ML20039A662
| ML20039A662 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/30/1981 |
| From: | Youngblood B Office of Nuclear Reactor Regulation |
| To: | Delgeorge L COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8112210090 | |
| Download: ML20039A662 (25) | |
Text
-... _ _ _ _
t fi
/
DISTRIBUTION:
'. Docket File a bcc:
'LB#1 Rdg.
TERA NOV 3 0 ser BJYoungblood PDR MRushbrook LPDR KKioer NSIC Docket Nos.:
STN 50-454 Schesnut TIC and STN 50-455 DEisenhut ACRS (16)
SHanauer RVollmer M Mcol k(/,
Mr. Louis 0. DelGeorge TMurley Director of Nuclear Licensing
.RMattson
% b\\
Comonwealth Edison Company RHartfield, MPA g
g\\,
Post Office Cox 767 OELD Chicago, Illinois 60690
..,01E(3)
Mg
Dear Mr. DelGeorge:
Subject:
Additional Information Requested, Byron Initial Test Pro' ' -N'e As a result of our review of Chapter 14 of the Byron /Braidwood FSAR, we have identified a need for additional information and clarification. This request concerns the Byron initial test program and is included in Enclosure 1.
In addition to these new questions, item 423.12, parts 25 and 28, was previously sent to you and has not as yet been addressed.
You are requested to respond to these items by Decerber 11, 1981 or inform us, within seven days of receipt of this letter, of your schedule for response.
Sincerely, Or181nal signed by; Ylilliam Kane (p
1 B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing
Enclosure:
As stated cc w/ encl.: See next page 8112210090 811130 PDR ADOCK 05000454 A
ppg l
DLyl.B#1 y,,,,,,,DL LB81[7 D,L,,f',j,k omcs >
$URNAME)
...........9...
...................o-naa.a..---*.--
1 1
... /..t..y /. 81
- 11.../. /..7./. 81.......
oanp
.... ~.. - - - -
enc ronu m om uncu om OFFICIAL RECORD COPY usam mi -mm
S
.~
~
hir. Louis 0. DelGeorge Director of Nuclear Licensing Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 ccs:
Mr. William Kortier U. S. Nuclear Regulatory Commission Atomic Power Distribution Resident Inspectors Office Westinghouse Electric Corporation 4448 German Church Road P. O. Box 355 Byron, Illinois 61010 Pittsburgh, Pennsylvania 15230 Ms. Diane Chavez Paul M. Murphy, Esq.
602 Oak Street Isham, Lincoln & Beale Rockford, Illinois 61104 One First National Plaza 42nd Floor Chicago, Illinois 60603 Mrs. Phillip B. Johnson 1907 Stratford Lane
.Rockford, Illinois 61107 Ms. Bridget Little Rorem Appleseed. Coordinator 117 North Linden Street Essex, Illinois 60935 Dr. Bruce von Zellin Department of Biological Sciences Northern Illinois University DEKalb, Illinois 61107 Mr. Edward R. Crass Nuclear Safeguards and Licensing Division Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 Nuclear Regulatory Commission Region III Office of Inspection and Enforcement 799 Roosevelt Road Gl'en Ellyn, Illinois 60137 Myron Cherry, Esq.
Cherry, Flynn and Kanter 1 IBM Plaza, Suite' 4501 Chicago, Illinois 60611 i
ENCLOSURE
~
STAFF POSITIONS.AND REQUESTS FOR ADDITIONAL INFORMATION BYRON STATION UNIT 1 INITIAL TEST PROGRAM 423.22 The response to Item 423.1 is no.t totally acceptable.
Modify (I**)
Subsection 14.2.2 as follows:
1.
The QA Topical Report is referenced to Chapter 14.
The proper reference is Chapter 17.
I 2.
State the composition of the Onsite Review Group.
423.23 Modify Subsection 14.2.4 to address the following items:
(14.2.4) 1.
Inclusion of the entire initial test program (both pre-operational and startup tests).
2.
Incorporate the response to Item 423.6 into this subsection.
3.
Ensure that all data from unsuccessful tests will be recorded 1
to permit post-test analysis.
4.
State how test procedure modifica' tion (both major and' minor)
~
is act:molished.
Ncte :na the technical s:e ifica:icns will require that minor tem;crary : nan;es to prc:e:ures c:verin; test activities of safety-related equipment must be approved by two members of the plant management staff, at least one of which holds a Senior Reactor C: era: r's License cr. :ne af#e::ed unit.
