ML20040H026

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Notification of 820225-26 Meetings W/Util in Midland,Mi to Review Details of Facilities Initial Test Program & Discuss Encl Potential Open Items in Chapter 14 of SER
ML20040H026
Person / Time
Site: Midland
Issue date: 02/10/1982
From: Hernan R
Office of Nuclear Reactor Regulation
To: Adensam E
Office of Nuclear Reactor Regulation
References
NUDOCS 8202170021
Download: ML20040H026 (25)


Text

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Docket Nos: 50 329 and 50 330 FEB 1 0 ;ggy MEIORANDUM FOR: Elinor G. Adensam, Chief Licensing Branch 140. 4 Division of Licensing FROM:

Ronald W. liernan, Project Manager Licensing Branch No. 4 Division of Licensing

SUBJECT:

fl0TICE OF MEETIfG - MIDLAND PLA!iT, UNITS 1 AND 2 DATE & TIME:

February 25-26, 1982 8:30 a.m. - 4:00 p.m.

LOCATIO!!:

Midland Plant Site Midland, Michigan PURPOSE:

To review the details of the Midland Plant Initial Test Program and discuss potential Open Items in Chapter 14 of the Midland SER.

PARTICIPANTS:

fjRC Conswiers,,Pos,-#cr,Cogany S. MacKay T. Sullivan, et. al.

R. liernan

{ag!((g,ligghttgs},(ag,((yQ W. Appley cnald W. Hernan, Project Manager Licensing Branch No. 4 Division of Liconsing

Enclosure:

Potential SER Open Itecs cc:

See next page Meetings between NRC technical staff and applicants for licenses are open for interested nenbers of the public, petitioners, intervenors, or other parties to attend as observers pursuant to "Open Meeting and Statement of HRC Staff Policy", 43 Federal Register 28058,6/28/78.

If it is necessary for the participants th'cBT1Ect'iiBMiBns of this meeting within the plant

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MIDLAND Mr. J. W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 cc:

Michael I. Miller, Esq.

Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq.

Division of Radiological Health Alan S. Farnell, Esq.

Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Suite 4200 Lansing, Michigan 48909 1 First National Plaza

Chicago, Illinois 60603 William J. Scanlon, Esq.

2034 Pauline Boulevard James E. Brunner, Esq.

Ann Arbor, Michigan 48103 Consumers Power Conpany 212 West Michigan Avenue U.S. Nuclear Regulatory Comission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Myron M. Cherry, Esq.

Midland, Michigan 48640 1 IBM Plaza Chicago, Illinois 60611 Ms. Barbara Stamiris 5795 N. River Ms. Mary Sinclair Freeland, Michigan 48623 5711 Summerset Drive Midland, Michigan 48640 Mr. Paul A. Perry, Secretary Consumers Power Company Stewart H. Freeman 212 W. Michigan Avenue Assistant Attorney General Jackscn, Michigan 49201 State of Michigan Environmental Protection D,ivision Mr. Walt Apley 720 Law Building c/o Mr. Max Clausen Lansing, Michigan 48913 Battelle Pacif.ic North West Labs (PNWL)

Battelle Blvd.

Mr. Wendell Marshall SIGMA IV Building Route 10 Richland, Washington 99352 Midland, Michigan 48640 Mr. I. Charak, Manager Mr. Roger W. Huston NRC Assistance Project Suite 220 Argonne National Laboratory 7910 Woodmont Avenue 9700 South Cass Avenue Bethesda, Maryland 20814 Argonne, Illinoi's 60439 Mr. R. B. Borsum Ja"es G. Keppler, Regional Administrator Nuclear Power Generation Division U.S. Nuclear Regulatory Comission, Babcock & Wilcox Region III 7910 Woodmont Avenue, Suite 220 799 Roosevelt Road Bethesda, Maryland 20814 Glen Ellyn, Illinois 60137 Mr. Steve Gadler 2120 Carter Avenue St. Paul, Minnesota 55108

POTENTIAL SER CHAPTER 14) oPEN ITEMS MIDLAND UNITS 1 & 2 POTENTIAL FSAR oPEN ITEM CHAPTER FWMBER NUMBER Modify the Main Turbine System Test (14A.l.2) to include 1.

i (14A1.2) testing that will ensure correct operation of the overspeed trip.

2.

Modify Subsection 14A.l.64.3.9 to ensure that results of the (14A.l.64) temperature survey are extrapolated to the maximum expected ambient conditions under which the equipment is required to operate.

Use that extrapolation to determine if the reactor building cooling system is adequate.

3.

