pumps at 100".), and 0.2.v of Appendix A.
423.22 Clarify the information in Section 14.2 to specifically identify each startup test listed in Table 14.2 that is not considered
" essential" to demonstrate the operability of sthJctures, s and components that meet any of the criteria listed belcw. ystems, a.
Those that will be used for safe shutdown and cooldown of the reactor under normal plant conditions and for main-taining the reactor is a safe condition for an extended shutdown period; or b.
Those that will be used for safe shutdcwn and cocidown of the reactor under transient (infrequent or moderately frequent events) conditions and postulated accident conditions and for maintaining the reactor in a safe condition for an extended shutdown period following such conditions; or c.
Those that will be used for establishing confor-nance with safety limits or limiting conditions for operation that will be included in the facility technical specifications; or d.
Those that are classified as engineered safety features or will be used to support or ensure the operations of engineered safety features within desgin limits; or e.
Those that are assumed to function or for which credit is taken in the accident analysis for the facility, as described in the FSAR; or f.
Those that will be used to process, store, control, or limit the release of radioactive materials.
423.23 The statui or mode of operations of plant control systems (avtomatic or manual) should be specified for all transient tests. Acceptance criteria relating to the performance of control systems should also be provided.
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423:24 Our review of the test abstracts provided in you: FSAR disclosed that they are not sufficiently descriptive to ecnclude that comprehensive testing is planned or that satisfactory test acceptance criteria have been established. The individual test abstracts should be modified as indicated below:
1.
Provide technical justification for the Average Power Range Monitor Calibration Test Level 2 acceptance criterion of t 7% of rated power.
2.
Modify the test abstract for the Reactor Core Isolation Cooling System to pro <ide for five cold quick starts of the system. Specify system conditions for cold cuick sta rt. Also, the Level 1 acceptance criteria refer to operating restriction on Figure 14.2-3 if the criteria are not met. Figure 14.2-3 does not indicate this restriction.
Provide adequate restrictions on operation if Level I criteria are not met.
3.
Expand the description of controls to ensure TIP reproducibility in the Core Power Distribution test for both random noise and gecmetric components. Also, provide ass :tnce that the process computer properly calculates core power distribution for both symmetric and non-symmetric rod patterns. Provide technical justification for the Level jl acceptance criteria.
4.
The description of the test methods in the Selected Process Temperatures Test should be expanded. The acceptance criteria should be made consistent with the stated test purpose.
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5.
Modify or clarify the acceptance criteria for the System Expansion test to provide assurance that design stress levels j
or fatigue limits will not be exceeded.
6;j/in the ko~re Power-Void Mode Test} description specify the l
mode of control (auto or manual) of each of the principal i
control systems at each test condition. Provide technical justification or the bases for the Level 2 acceptance criterion to assure that if the acceptance criterion is just satisfied, that stable performance can be expected l
throughout core life.
7.gf n the ipr *< cure Regulator Startup Te specify the mode of f
control (auto or manua u vi e vi e other principal control systems at each test condition. Provide technical justification or the bases for the Level 2 acceptance criterion (paragraph 1) to assure that if the acceptance criterion is just ~ satisfied, that stable performance can be expected throughout core life.
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8.
Modify the Feedwater System Startup Test to specify the mode of control (auto or manual) of each of the other principal control systems at each test condition for the feedwater control setpoint changes. Provide technical justification or the bases for the Level 2 acceptance criterion (paragraph 1) to assure that if the acceptance criterion is just satisfied, that stable performance can be expected throughout core life. Also, the test description should be modified to include a feedwater heater trip and to specifically identify:
(1) the type of trip to be initiated; (2) the feedwater heater (s) involved; and, (3) a discussion of how the planned trip relates to the worst case limiting event for your design that could result frem a single equipment failure or operator error.
Acceptance criteria for this later transient should be modified to:
(1) identify the parameters or variables to be monitored; (2) provide assurance that the transient results will be compared with predicted results for the actual test case; and (3) provide quantitative acceptance criteria and their bases for the required degree of convergence of actual test results with predicted results for the monitored variables and parameters.