Since most, li.. not all, startup tests ar ect sarety-related systems, this requiremen applies :: s:ar u: :est procedures.
(It dces not apply to preoperaticnal tests conducted before fuel loading.)
Therefore, indicate that minor changes.to startup test crocedures will be mace in accordance with technical specification requirements for safety-related systems.
t 223.2:
The response to Item a23.7 is n'o: acequate.
Revise
'i*2 3)
Subsection 12.2.5 to incluce the a ;iicaole inf:rmation fr:m tne referencec cocuments.
t 222.25 Tne information cen:aine: in Subse::icns 12.2.5 and 12.111 is
- !'f* !.
inc:nsis ent.
Revise :ne sa:se::i:ns as 'Oll ws:
,'..:.1sf l.
30a:e Ond* 3ll :reO: era **.:nal !ss:s Wi$$ De
- ':$e~.e.
. h nravac :rier : ::re ! :a:.
page ?[onOJ r
~
- 2. ' State that all startup test data obtained at each power test plateau will be evaluated and approved before increasing power level.
423.26 Appendix A does not clearly state the applicable revision number (14.2.7) for revised regulatory guidelines.
Modify Appendix A to list the applicable revision num'er for each regulatory guide.
b 423.27 The response to Item 423.3 is not acceptable.
Modify (14.2.11)
Subsection 14.2.11 to state that any initial test schedule overlap at the Byron and Braidwood Stations will not result in significant divisions of responsibilities or dilutions in -
the staff provided to implement the test programs.
423.28 The response to Item 423.9 is not totally acceptable. Modify (I4*2"II)
Subsection 14.2.11 to state that test' procedures will be available for review by IE inspectors at least 60 days prior to their intended use, and not less than 60 days prior to-the scheduled fuel loading date for startup test,s.
423.29 List any tests, or portions of tests, described in (14.2.12)
Subsection 14.2.12 which you do not intend to perform on, each unit and provide technical justification for deletion of each.
423.30 The response to Item 423.10 is not acceptable.
Expand existing test abstracts, or provide additional ~ abstracts, to demonstrate the operability'of the noted systems and components in accordance with Regulatory Guide 1.68 (Revision 2), Appendix A.
The following additions / corrections are to be, addressed'in addition to those listed'in Item 423.10.
1.n. (7) Fire protection' systems 4.t.
Performance of natural circulation tests of the reactor coolant system to determine that design hat removal capability exists.
NUREG-0694, "Tf11 Related Requirements 1
1
)
for New Operating Licenses", Item I.G.1, requires j
applicants to perform "a special low power testing program approved by NRC to be conducted at power levels no greater than 5 percent for the purposes of providing meaningful technical information beyond that obtained in the normal startup test program and to provide supplemental. training".
To comply with this requirement new PWR applicants have committed to a series of natural circulation tes'ts.
To date, such tests have been performed at the Sequoyah 1, North Anna 2, and Salem 2 facilities.
Based on the success of the programs at these plants, the staff has concluded that augmented natural circulation training should be performed for all future PWR operating licenses.
Include description of natural circulation tests t. hat fulfill the following objectives:
1 Testing The tests should demonstrate the following plant char-acteristics:
leng:n of time required to stabilize natural circulation, core flow distribution, ability to establish and maintain natural circ ~ulation with or I
without onsite and offsite power, the ability to uniformly borate and cool down to hot shutdown conditions using natural circulation, and subccoling monitor performance.
Training Each licensed reactor operator (R0 or SR0 who performs R0 or SR0 duties, respectively) should participate in the initiation, maintenance, and recovery from natural circulation mode.
Operators.should be able to recognize when natural circulation has stabilize.d, and should be able to control saturation margin, RCS pressure, and
heat removal rate without exceeding specified operating limits.
If these tests have been performed at a ccmparable prototype plant, they need be repeated only to the extent necessary to accomplish the above training objectives.
5.w.
Containment penetration cooling system.
On those pene-trations where coolers are not used, provide a startup test description that will demonstrate that concrete temperatures surrounding hot penetrations do not exceed design limits.
423.31 The prerequisites of your preoperational test abstracts are (14.2.12) usually either " prior to core load" or " prior to plant operation".
These are, by definition, the prerequisites for all preoperational tests, as stated in Subsection 14.2.11.
