ML20034F613
| ML20034F613 | |
| Person / Time | |
|---|---|
| Site: | 05200001 |
| Issue date: | 02/16/1993 |
| From: | Fox J GENERAL ELECTRIC CO. |
| To: | Poslusny C Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9303040051 | |
| Download: ML20034F613 (8) | |
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GE Nuclear Energy C-i
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,hV h?.[ D $5 s February 16,1993 Docket No. STN 52-001 l
l l
i Chet Posiusny, Senior Project Manager I
Standardization Project Directorate Associate Directorate. for Advanced Reactors and License Renewal Office of the Nuclear Reactor Regulation
Subject:
Submittal Supporting Accelerated ABWR Review Schedule - SSAR Chapter l
14, Initial Test Program j
Dear Chet:
Enclosed is the GE follow-up action to the February 11,1993 phone call with the NRC Staff pertaining to SSAR Chpater 14, Initial Test Program.
l Sincerely, 4
t Jack Fox l
Advanced Reactor Programs cc: John Chambers (GE)
Norman Fletcher (DOE) i II. J. Yang (GE) 2 l
l 11 % 30 2.Z Z. 2 -
9303040051 930216 r
DR ADDCK 05200001
///
.a T
GE Follow-up Action to 2/11/93 Phone Call with NRC Staff re: SSAR Chapter 14 - Initial Test Program Item 1 - Applicability of Reg Guide 1.140 Staff Comment - The staff noted that in Section 14.2.7, "Conformance of Test Program with Regulatory Guides, Reg Guide 1.140, " Design, Testing and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorbtion Units of Light Water Cooled Nuclear Power Plants", was included as being applicable while in Table 1.8-20, "RGs Applicable to ABWR", it was listed as being not applicable.
GE Responce_ - Table 1.8-20 is correct.
The ABWR does not include any
" normal" atmosphere cleanup systems.
The only atmosphere cleanup systems that exist System and a dedicated portion of thein the ABWR design are the Sta system.
Main Control Room ventilation
" Design, Testing and Maintenance Criteria for Post Accid Safety-Feature Atmosphere Engineered-Cleanup System Units of Light-Water-Cooled Nuclear Power Plants" Air Filtration and Adsorbtion No other ABWR ventilation systems perform an atmosphere cleanup function, and thus they have no equipment requirements of Reg Guide 1.140.(HEPA filters, charcoal beds, etc.) subject to the Therefore, the reference to RG 1.140 in Section 14.2.7 of the SS AR will be deleted in a future Amendment attached markup).
(see Item 2 - Radioactive Waste Systems NRC Comment - Section 14.2.12.2.38, "Radioactis e Waste Systems Performance" describes the power ascension testing for both gaseous and liquid radwaste systems while Table 14.2-1, " Power Ascension Test Ma trix",
includes only an entry entitled " Liquid RadWaste Systems Performance" GE Response - The entry in Table 14.2-1 was intended to include testing o both gaseous and liquid radwaste systems.
This intent will be clarified in a future SSAR amendment (see attached m ark up).
1 A
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Item 3 - COL ltems NRC Comment - In Section 14.2.13. " COL License Information - Initial Test Program", it is stated that the COL applicant is to provide the final list of tests proposed to be exempt from license conditions requiring NRC preapproval of changes to the testing specified.
Justification for each item on this list should also be provided.
This is what was intended, although not explicitly stated.
This will be clarified, via addition of an explicit requirement, in a future SSAR amendment (see attached markup).
Item 4 - Cross-Reference to Utility Organization NRC Comment - In Section 14.2.2.1, " Normal Plant Staff", a reference is made back to Chapter 13 for information regarding the plant owner / operator's organization.
However, in the ABWR SSAR, that particular information is listed as being out of scope.
GE Response - GE will revise the wording of 14.2.2.1 to clarify that such information is the responsibility of the COL applicant, and thus will be supplied at a later date (see attached markup).
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23A6100AN Standard Plant arv. n (7) Regulatory Guide 1.52--Design, Testing, To the extent practicable throughout the pre-and braintenance Criteria for Engineered operational and initial stattup test program,
-Safety-Feature Atmosphere Cleanup System test procedures will utilize operating, emer-g' ncy, and abnormal procedures where applicable Air Filtration and Adsorption Units of e
Light-Water Cooled Nuclear Power Plants.
In the performance of tests. The use of these procedures is intended to do me following:
(8) Regulatory Guide 1.56--Afaintenance of Water Purity in Boiling Water Reactors.
(1) prove the specific procedure or illustrate changes which may be required; (9) Regulatory Guide 1.95--Protection of Nuclear Power Plant Control Room Operators (2) provide training of plant personnel in the Against an Accidental Chlorine Release.
use of these procedures; and (10) Regulatory Guide 1.108--Periodic Testing of (3) increase the level of knowledge of plant Diesel Generators Used as Onsite Electric personnel on the systems being tested.
