ML20035F006

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Forwards SSAR Markups Addressing Section 4.2 COL Action Items Re Testing & Summary of Test Programs & Objectives. COL Action Item 14.2.12.3-1 No Longer Required Since Corresponding Info Now Included as Design Requirement
ML20035F006
Person / Time
Site: 05200001
Issue date: 04/06/1993
From: Fox J
GENERAL ELECTRIC CO.
To: Poslusny C
Office of Nuclear Reactor Regulation
References
NUDOCS 9304200163
Download: ML20035F006 (8)


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GE NuclearEnergy l

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OMP'J OWbtC Cpmp39y 115 Cwiner Avenue, San. hse. CA 9505

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1 April 6,1993 Docket No. STN 52-001 '

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l Chet Posiusny, Senior Project Manager j

Staridardization Project Direvornie i

Associate Directorate for Advanced Reactors i

and Licetise Renewal

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Office of the Nuclear Reactor Regulation

Subject:

Submittal Supporting Accelerated ABWR Review Schedule - Section 4.2 COL Action Items l

Dear Chet:

l Enclosed are SSAR markups addressing DFSER COL Action Items: 14.23-1,14.23-2,14.23-3, 14.23-4,14.2.4-1,14.2.5-1,14.2.10.4-1,14.2.11-1,14.2.12.4-1 and 14.2.12.4-2.

We find that COL Action Item 14.2.123-1 is no longer required since the corresponding information is now included as a design requirement (See my letter dated February 12,1993).

Sincerely, d

1 Jack Fox Advanced Reactor Programs cx:: Norm o Fletcher (DOE)

Mike Song (GE)

H. J. Yang (GE) 200035 nv3-81 l

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ABWR 2=>ous Standard Plant p.rv s

~ 4.2.13 COLI.Acesse Inferination !:'i' T--!

Of the tests described in Subsection 14.2.12.2 1

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for the ABWR Standard Plant the following tests, or designated portions thereof, are thus gal,,,./ed.g c' perrpr :!!- r' r '

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candidates for proposed exemptions from operating Th: ;:::r't ;

!rrr; *--*- r e "-!!rd !c !Er:r :/ !:r: trd license conditions requiring NRC prior approval e r r p e r--t- "'5!, c d!:::!'; rr!sted !c, th: for major test changes:

.... _.__ _..__.. Other testing, with respect to site specific aspects of the plant will be (1) 14112113 Recirculation Flow Control -

l necessary to satisfy certain ABWR requirements.

except for those features stTesting of such systems and components :5r'! 5:"

intended to limit maximum Q adequate to demonstrate conformance to such core flow; requirements as defined throughout the specific m,c,q u chapters of the SSAR. Below are systems that may (2)1411?1 Reactor Water Cleanup System ergy w require such testing:

Performance (1) electrical switchyard and equipment; (3)1411???'t Plant Cooling / Service Water System Performance - those (2) the site security plan; portions pertaining to the turbine building and service co t.

i*. z.i 2.4 - 1 (3) personnel monitors and radiation survey water systems; instruments; and col (4) 14.2." ? 74 HVAC System Performance -

t*,2. i t.1 -l (4) the automatic dispatcher control system (if Those portions pertaining to applicable).

the normal HVAC system and Nf tha.,e awel fut ib.h its associated nonessential

^' r te be ir;;! rd by / Men l /4. 2.13. 2.

e COL applicent-is the fcueW f3 yri chilled water system; 2_ : _ :.... : _ _ _.....i a.,_.:u a : e,,.,:m wem

5., ri!:i -"' d:::5!bA, E=:r- -'E-- !E! ;. (5) 141111?Q Feedwater Pump Trip; and 2:: :: ri::3 'er the

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r;;-c"'e'*:' r:9: rr> !E perr% rr :: (6) 14 112.239 Steam and Power Conversion pr e e-' 'e th- ---' te:':- ;! rte rs System Performance.

The COL a phant shai!

$o ihe~ ails The COL applicant shall provide the finallist those tests to be performed as part of the power of tests proposed to be exempt from such license ascension test phase ~ that are proposed to be conditions, including adoption or augmentation of exempt from operating license conditions requiring the above list, as appropriate.

NRC prior approval for major test changes. Reg Guide 1.68 specifies criteria (see Regulatory Position C.1) for determining what structures, systems, components and design features are required to be tested during the power asce'tsion test phase in accordance with the requirements therein. Testing of such structures, systems, components and design features is then subject to 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.

1 14.245 Amendmeni 23 i

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i INSERT "A"

a (1) the scoping documents (i.e.,

preoperational and startup test specifications) containing testing objectives and acceptance criteria applicable to its scope of design responsibility.

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(See Subsection 14.2.3)

(2) the startup administrative manual (procedure) and any other i

documents which delineate plant operational conditions at which tests are to be conducted, testing methodologies to be utilized, specific data to be collected, and acceptable data

.;t ig g 3 2 et reduction techniques to be reviewed by the NRC at the time of combined operating license.