Revise the appropriate preoperational and startup test abstracts to provide prerequisites that identify the major component or system status necessary to conduct the test.
c l
t 8
0 M
pag @ m
~
423.32 Certain terminology used in the individual test descriptions (14.2.12) does not clearly indicate the source of the acceptance criteria to be used in determining test adequacy.
An acceptable format for providing acceptance criteria for test results includes any lof the following:
Referencing technical specifications (Chapter 16)-
- ~ Referencing accident analysis (Chapter 15)
Referencing other specific sections of the FSAR Referencing vendor technical manuals Providing specific quantitative bounds (only if the information carnot be provided in any of the above ways).
Modify the individual test description abstracts presented below
+o provide adequate acceptance criteria for all items' in the respective test summaries or, if applicable, add a paragraph to Subsection 14.2.12 that provides an acceptable description to each of the following unclear terms found in the identified tables.
(1)
Design,asdesigned,designvalues,designcriterfi, design specifications, design requirements, design limits, design conditions Table 14.2-2
-5
-6
-7
-8
-9
-11
-12
-13
-15
-16
-17
-18
-20
-21
-22
-23
-24
-26
-28
-29 4
-30 I
-33
-34
-35
-36 i
-37 (2 times)
-38
-39
-40
-41
-45
-46
-48 (2 times)
-49
-51
-53
-60
-61
-62
-64
-65
-67
-68
-71
-73
-74
-75
-84
.-87
-89 (2)
Plant installation Table 14.2-3
-5
-6
-7
-8
-9
-18
-20
-21
-22
-23
-24
-25
-26
-28
-29
-30
-33
-34
-35
-36
-37
-38
-39
-40
-41
-45
-49
-51
-53
-61
-64
-65
-67
-68
-71
-73
-74
-89 (3) Manufacturer's recommendations, vendor recommendations Table 14.2-3
-5
-8
-9
-20
-23
-24
-25
-35
-36
-37
-38
-39
-40
-41
-61
-64
-67
-74 (4)
Safety analysis report, FSAR (state specific section)
Table 14.2-6 (2 times)
-7
-18
-28
-29
-30
-33
-34
-45
-51
-53
-61
-63
-65
-68
-71
psap grvr7a e
-73
-75
-77
-78
-79
-80
-82
- -84
-87
-89 (5) Appropriate, applicable Table 14.2-2
-11
-12
-35
-36
-37
-38
-39
-41
-48
-60 (6)
Acceptable, adequate, sufficient, unacceptable Table 14.2-12
-15 (2 times)
-16
-19
-27
-54
-68
-85 (2 times)
(7)
Specified, required, expected, predetermined Table 14.2-13
-32
-59 (2 times)
-77
-78
-79
-81
-82
-83
-85
-88 (8)
Function, can function, are functional, systems analysis of functional requirements Table 14.2-14
-44
-52
nu v=r,r w rn os (9)
Various Table 14.2-17
-19 (10)
Verify, verified Table 14.2-22
-74 (11)
Safely, properly Table 14.2-23
-31 (12) Appropriate regulatory guidelines or requirements, other applicable regulations Table 14.2-25
-73 (13)
Maintain, maintained Table 14.2-47
-59 (14)
Approved procedures, applicable procedures '
Table 14.2-58
-62
-75 (15)
Capable Table 14.2-60 (16)
Operational, verified to operate Table 14.2-60
-63 (17)
Compa tible Table 14.2-77
-78
-79
-80
-82
-83 i
-m
~
v >
423.33
' We could not conclude from our review of the preoperational (14.2.12.1) test phase description, the test abstracts provided in Tables 14.2-2 through 14.2-61, and the responses to Item 423.12 that required testing is scheduled for several systems and components. 2Therefore, clarify or expand the description of the p'reoperational test phase to address the following:
1.
Table 14.2-6, Reactor Protection.
The response to Item 423.12, Sub-item 3, is not acceptable.
Modify the test description to include the following:
a.
Account for process-to-sensor hardware (e.g.,
instrument lines, hydraulic snubbers, sensing lines) delay times; b.
Provide assurance that the response time of each primary sensor is acceptable; c.
Account for output of the sensor-to-tripping, of the reactor trip breaker delay times; i
l d.
Provide assurance that the total reactor protection system response time (the sum of the above three time delays) is censervative with respect to the accident analysis assumptions.
Note:
Item b can be accomplished by measuring the response time of each sensor during j
the preoperational test, sta. ting that the response time of each sensor will be' measured by the manufacturer within two years prior to fuel loading, or describing the manufacturer's certification process in sufficient detail for us to conclude that the sensor response times are in accordance with design.