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9.
Modify the description of the Turbine Valve Surveillance Test to ensure that the rate of valve stroking and timing of the close-open sequence is consistent with the conditions which will be experienced during surveillance tests.
10.
In the MSIV Tests modify the acceptance criteria for full MSIV closure at 100% power to:
(1) identify the parameters and variables that will be monitored; (2) provide assurance that the transient results will be compared with predicted results for the actual test case; and (3) provide quantita-l tive acceptance criteria and their bases for the required I
degree of convergence of actual test results with predicted l
results forthe monitored variables and parameters. Also l
provide clear acceptance criteria for relief valves and l
RCIC performance during this transient. Also provide acceptance criteria for minimum values of individual valve closure times.
- 11. Modify the Turbine Trip and Generator Load Rejection Tests to (1) specify that both a turbine trip and a generator load rejection will be conducted from approximately full power; (2) correct the Level 1 acceptance criteria to be consistent l
with your design; (3) identify the variables or parameters l
to be monitored for each trip; (4) provide assurance that test results will,be compared with predicted.results t
t for the actual tests to be run (for each trip), (5) provide quantitative acceptance criteria and their bases for the required degree of convergence of actual test results with predicted results for the monitored variables and parameters l
for each trio; and (6) provide acceptance criteria for g:id stability, voltage and frequency following generator load rejection trips.
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- 12. diodify the Recirculation Flow Control Startup Test abstract to specify the made of control (auto or manual) of each of the other princi;,al control systems at each test condition where system stability checks will be conducted. Provide technical justification or bases to assure that if Level 2 acceptance criteria are just satisfied, that stable performance can be expected throughout core life.
13.
odify the Recirculation System Startup Test to define the types of trips, including two pump trips, to be conducted at each test condition and the manner by which the pumps will be tripped. Also modify the test description and provide acceptance criteria for flow coastdown and for APRM flow biased rod block and scram transient setpoints following the double recire pump trip. Also provide stability criteria for plant performance following the trips.
l 14.
Modify the Loss of Turbine-Generator and Offsite Power Test abstract to:
(1) describe the initial plant conditions for the test including the lineup of the plant's electrical system; (2) describe the type of trip to be conducted; (3) identify the variables, parameters and plant equipment to be monitored; (4) provide assurance that test results will be compared with predicted results for the actual test case; (5) provide quantitative acceptance criteria and their bases for the required degree of convergence of actual test results with predicted results for the monitored variables and parameters; and (6) provide functional acceptance criteria for plant equipment tnat should function during or following the test.
15.
The Reactor Water Cleanup System Test states that it will be run in three modes as described in the System Process i
Diagram. The System Process Diagrams (Figures 5.4-17 a, b, c and 5.4-18) do not define the three modes. Modify the test description and Level 2 acceptance. criteria to correspond i
to the information presented in Chapter 5.
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The Residual Heat Removal System Test acceptance criteria are based on flow rates and temperatures in the process l
diagrams. The RHR system process diagrams do not contain l
this information. Modify the acceptance criteria to include l
the necessary infonnation.
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. 423.25 Chapter 5', Section 5.2.2.4.1 (page 5.2-12) of the FSAR specifies that the preoperational and startup testing of the safety relief valves will include monitoring of the discharge line movement.
Modify the startup test description to reflect this ccmitment.
423.25 Chapter 5. Secticn 5.2.5.5.5 of tne FSAR specifies that alarm points for the leak Detection System will be detemined analytically or based on measurements of appropriate parameters made during startup or preoperational tests. Modify the test description to identify these parameters and the methods of detemining the alam points.
42327 Chapter 6, Section 6.3.2.2.3 (page 6.3-15) of the FSAR states that during preoperational testing of the Low Pressure Core Spray System, the discharge flow orifice will be sized to limit system flow to acceptable values as described in the LPCS process diagram.
Mcdify the test description to reflect this cormitment.
323.28 Provide a precperational test description for the various modes and systems of the Fire Protection System.
423.29 Provide a schedule relative to fuel loading that specifies the scheduled time for performing icw power and power ascension testing.
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