Power Systems at Nu: lear Power Plants.
A testing procedure utilizing an operating, (11) Regulatory Guide 1.139--Guidance for emergency, or abnormal procedure will reference Residual Hear Removal.
the procedure directly, extract a series of steps from the procedure, or both in a way that
- 12) Regblato uide
.140-- esign, Testin andi is optimum to accomplishing the above goals Af4intena e Crit ria for Normbi Venti ation while efficiently performing the specified ir Filt;ation /nd Ab rbtion testing.
q fhaust stem Units Light Water Cooled Nuclear Powe
- =
Plants.
14.2.10 Initial Fuel Loading and Initial Criticality 14.2.8 Utilization of Reactor Operating and Testing Experience in the Developrnent Fuel loading and initial criticality are of Test Prograrn conducted in a very controlled manner in accordance with specific written procedures as Since every reactor / plant in a GE BWR product part of the startup test phase (see Subsection line is an evolutionary development of the 14.2.12.2). Approval for commencement of fuel previous plant in the product line (and each loading is granted by the NRC after it has been product line is an evolutionary development from verified that all prerequisite testing has been the previous product line), it is evident that satisfactorily completed. However, there may be the ABWR plants have the benefits of experience unforeseen circumstances that arise that would acquired with the successful and safe startup of prevent the completion of all preoperational more than 30 previous BWR/1/2/3/4/5/6 plants. testing (including the review and approval of The operational experience and knowledge gained the test results) that would not necessarily from these plants and other reactor types has justify the delay of fuel loading. Under such been factored into the design and test speci-circustances, the applicant referencing the ABWR fications of GE supplied systems and equipment design may decide to request permission from the that will be demonstrated during the preopera-NRC to proceed with fuel loading. If portions tional and startup test programs. Additionally, of any preoperational tests are intended to be reactor operating and testing experience of conducted, or their results approved, after similar nuclear power plants obtained from NRC commencement of fuel loading, then the following Licensee Event Reports and through other industry shall be documented in such a request: (1) list sources will be utilized to the extent each test; (2) state which portions of each test practicable in developing and carrying out the will be delayed until after fuel loading; (3) initial test program.
provide technical justification for delaying these portions; and (4) state when each test 14.2.9 Trial Use of Plant Operating and will be completed and the results approved.
Ernergency Procedures 1G5 Amendment 21
4
,ABM 23A6100AN Staridard Plant
,3 Table 14.21 POWER ASCESION TEST MATRIX (Continued) i TESTrG PLATEAU POWER ATR4SONTEST Of HJ LP MP HP tap 3 l
V At 8490% CTP 100% Flow esnng HP Lome of Feedwater Heating V
Feedwater Pump Tno Recircutabon Pump Tno V
/
At near rand now One RtP Trp V
/
At neer rand now Two RIP Tnp V
V At near rand now Three RIP Trip
/
Af *10% h load Shumwn from %de the Control Roorn
/
At 10-20% raad power Loss of Ti,0.e Generator and Offsne Power Turt>ne Trip and Generator Load Re,weten V
Load Reecten within Bypass Capaeny V
Turtano Trip V
Fut Power Load Re.eenon V
Reactor Fuf isolaton V
V V
V Oftgas Sye-.T. Performance V
V V
V L; Ce.we,
,.7 Eouipment Performance V
V V
V Loose Parts Monitonng System Bassine Data V
V
&assed RadWaste Systems Portormance h (LQWd 64 Gaxm) c TM 2
=-
Tes6ng required kt pia.teau; ahernatrve test cordbons or exceptorts kfontt5ed in detailed lesang spec 5cabon V
=
Testng not spea5caty rogured in indcated p!steau. but to be cone 6n confunction wtth other lesng, or at e'
specife tesang cendrDons, generapy within recated p!ateau; see NOTES Wumn for explanadon OV. Open vessel HU = Nucseer Heshp LP = Low Power MP = Mid Power HP = High Power 14.2-66 3 Arnendant D
't
,6 kN 21A6100AN Standard Plant nrv. n 14.2.13 COL License Information - Initial Test Of the tests described in Subsection 14.2.12.2 Program for the ABWR Standard Plant the following tests, or designated portions thereof, are thus The preceding discussion of preoperational and candidates for proposed exemptions from operating startup tests were limited to those systems and license conditions requiring NRC prior approval components within, or directly related to, the for major test changes:
ABWR Standard Plant. Other testing, with respect to site specific aspects of the plant will be (1) 14.2.12.2.13 Recirculation Flow Control -
l necessary to satisfy certain ABWR requirements.