2.
Table 14.2-7, Engineered Safety Features.
The response to Item J23.12, Sub-item d, is not acceptable.
Modi fy the test description to include the follo',ying:
i I
i t
~
l
g.pgrincyrg3
)
a.
Title the test "Enginee, red Safety Features Actuation System";
b.
Modify the test summary to include testing to demonstrate redundancy, coincidence, and safe failure on loss of power; c.
Modify the response time testing to:
i.
Account for process-to-sensor hardware (e.g.,
instrument lines, hydraulic snubb'ers, sensing lines) delay times; ii. Provide assurance that the response -time of each primary sensor is acceptable; iii. Account for output of the sensor-to-engineered safety features actuation delay time; iv. Provide assurance that the total engineered safety features act'uation system response time (the sum of the above three time delays)'is conservative with respect to the accident analysis assumptions.
flote:
Item ii can be accomplished by measuring the response time of each sensor during the pre-operational test, stating that.the response time of each sensor will be measured by the manufacturer within two years prior to fuel loading, or describing the manufacturer's certification process in sufficient detail for us to conclude that the s.ensor response times are in accordance with design.
Table-14.2-13, D-C Power.' Modify the test abstract to 3.
provide the following:
a.
Ensure that each battery charger is capable of charging the battery within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest
. combined demands of the expected steady-state loads under all plant operating conditions) b.
The response to Itein 423.12, Sub-item 9, is not totally acceptable.
Either provide a test description that
.r.
demonstrates that d.c. J.oads will perform as necessary to assure plant safety at a battery terminal voltage equal to the acceptance criteria that has _ been established for minimum battery terminal voltage for the discharge load test or reference,a desciiption of the manu-facturer's testing at this voltage that ensures proper operation.
Commit to including this infor-'
mation as part of your plant records.
4.
Table 14.2-14, Vital Bus Independence Verification.
Modify this test abstract to conform to the requirements of Regulatory Guide 1.41 as follows:
a.
State whether the isolation of the plant electric power distribution system will include the switchyard and the unit and system auxiliary transformers; b.
State how the system isolation will be eff'ected; c.
Provide assurance that all sources of power-supply to vital buses are capable of carrying full acciden.t. loads.
If some portions of the power supplies cannot be full-load tested, provide justification.
5.
Table 14.2-16, Component Cooling System.
The re'sponse to Item 423.12, Sub-item 11, is not totally acceptable.
Provide acceptance criteria for bench testing of the surge tank relief valyes.
6.
Table 14.2-18, Containment Spray System.
Verify that paths for the air-flow test of containment spray nozzles overlap the water-flow test paths of the pumps to demonstrate that there is no blockage in the flow path.
7.
Table 14.2-19, Auxiliary Feedwater System.
Modify the test abstract to provide the following:
a.
The reference to " prime movers" is unacceptable.
Specif-ically identify the equipment in question;
o b.
dur review of licensee e.v.ent reports has disclosed several instances of auxiliary feedwater pump failure to start on demand.
It appears that many of these failures could have been avoided if more thorough testing had been conducted during the plant's initial ~
test programs.
In order to discover'any problems
~
affecting pump startup and to demonstrate the reliability of your auxiliary cooling system, state your plans to demonstrate at least five consecutive ~, successful, cold, quick pump starts during your initial test program.
8.
Table 14.2-20, Primary Sampling System.
Verify flow paths, holdup times, and procedures.
9.
Table 14.2-21, Leak Detection System.
The response to Item 423.12, Sub-item 15, is not acceptable.
Modify the test abstract to provide the following:
a.
Rewrite the Test Objective.
The first paragraph needs clari.fication; the remaining paragraphs do n6$ deal-with test objectives;-
b.
Define the usage of "RCS surge tank" and provide a test summary for RCS surge tank level and radiation monitors; c.
Provide a preoperational test of the Radwas.te Systems that describes testing of the containment floor drains, reactor cavity sump, and totalizing meters.
10.
Table 14.2-22, Fuel Pool Cooling and Cleanup System.
Modify the test abstract as follows:
~
a.
Expand the test summary to specify the other flow paths; b.
The response to Item 423.12, Sub-item 16, is not acceptable.
Provide test objectives, a tett summary, and acceptance criteria for the requested systems and operations.
11.
Table 14.2-23, Fuel Handling and Transfer. Systems.