Modify the Reactor Coolant Flow and Flow Coastdown Test (14A.2.3)

(14A.2.3) to ensure that the. flow and coastdown data is compared to zero power design flow conditions.

Extrapolate the flow and coast-down data to 100% power design flow conditions to ensure that both minimum and maximum flowrate values are met.

4.

The Turbine Trip Test (14A,.4.19) and the Generator Trip Test (14A.4)

(14A.4.20) may be combined into one test if the conditions of Regulatory Guide 1.68, Revision 1, Appendix A, Sections 5.1.1 and 5.n.n are met.

Whether the tests are combined or not,

~

modify the two test descriptions to reflect the Revision 1 requirements.

Modify test descriptions 14A.l.12,14A.1.14, and 14A.1.15 to 5.

(14A.1) explain how the determined ficw conditions will be compareo to l

the design flow conditions in FSAR Chapter 6.

This explanation

(

is necessary since the stated design operating 3ressures and f

temperatures given in FSAR Chapter 6 are different tnan the preoperational test conditions.

I

6.

Recently, questions hava arisen concerning the operability (14A.12,14) and dependability of certain ESF pumps.

Upon investigation, the. staff found that some completed preoperational test procedures did not describe the test conditions in sufficient detail.

provide assurance that the preoperational test procedures for ECCS and containment cooling pumps will

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require recording the status of the pumped fluid (e.g.,

pressure, temperature, chemistry, amount of debris) and the duration of testing for each pump.

In addition, provide preoperational test descriptions to verify that each engineered safety feature pump operates in accordance with the manufacturer's head-flow curve.

Include in the description the bases for the acceptance criteria.

(The bases provided should consider both flow requirements for ESF functions and pump NpSH requirements.)

7.

Modify Table 14A.l.5, page 14A.l.6 to include the commitment (14A.l.5) to demonstrate at least five consecutive successful cold, quick auxiliary feedwater pump starts.

3, Modify Table 14.1.45, page 14A.1.48 to include the commitment (14A.1.45) to demonstrate that each battery charger is capable of floating the battery on the bus or recharging the completely discharged 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 various steady-state loads under all plant

. operating cond.itions.

I Table 14.1.53 is inadequate as written.

Some method of 9.

(14.1.53) accounting for process-to-sensor coupling must be included in the test description.

This should consist of determining a theoretical worst case condition and demonstrating adequate response time even with worst case conditions.

l i.

Provide a comitment to include in your test program any 10.

(14. 2. 3) design features to prevent or mitigate anticipated transients without scram (ATWS) that may now, or in the future, be incorporated into your plant design.

The Midland plant is a multi-unit facility; therefore, 11.

(14A.1.40, 41, describe the power supplies to the "other" units to ensure 44,45) independence during power distribution testing.

The des-criptions should address both nonnal and emergency A.C. and D.C. power distribution systems.

Provide assurance that cross-ties will not exist which could cause loss of emergency bus power to one unit due to testing of the other unit.

ii.

Modify Table 14A.1.43 to provide assurance that all sources (14A.1.43) of power supply to vital buses are capable of carrying full loads.

If some portions of the power supply cannot be full load tested, provide justification.

We have noted on other plant startups that the capacities 13.

(14A. l.10) of pressurizer or main steam relief valves and turbine bypass valves are sometimes in excess of the values assumed in the accident analyses for inadvertent opening or failure of these valves.

Modify Table 14A.1.10 to include a description of the testing that demonstrates that capacity of these valves is consistent with f

your accident analysis assumotions.

Include a test description that will verify that open and 14, (14.2.12) reclosure setpoints for all safety and relief valves are i

checked at temperature.

l Modify Table 14A.1.16 to include a test that will verify 15.

(14A.1.16 that paths for the air-flew 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.

i

Itisthestaff'shositionthatthecontainmentrecircu-16.

(14A.l.26) lation fan should be tested.

This test' should include verification that the recirculation fan motor current is within its design value at conditions representative of accident conditions.

Address such issues as air density, temperature, humidity, fan speed, and blade angle.

17.

List any tests, or portions of tests, described in (14.2.12)

Section 14.2.12 which you do not intend to perform on each unit and provide technical justification for deletion of each.

L 18.

Modify Table 14A.l.49 to verify that tests of sampling

-(14A.l.49) systems are adequate to verify flow paths, holdup times, l'

and procedures.

t.

Provide a preoperational test description to test contain-19.

(14.2.12) ment penetration coolers.' On those penetrations where coolers are not used, provide a startup test description that will demonstrate that concrete temperatures surrounding,

hot penetrations do not exceed design limits.

t Modify Section 14.2.11 to state that p'reoperational test 20.