(See Subsection 14.2.3 and 14.2.4) i (3) any reconciliation methods needed to account for test conditions, methods or results if testing if performed at conditions other than representative design operating 7

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(See Subsection 14.2.3) i (4) the approved preoperational and startup test procedures approximately 60 days before their intended use.

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_1/ 16.22-4 =P (See Subsection 14.2.3)

(5) a startup administrative manual (procedure) and any other documents that delineate the conduct of the test program to be reviewed by the NRC at the time of combined operating license.

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(See Subsection 14.2.4)

(6) a startup administrative manual (procedure) and any other documents that delineate the review, evaluation, and approval

[s v25lo of test results for the NRC review.

(See Subsection 14.2.4) a r

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(7) a startup administrative manual (procedure) and any other documents that delineate the method of controlling pre-fuel-load-checks, initial fuel loading, precritical testing and l

OL * > lo h/ w initial criticality for the NRC review.

(See Subsection 14.2.10)

(8) a startup administrative manual (procedure) and any other i

documents that delineate the test program schedule for NRC review.'

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(See Subsection 14.2.11) c, q q -, ;

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MM 23A6100AN arv 4 Standartl PInnt 14.2 SPECIFIC INFORMATION TO include, but are not limited to, flushing and BE INCLUDED IN FINAL SAFETY cleaning, hydrostatic testing, initial calibra-ANALYSIS REPORTS tion of instrumentation, checks of electricai wiring and equipment, valve testing, and initial 14.2.1 Summary of Test Program and energization and operation of equipment and sys.

4 Objectives tems. Completion of this phase will assure that systems are ready for preoperational testing.

l The initial test program consists of a series Abstracts of these tests are not provided as of tests categorized as construction, preopera-part of this chapter.

tional, or initial startup tests. The construc-tion acceptance tests determine correct instal.

14.2.1.2 PreoperationalTest Objectives lation and functional operability of equiptnent.

Preoperational tests are those tests normally Preoperational tests are conducted prior to conducted prior to fuel loading to demonstrate fuel loading in o.rder to verify that plant the capability of plant systems to meet perfor-systems are capable of operating in a safe and mance requirements. Initial startup tests begin efficient manner compatible with the system with fuel loading and demonstrate the capability design bases. The general objectives of the of the intestated plani to meet performaoce preoperational test phase are as follows:

requirements.

(1) ensure that design specification and test The objectives of the initial test program are acceptance criteria are met; to:

(2) provide documentation of the performance and (1) ensure that the construction is complete and safety of equipment and systems; i

acceptab!c; (3) provide baseline test and operating data on (2) demonstrate the capability of structures, equipment and systems for future reference-l 4

components, and systems to meet performance (4) run.in new equipment for a sufficient period requirements; so that any design, manufacturing, or (3) effect fuelloadingin a safe manner; installation defects can be detected and corrected; (4) demonstrate, where practical, that the plant is capable of withstanding anticipated (5) ensure that plant systems operate together transients and postulated accidents; on an integrated basis to the extent possible; (5) evaluate and demonstrate, to the extent possible, plant operating procedures to (6) give maximum opportunity to the permanent provide assurance that the operating group plant operating staff to obtain practical is knowledgeable about the plant and experience in the operation and maintenance procedures and fully prepared to operate the of equipment and systems; facilityin a safe manner; and i

(7) help demonstrate safe and efficient system (6) bring -the plant to rated capacity and operating and surveillance testing procc-sustained power operation.

dures to the extent possible;and 14.2.1.1 Construction Test Objectives (8) demonstrate that systems and safety equipment are operational and that it is Construction tests are performed to possible to proceed to fuel loading and to demonstrate that components and systems are the startup phase.

correctly installed and operational. These tests L

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ABWR 23^6mv REV B Standard Plant iwill be made available to the NRC staff approximately 60 days prior to their intended use for preoperational tests and 60 days prior to scheduled fuel loading for power ascension tests.

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14.2.4 Conduct oftest Pmgtsm

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The initial test program is conducted by the startup group in accordance with the startup administrative manual. This manual contains the administrative procedures and requirements that govern the activities of the startup group and their interfaces with other organizations. The startup administrative manual receives the same level of review and approval as do other plant administrative procedures. It defines the spe-eific format and content of preoperational and startup test procedures as well as the review and approval process for both initial procedures and subsequent revisions or changes. The start-up manual also specifies the process for l

14.2-3.1 Amendment 23 1

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ABWR nA6 oaAN REV B Standard Plant review and approval of test results and for re-within the test phun See S a s,c/.,n g 2 13.2 r- --

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  • ion of failures to meet acceptance crite.