Modi fy the test abstract as follows:
pWWoTT5 T
' {, ~
7,
p-7:
a.
Provide the system descciption in the Test Objective, not the Test Summary; b.
Describe load testing to be performed to meet the requirements of Regulatory Guide 1.68, Appendix A, Part 1.m.(4).
i 12.
Table 14.2-25, Diesel-Generator.
The response to Item 423.12, Sub-item 18, is not acceptable.
Modify this test abstract, or other test abstracts, to quantitatively conform to the. require-ments of Regulatory Guide 1.108, Rev. 1, Regulatory Position 2.
13.
Table 14.2-26, Diesel Fuel Oil Transfer System.
The response to Item 423.12, Sub-item 19, is not acceptable.
Modify the test summary and acceptance criteria to ensure that the capacity of each fuel oil transfer pump to deliver flow in excess of the maximum demand, as indicated in Subsection 9.5.4, is verified.
(See also response to Item 040.102.),
14.
Table 14.2-28, ECCS - Safety Injection Pumps; Table 14'.2-29, ECCS - Centrifugal Charging Pumps;- and Table 14.2-30, ECCS - RHR Pumps.
Modify these test abstracts as follows:
a.
For the Safety. Injection Pumps and the Centr'ifugal Charging Pumps the second paragraph in the Test Surary of each abstract must be rewritten due to an incons'stency.
The first statement excludes the situation addressed in the second statement.
b.
The response to Item 423.12, Sub-item 21, is not acceptable:
i.
The requested information was provided in Table 14.2-33, not in Tables 14.2-28, 29, and 30 as stated.
Either modify Tables 14.2-28, 29, and 30 to reflect the response, or revise the response appropriately.
.e
w N.
,u e
- m,
^
3
.4 s
ii.
For the Safety Injection Pumps and the RHR Pump
~
abstracts, change Reactor Water Storage Tanks to Refueling Water Storage Tanks.
15.
Tat')1e 14.2-31, ECCS - Accumulators.
The response to Item 423.12, Sub-item 22, is not acceptable. Modify the test summary and acceptance criteria to verify proper operation of the nitrogen fill, venting and relief valves, accumulator drains, and accumulator v
makeup.
16.
Table 14.2-37, Diesel-Generator Room Ventilation System.
The response to Item 423.12, Sub-item 27, is not totally acceptable.
Modify the ' test description to show that testing of the filtration and absorption units will be performed in accordance with Regulatory Guide 1.52.
17.
Table 14.2-40, Hydrogen Recombiner.
Modify the test abstract as follows:
I a.
Demohstrate the capability of the system to oper. ate in response to post-LOCA requirements; b.
Demonstrate that post-LOCA hydrogen monitors function i
properly.
18.
Table 14.2-41, Containment Ventilation.
Modify the test abstract as fo11cws:
a.
Replace " specialized" with the appropriate terminology; b.
Verify that containment recirculation fan motor current is within its design Value at conditions representative of accident conditions.
Address such issues as air s
density, temperature, humidity, fan speed, and blade angle.
l'9.
Table 14.2-42, Main Steam Isolation Valves.
Modify the test abstract as follows:
i t
i n
.n-
- - ~ ~ ~
page 1 C oT ZG
~
r :
a.
State that you will meesure the full travel of the valves or provide technical justification for other j
methods of measurement.
If the measurement is to be based on 90% travel, calculate MSIV closure time as equal to the interygl from deenergizing solenoids until the valve reaches 90% closed, plus the period from 10% closed to 90% closed times 1/8, or provide technical justification for any method which " double-l counts" delay time.
b.
Expand the acceptance criteria to include all of the items in the test summary.
~
20.
Table 14.2-50, Primary Safety and Relief Valves. The response to Item 423.12, Sub-item 35, is not acceptable.
Modify the test abstract as follows:
a.
Describe how proper actuation and operation of the power-operated relief valves is demonstrated.
Note that in Subsection 5.2.2.11 credit is taken'for PORV operation to provide protection against exceeding 1
j 10 CFR 50 limits.
b.
Safety valve setpoint verification from vendor certifi-I cation data is' not acceptable.
Expand the test to I
include in-plant preoperational testing of the pres-surizer safety valves (and modify your test summary as appropriate).
Include testing to ensure seat leakage is within acceptable limits.
21.
Table 14.2-51, Steam Gene ~rator Safety and Relief Valves.
Revise *'e test abstract to provide acceptance criteria for al. components and systems identified in the test summary.