except for those features Testing of such systems and components shall be intended to limit maximum adequate to demonstrate conformance to such core flow; requirements as defined throughout the specific chapters of the SSAR. Below are systems that may (2) 14.2.17 ? ?1 Reactor Water Cleanup System require such testing:
Performance (1) electrical switchyard and equipment; (3) 14.2.12 2 21 Plant Cooling / Service Water System Performance - those (2) the site security plan; portions pertaining to the turbine building and service (3) personnel monitors and radiation survey water systems; instruments; and (4) 14.2.12.2.24 HVAC System Performance -
(4) the automatic dispatcher control system (if Those portions pertaining to applicable),
the normal HVAC system and its associated nonessential l
Also to be supplied by the COL applicant is the chilled water system; startup administration manual described in Section 14.2.4, which will describe, among other things, (5) 14.2.17 ? ?9 Feedwater Pump Trip; and what specific permissions are required for the approval of test results and the permission to (6) 14.2.1? ? '49 Steam and Power Conversion proceed to the next testing plateau.
System Performance.
l The COL applicant shall also provide a list of The COL applicant shall provide the final list those tests to be performed as part of the power of tests,roposed to be exempt from such license ascension test phase that are proposed to be condit' r.s, including adoption or augmentation of exempt from operating license conditions requiring the ove list, as appropriate.
NRC prior approval for major test changes. Reg Guide 1.68 specifies criteria (see Regulatory uO J.% grqi.b g (icM 5)
Position C.1) for determining what structures, systems, components and design features are required to be tested during the power ascension test phase in accordance with the requirements o
therein. Testing of such structures, systems, ITf>^
i components and design features is then subject to r
license conditions requiring NRC approval for major test changes. For completeness, the testing described in Subsection 14.2.12.2 includes testing of a limited number of ABWR structures, systems, components and design features that do not meet the referenced Reg Guide 1.68 criteria, and are thus exempt from such license conditions.
14M5
. unendment 23 J
\\
N 22A62 MAN
. Sta5da'rd Plant nrv A 14.2.1.3 Startup Test Objectives adequacy of the various component, system and plant procedures; and After the preoperational test phase has been completed, the startup phase begins with fuel (7) to conduct a successful warranty demonstra-i loading and extends to commercial operation.
tion.
This phase may be generally subdivided into the following four p.rts:
14.2.2 Organization and Sta agm -
eAde -4c sc9e. of Ac W (1) fuel loading and shutdown power ;evel tests; 14.2.2.1 Normal Plant Staff 5%i.rA M 4 4 bepdd W A. Cot.- uph+ps d;ossd (2) testing during nuclear heatup to rated Normal plant staff respo ibilities, authori-temperature and pressure (approximately 5% ties, and qualifications are*givee in Chapter power);
- 13. During the construction cycle and the var-h "4 ious testing phases additional staff is supplied (3) power testing from 5 to 100% of rated by the plant owner / operator, GE, znd others.
output; and 14.2.2.2 Startup Group (4) warranty demonstration.
The startup group is an ad hoc organization The tests conducted during the startup phase created for the purpose of ensuring that the consist of major and minor plant transients, initial test program is conducted in an effi-steady state tests, and process control system cient, safe, and timely manner. The startup tests all of which are directed towards demon-group is responsible for the planning, executing trating correct performance of the nuclear boiler and documenting of all startup and testing and the various plant systems while at power.
related activities that occur between the comple-tion of the construction phase and commencement The general objectives of the startup phase of commercial operation of the plant. At comple-are as follows:
tion of the startup program the startup group is dissolved and the normal plant staff assumes (1) to achieve an orderly and safe initial core comp 1:te responsibility of the plant. Ideally, loading; the startup group will include individuals assigned temporarily from the various depart-(2) to accomplish all testing and measurements ments and disciplines within the normal plant necessary to assure that the approach to and utility organization. This will assure max-initial criticality and subsequent power imum transfer and retention of experience and ascension is safe and orderly; knowledge gained during the startup program for i
the subsequent commercial operation of the (3) to conduct low-power physics tests plant. It is likely that the startup group will sufficient to ensure that test acceptance also include an augmented staff of individuals criteria have been met; from other concerned parties such as the NSSS vendor (GE), the architect engineer, and the (4) to conduct initial heatup and hot functional plant constructor. The normal plant staff will testing so that hot integrated operation of be included in as many aspects of the test pro-all systems is shown to meet test acceptance grams as is practicable considering their normal criteria; duties in the operation and maintenance of the plant.
(5) to conduct an orderly and safe power ascension program, with requisite physics 14.2.2.3 General Electric Company and systems testing, to ensure that integrated plant operation at power meets The General Electric Company (GE) is the test acceptance criteria; supplier of the boiling water reactor (BWR) nuclear steam supply system (NSSS) and is (6) to demonstrate, to the extent possible, the responsible for generic and specific BWR Ametximent 2 102-2 J