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ria and of other operational problems or design 14.2.6 Test Records deficiencies noted. It describes the various phases of the initial test program and establi-Initial test program results are compiled and shes the requirements for progressing from one maintained according to the startup manual, phase to the next as well as those for moving be-plant administrative procedures, and applicable yond selected hold points or milestones within a regulatory requirements. Test records that given phase. It also describes the controls in demonstrate the adequacy of safety related place that will assure the as-tested status of components, systems and structures shall be l cach system is known and that will track modi-retained for the life of the plant. Retention fications, including retest requirements, deemed periods for other test records will be based on necessary for systems undergoing or already consideration of their usefulness in having completed specified testing. Additional-documenting initial plant performance ly, the startup manual delineates the qualifica-characteristics.

tions and responsibilities of the different positions within the startup group. The startup 14.2.7 Conformance of Test Prograrn with administrative procedures are intended to supple-Regulatory Guides ment normal plant administrative procedures by add :=i:; those concerns that are unique to the The NRC Regulatory Guides listed below were startup program or that are best approached in a used in the development of the initial test different manner. To avoid confusion, the start-program and the applicable tests comply with up program will attempt to be consistent with these guides except as noted. The applicable.

normal plant procedure where practical. The revisions of the regulatory guides listed below plant staff will typically carry out their duties can be found in Table 1.8-20.

according to normal plant procedures. However,

'in areas of potential conflict with the goals of (1) Regulatory Guide 1.68--Initial Test the startup program, the startup manual or the Programs for Water-Cooled Nuclear Power individual test procedures will address the Plants.

required interface.

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(2) Regulatory Guide 1.68.1--Preoperational and

--y 14.2.5 Review,Evnluation,and Apptuval Initial Startup Testing of Feedwater and of Test Results Condensate Systems for Boiling Water Reactor Power Plants.

Individual test results are evaluated and reviewed by cognizant members of the startup (3) Regulatory Guide 1.68.2--Initial Startup group. Test exceptions or acceptance criteria Test Program to Demonstrate Remote Shutdown violations are communicated to the affccted and Capability for Water-Cooled Nuclear Power responsible organizations who will help resolve Plants.

the issues by suggesting corrective actions, design modifications, and retests. GE and others (4) Regulatory Guide 1.68.3--Preoperational outside the plant staff organization, as Testing of Instrument and Control Air appropriate, will have the opportunity to review Systems.

the results for conformance to predictions and expectations. Test results, including final (5) Regulatory Guide 1.20 -Comprehensive resolutions, are then reviewed and approved by Vibration Assessment Program for Reactor designated startup group supervisory personnel.

Internals During Preoperation and Initial Final approval is obtained from the SCG and the Startup Testing.

appropriate level of plant management as defined in the startup administrative manual. The SCG (6) Regulatory Guide 1.41--Preoperational and the desiganted level of pInnt manngement will Testing of Redundant Onsite Electric Power also have responsibility for final review and Systems to Verify Proper Load Group approval of overall test phase results and of Assignm ents.

that for selected milestones or hold points 14.2 4 Amendment 21

224sioo^s ABM Rev. s Standard Plant (7) Regulatory Guide 1.52--Design, Testing, To the extent practicable throughout the pre-and Maintenance Criteria for Engineered operational and initial stnrtup test program,

. Safety-Feature Atmosphere Cleanup System test procedures will utilize operating, emer.

Air Filtration and Adsorption Units of gency, and abnormal procedures where applicable Light Water-Cooled Nuclear Power Plants.

in the performance of tests. The use of these procedures is intended to do the following:

(8) Regulatory Guide 1.56--Maintenance 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 Nuclear Power Plants.

A testing procedure utilizing an operating, (11) R egulatory Guide 1.139--Guidance for emergency, or abnormal procedure will reference Residual Near Removal.

the procedure directly, extract a series of steps from the procedure, or both in a way that (12) Regulatory Guide 1.140--Design, Testing and is optimum to accomplishing the above goals Maintenance Criteria for Normal Ventilation while cificiently performing the specified Exhaust System Air Filtration and Absorbtion testing.

Units of Light Water Cooled Nuclear Power 14.2.10 Initial Fuel Imading and Initial Plants.

Criticality 14.2.8 Utilization of Reactor Operating and Testing Experience in the Developrnent Fuel loading and initial criticality are conducted in a very controlled manner in of Test Prograrn 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 prevsous 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) provide technical justification for delaying initial test program, these portions; and (4) state when each test 14.2.9 Trial Use of Plant Operating and will be completed and the results approved.

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14.2-5 Amendment 21

I MM 21A6100AN Stanatard Plant arv. s testing at lower power levels should generally be i

performed prior to that at higher power levels.

The detailed testing schedule will be generated by the applicant referencing the ABWR Standard Plant design and will be made available to the NRC prior to actual implementation. Tbc schedule will then be maintained at the job site so that it may be updated and continually optimized to i

reflect actual progress and subsequent revised i

projections.

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14.2.12.1 Preeperational Test Procedures The following general descriptions relate the objectives of each preoperational test. During the final construction phase, it may be necessary to modify the preoperational test methods as operating and preoperational test procedures are developed. Consequently, methods in the I

following descriptions are general, not specific.

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