22.
Table 14.2-61, Reactor Containment Crane and Hoists.
l Modify the test abstract to describe load testing to be performed to meet the requirements of Regulatory Guide 1.68, Appendix A, Part 1.o.(1).
-.n y
+ ~,- -.. _. _ -,.,.,.
~
4 423.34 The response to Item 423.13 is not acceptable.
Section 9.3 I 'I) states that some vcives in the compressed air system,'namely certain containment isolation valves, power-operated main steam relief valves and auxiliary feedwater flow control valves, fail in the safe position on loss of air.
The operability of safety-related equipment and processes would be compromised if these valves failed in the unsafe j
position.
Demonstrate proper operation of these valves in accordance with the testing requirements of Regulatory Guide 1.80.
423.35 The response to Item 423.14 is inadequate. Modify the (14.2.12) initial test program to provide a description of the inspections or tests that will be performed following system operation to assure that all snubbers are operable.
423.36 The response to Item 423.15 is inadequate.
Provide or (14.2.12) modify test descriptions to assure that tests wil,L be performed'to demonstrate that the emergency ventilatio.n systems are capable of maintaining all ESF equipment-within its design temperature range with the equipment operating in a manner that will produce the maximum heat load in the compartment.
If it is not possible to operate equipment te produce maximum heat loads, describe how the tests performed satisfy the objectives listed above.
l flote that it is not apparent that post-accident design I
heat loads will be produced in ESF equipment rooms during the power ascension test phase; therefore, simply assuring that area temperatures remain within design limits during this period will not demonstrate the design heat removal capability of these systems.
It will be necessary to include measurement of air and cooling water temperatures and flows and the extrapolations. used to verify that the ventilation systems can remove the postula,ted post-accident heat loads.
1
---oe--
page 18 of 23 I
t..
423.37 Our review of licensee event.. reports has disclosed that many (14.2.12)
. events have occurred because of dirt, condensed moisture, or other foreign objects inside instruments and electrical components (e.g., relays, switches, breakers).
Describe any tests or inspections that will'be performed or any administrative controls that will be implemented during the initial test program to prevent similar component i
failures.
423.38 The initial test p'rogram should verify the capability of the (14.2.12) offsite power system to serve as a source of power to the emergency buses.
Tests should demonstrat'e the capabilit'y of each starting transformer to supply power (as the alternate supply) to its unit's emergency buses while carrying its maximum load of plant auxiliaries and the other unit's emergency buses (as preferred supply). Tests should also demonstrate the transfer capabilities-of the unit's emergency bus feeders upon loss of one source of offsite po,wer. These tests she'uld be performed as early in the test program as the availability of necessary components allows.
Provide des-criptions of the tests that will demonstrate these capabilities.
423.39 The test descriptio.ns are not sufficiently detail'ed to (14.2.12) ascertain if the voltage levels at the safety-related buses are optimized for the full lead and minimum load conditions that are expected throughout the anticipated range of voltage variations of the offsite power source by appropriate -
adjustment-of the voltage tap settings of the.inte,rvening transformers.
We require 'that the adequacy of the design in this regard be verified by actual measurement and by correlation of measured values with analysis results.
~
Provide a description of the method for making this verification.
423.40 Verify that sources of water used for long-term core cooling
-(14.2.12) are tested to demonstrate adequate NpSH and the absence of vortexing over range of basin level from maximum to the minimum calculated 30 days folloQing.LOCA.
,n,,
n
~
page WoV D 423.41 The response to Item 423.18.is not adequate.
The intent (14.2.12.2) of this requirement is to determine if any of the startup tests are nonessential, based on the described criteria.
List any nonessential tests.
423.42 We could not conclude from our review of the startup test (14.2.12.2) abstracts and the responses to Item 423.19 that comprehensive testing is scheduled for several systems and components.
Therefore, clarify or expand the startup test phase des-cription to address the following:
1.
Table 14.2-62, Initial Core Load.
Modify this test abstract, or expand Sub;ection 14.2.10.1, to address the following:
a.
Commit to a response check of nuclear instruments to a neutron source within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of fuel loading; b.
Specify the frequency of determination of baron concentration commensurate with the maximpm dilution rate; c.
Include the maintenance of continuous voice communi-cation between the control room and fuel loading personnel;
~
d.
Verify the operability of radiation monitors, nuclear instrumentation, manual initiation, and other devices to actuate building evacuation alarm and ventilation control; e.