(14.2.11) procedures will be available for examination by NRC regional personnel approximately 60 days prior to the scheduled performance of a preoperational test.

e J.

t 21 If portions of any preoperational tests are intended to be (14.2.12) conducted, or their results approved, after fuel loading:

(1) list each test; (2) state what portions of each test will be delayed until after fuel loading; (3) provide technical justification for delaying these portions; and (4) state when each test will be completed (key to test

' conditions defined in Chapter 14).

Note that any test that you do not intend to begin prior to fuel loading should be included in your startup test phase ihstead of the preoperational test phase.

22.t Our review of licensee event reports has disclosed that (14.2.12) many event.s have occurred because of dirt, condensed s

moisture, or other foreign objects inside instruments r

s and electrical components (e.g., relays, switches, breakers).

i Describe any tests or inspections that will be performed or any administrative control' will be implemented during your ini,tial test pro 3 to prevent component failures t

such ask these at your facility.

Modify' Table 14A.l.28 to demonstrate 23.

i (14A. l. 28 )

a)

The capability of the combustible gas control system to operate in response te oost-LOCA requirements.

b)

That post-LOCA hydrogen monitors function properly c)

To demonstrate the operability of the vacuum breakers t

Modify Tables 14A.l.30 and 14A.l.31 to include verifying 24.

(14A.l.30,31) % operability of the solid and liquid radwaste systems by

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testing with representative chemical waste streams.

The acceptance criterien for the solid radwaste system should s

require that-there _ be n'o ' free liquid in the solidification sampl e.

i 25.

Verify that acceptance criteria for startup transient

( 14.2.12) tests are based on realistic test conditions.

For example, when referencing your' accident analysis for deternining i

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'.2 1,!

proper plant response, verify that important parameters i

which determine plant response (such as buildup of decay products) are in accordance with the levels assumed in the accident analysis.

Regulatory Guide 1.68, Rev.1 (Appendix A, 2.b) requires cold i

26.

(14A.2.4) flow and no-flow rod drops to bound the conditions under which the control rods might be required to function to achieve plant shutdown.

Modify Table 14A.2.4 to include cold flow and no-flow rod drop tests, or provide a detailed technical justification that will en ure that your test conditions have, 1

in fact, bracketed the expected operation envelope.

1 Specify the appropriate sections and/or subsection in

]

g, (14A.1.11)

Chapter 6 to which tha acceptance criteria is referring in preoperational test No.14A.l.ll..

Specify the appropriate sections and/or subsection in 28.

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(14A.1.14)

Chapter 6 to which acceptance criteria No. 4.1 and 4.3 of-preoperation test No.14A.l.14 are referring.

29.

Specify the appropriate sections and/or subsections in (14A.1.26)

Chapter 6 to which the acceptance criteria of preoperational test 14A.l.26 is referring.

Specify the appropriate sections and/or subsection in l

30.

(14A.l.43)

Chapters 6 and 8' to which the acceptance criteria of preoperation test number 14A.l.43 is referring.

31.

Clarify what is meant by "section 16.3/4.3" on page (14A.l.53) 14A.1-56A.

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32.

Provide a test' abstra'ct in. Section 14A.4 which will demonstrate (14 A.a) that reactor. coolant system design heat removal capability exists using natural circulation cooling.

NUREG-0694, "TMI RelatedRequirementdforNewOperatingLicenses",ItemI.g.1, requires applicants to perform "a special low power testing

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program approved by NRC to be conducted at power levels no l

greater than 5% for the purposes of providing meaningful technical information beyond that cbtained in the normal startup test program and to provide supplemental training".

To comply with this requirement new PWR applicants have comitted to a series of natural circulation tests.

To date, such tests have been performed at the Sequoyah I', North Anna 2, and Salem 2 facilities.

Based on the success of the programs at these plants, the staff has concluded that aug-mented natural circulation training should be performed for all future PWR operating licenses.

The natural circulation tests must fulfill the following objectives:

Testing The tests should demonstrate the following plant characteristics:

length of time required ~ to' stabilize natural circulation, core flow distribution, ability to establish and maintain natural circulation with or without onsite and offsite power, the ability to uniformly bora'te and cuci down to hot shutdcwn conditions using natural circulation, and subcooling nenitor performance.

Training Each licensed reactor operator (R0 or SRO who performs RO or SRO duties, respectively) should participate in the initiation, maintenance, and recovery from natural circulation mo'de.

Operators should be able to recognize when natural circulation has been stabilized and should be able to control saturation margin, RCS pressure, and heat removal rate without exceeding specified operating limits.