Specify criteria for emergency boron injection and containment evacuation.
2.
Table 14'.2-65, Reactor Trip Circuit.
The response to Item 423.19, Sub-item 3, is not totally acceptable.
Modify Table 14.2-6, Reactor Protection, to include the information cortained in this response.
3.
Table 14.2-66, Rod Drop Measurements.
Modify the test abstract to address the following:
[9M@ N W D a.
Revise the Test Objective to reflect the flow and temperature conditions specified in the Test Summary; b.
The response to Item 423.19, Sub-item 4, is not totally acceptable.
Retesting the drop times of the fastest and slowest rods does not guarantee that all rods outside the two-sigma limit will be included.
Commit to retesting all rods outside this limit at least three additional times.
4.
Table 14.2-70, Reactor Coolant System Flow.
The response to Item 423.19, Sub-item 6, is not adequate. Modify the test abstract as follows:
a.
Ensure that pump performance, rotational speed, and indicated flow are consistent with performance curves; b.
State that the flow. measuring devices are prbperly calibrated; c.
Provide a description for vibration monitoring.
5.
Table 14.2-75, Initial Criticality.
The response to Item 423.19, Sub-item 8, is not adequate.
Modify this test abstract or Subsection 14.2.10.2 to address the following items from Regulatory Guide 1.68-(Revision 2),
Appendix A, Section 3:
a.
Ensure that a neutron count rate of at least 1/2 count per second is indi.cated on the startup channels before the startup begins, and the signal-to-noise ratio is greater than 2; l
b.
Ensure that predictions of boron concentration and control rod positions are provided, as well as criteria and actions to be. ':en if actual plant conditions l
deviate from predicted values;
.S 7
-.~-m...
page FltroV7DJ e
c.
Prescribe the reactivity addition sequence to assure that criticality will not be passed through on a period shorter than approximately 30 seconds.
6.
Table 14.2-76, Power Ascension.
Provide a table that lists each startup test and denotes each power level where testing will be accomplished.
7.
Table 14.2-81, Pseudo Rod Ejection.
Modify this test abstract to include your response to Item 423.19, Sub-item 10, as follows:
a.
State that the most reactive RCCA will be withdrawn for this test; b.
Verify that its worth is conservative with respect to the accident analysis.
8.
Table 14.2-82, Power Reactivity Coefficient Measurement.
The response to It'em 423.19, Sub-item 11, is not adequate.
Modif-y the test abstract to describe how reacfor power and associated reactivity changes will be measured.
9.
Table 14.2-85, Turbine Trip.
The response to Item 423.19, Sub-item 12, is not adequate.
Expand the acceptance criteria to ensure that the recorded parameters and observed transient results will be compared.with predicted results for the actual test case, and quantitative values should be provided 'for the required convergence of actual test results with predicted values.
10.
Table 14.2-86, Core Performance Evaluation.
The response to Item 423.19, Sub-item 13, is not adequate.
Modify the test. abstract to show that data will be obtained at locations outside the control room to verify that the plant has achieved hot standby status and that the plant can be maintained at stable hot standby conditions for at least 30 minutes.
Also, show that data will be
~
obtained at locations outside of the control room l
t
page 22 of 23
~
- r -
to demonstrate a potential. capability for co'd shutdown by partially cooling down the plant from the hot standby condition.
The test should demonstrate that:
i.
The reactor coolant temp'erature and pressure can be lowered sufficiently to permit the operation of the core decay heat removal system that is to be ultimately used to place the reactor in a refueling shutdown mode.
ii. Operation of this decay heat removal system can be initiated and controlled.
iii. A heat transfer path to the ultimate heat sink can be established.
iv. Reactor coolant temperature can be reduced approximately 50 F using this decay heat removal system at a rate that would not exceed technical specification limits.
a
.11.
Table'14.2-87, Loss of Offsite Power.
The risponse to Item 423.19, Sub-item 14, is inadequate.
Modify.the 1
acceptance criteria to state that the duration of the blackout is at least 30 minutes.
~
12.
Table 14.2-88, 10% Load Swing.
The response to Item 423.19, Sub-item 15, is not adequate.
Include the response to this item in the test astract.
Also, expand the acceptance criteria to address acceptable overshoot, undershoot, or oscillation.
13.
Table 14.2-89, 50" Loa'd Reduction.
The response'to Item 423.19, Sub-item 16, is not adequate.
Include the a
response to this item in the test abstract.
423.43 The response to Item 423.20 is not adequate.
Modify the (14.2.12;2) '
acceptance criteria in Table 14.2-90 to assure that the linearity of the aT measurements is within the specifi-cations' required for the appropriate control systems.
W
9895 25~W7D ERRATA Page Section/ Table Item 14.0-1 14.2.3
" Testing" should be " Test" 14.2.11 "14.2-10" should be "14.2-9" 14.0-iv 14.2-89
" Sequence".should be " Reduction" 14.2-2 14.2.2 architect-engineer (sp) 14.2-4 14.2.9 Trial (sp) 14.2-5 14.2.10.1 channels, when responding, are (missing commas) 14.2-9 14.2.11 Demonstrations are satisfactorily (missingword) 14.2-11 14.2.12.2 "14.2.2" should be "14.2.12.2" 14.2-19 14.2-7(TS)
" loading" should be " cooling" 14.2-20 14.2-8(AC) radiation and circuit (extra comma, missingword) 14.2-21 14.2-9(AC) radiction and circuit (extra period, missingword) 14.2-29 14.2-17(TS) pumping from the (missing word) (twice),
etc., (missing comma) 14.2-33 14.2-21(TO) reactor (sp - was "Rx")
14.2-34 14.2-22(AC) in (sp - was "is")
14.2-36 14.2-24(TS) interlocks.and ~ relief valves (sp, missing word) 14.2-39 14.2-27(TS) temperatures to verify (plural)' inter-ference (sp) 14.2-44 14.2-32(TM) control (sp - was " content")
capacity for the test (sp - was "of")
14.2-45 14.2-33 ECCS (sp) 14.2-33(TM)
Specify "s" signal.
14.2-46 14.2-34(TS) operate, as indicated (missing comma) 14.2-47 14.2-35(TS) and to check (missing word) 14.2-48 14.2-36(TS) and to check (missing word) 14.2-36(AC)
A1.52-2 (sp) 14.2-49 14.2-37(TS) and to check (missing word) with room (improper abbreviation) 14.2-50 14.2-38(TS) and to check (missing word) 14.2-51 14.2-39(TS) and to check (missing word) 14.2-52 14.2-40(TO)
Remove first Test Objective section.
14.2-54 14.2-42(TS)
"with" should be "at" 14.2-64 14.2-52(PC) core (improper capitalization) 14.2-69 14.2-57
" HYDRAULIC" should be " REACTOR" 14.2-94 14.2-82(TS)
During (sp) 14.2-99 14.2-87(75)
" unavailable" should be "available"
~
f)?..
4,5 UNITED STATES 5
f 4 f}
fiUCI.E f.R REGULATC'3.Y CCfD.;:SSICS g
0.. -
exmuaTco ::.c.:ces r %g,h/,3 7
Novemb 19, 1981 N..O " f Docket No. 50-454 MEMORANDUM FOR:
J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing FROM:
Dennis L. Ziemann, Chief Procedures and Test Review Brcnch
~
Division of Human Factors Safety
SUBJECT:
STAFF POSITIONS AND REQUESTS FOR ADDITIONAL INFORMATION BYRON STATION UNIT 1 FINAL SAFETY ANALYSIS REPORT - CHAPTER 14 INITIAL TEST PROGRAM The Procedures and Test Review Branch has reviewed the Byron Station initial test program described in Chapter 14 of the FSAR, including Amendment 32. Additional information is required to ensure a satisfactory test program.
Enclosed are questions for your transmittal to Commonwealth Edison Company.
The review was perforced with the assistance of personnel from Pacific Northwest Laboratories (PNL).
D. Fischer was the PTRB reviewer. Any questions should be directed to Mr. Fischer (X24578).
Our review does not include Sections 14.2.2 " Organization and Staffing" and 14.2.6 " Test Records", which are LQB and QAB responsibilities.
These sections should be covered in con. junction with the Chapter 13 and 17 reviews, respectively.
Also, responses to items 423.12, Parts 25 and 28 were not provided by the applicant.
]
, j,u. p ::j L u* m ~
Dennis L. Ziemanni Chief Procedures and Test Review Branch Division of Human Factors Safety
Enclosure:
~
Staff Positions and Requests for Additional Information cc w/ enclosure:
~
5 A. Kipcr J. Kramer D. Vassallo J. Zwolinski W. Haass D. Fischer W. Apley S. MacKay
-F. Liederbach W. Long