. = -.

-7.

)

If these tests have been parformed at a comparable prototype plant, they need be repeated only to the extent necessary to accomplish the above training objectives.

33.

Modify the Auxiliary Feedwater System (AFWS) Preoperational (14A.1.5)

Test (14A.1.5) to include demonstration of an automatic transfer of the AFWS water supply from the condensate storage tank to the service water system.

In the acceptance criteria of test 14A.1.73, define the 34.

(14A. l. 73) criteria used to demonstrate whether a location is imune to RFI.

Also, define the criteria used to determine if a location " exhibits RFI sensitivity".

35.

Upgrade Table 14.2-1 to include preoperational tests corres-(14.2.12) ponding to the latest revision.

36.

Upgrade Table 14.2-4 to include power ascension tests (14.2.12) corresponding to the latest revision.

Your response to question'110.29 (14A) is inadequate.

Include 37.

(14A) in the 14A.l.74 test description that' a preservice~ examination will be made after snubber installation but not more tnan 6 months prior to initial system preoperational testing.

Also if the period between the initial preservice examination and initial system preoperational test exceeds six months due to unexpected situations, reexamination of test methods 3.1, 3.5, and 3.6 shall be performed.

i 38.

Modify Test Abstract 14A.l.1 (Main Steam Line Isolation

(

l (14A.l.1)

Valves) to include in test method subsection 3.1 a test l

to ensure that valve closure does not occur on loss of ac or de power alone unless a main steam line isolation signal is present.

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39.

Modify Table 14.2-4 to indicate at which power levels the (14.2)

Turbine Trip Test (14A.4519) and Generator Trip Test (14A.4.20) will be conducted.

Note (4) in Table 14.2-4 refers to Test Abstract 14A.4.14.

40.

(14.2)

Include the power levels at which the Process Steam Startup

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Test (14A.4.14) will be perforred in Table 14.2-4 and delete note (4).

41.

Table 14.2-1 lists a preoperational test 14A.l.65 (Reactor (14.2)

Internal Components Inspection) as being available on page 14A.1 -70.

This test is not included in the present Chapter 14 version.

Include this abstract in appendix 14A and modify Table 14.2-1 to reflect the test addition.

Modify Table 14.2-4 or provide an additional table so that in 42.

(14.2) addition to indicating the power levels at which the individual tests are accomplished, a table also exists which correlates the tests, test numbers, and identifying page for the power ascension tests.

l Section 14.2.7 states that Regulatory Guide Conformance is given 43.

(14.2.7) in Appendix 3A.

j 4

(1)

Modify Appendix 3A (page 3A-28) to indicate that the applicable revision of Regulatory Guide 1.20 is number two (effective docket date 6-22-76).

(2)

Modify Appendix 3A (page 3A-100 and 100A) to indicate that the applicable revision of Regulatory Guide 1.68 is number one (effective docket date 9-15-77).

In additicn, modify the reouested exceptions to Regulatory Guide 1.68 to correspond to the applicable sections of revision one.

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44.

Figure 14.2-2 provides the test program sequence for Units #1 (14.2)

.and #2.

Several portions of the test sequence require t

explanation.

(1)

Explain why the Reactor Building Leak Rate Test -ILRT (14A.l.60) is perfomed before the Precore Load Hot Function Testing (14A.1.64) for Unit #1, but the sequence is reversed for Unit #2.

(2)

Testing of the Engineered Safety Features Actuation System (ESFAS) is conducted at the same time for both Units #1 and #2.. At the time Unit il will not have completed Construction and prerequisite Ter.ts and will have over 5 months of preoperational Testing left to accomplish.

Explain how an integrated test of the ESFAS system can be accomplished which will verify proper bus stripping, separation of non-vital loads, and proper sequencing of vital loads as well as the correct operation of all ESFAS subsystems when a large number of the individual systems still require major testing.

45.

Section 14.2.1.1 states that in the final stages of preoperational (I4'2*I*I) testing, an integrated precore hot functional testing program is oerfomed.

Figure 14.2-2 indicates that this testing is ccmpleted eight (8) months before the completion of preoperational testing and over four (4) months before all construction and prerequisite tests are completed fpr Unit #2.

For Unit #1 the numbers are six (6) months and two (2) months, respectively.

Modify Figure 14.2-2 to indicate that hot functional testing will actually be accomplished during the final stages of preoperational testing or explain how performing this testing as early as it is being accomplished will allow the objectives stated in Section 14.2.1.1 (a-g) to be effectively accomplished..

Section 14.2.7 states that compliance with Regulatory Guide 46.

(14.2) 1.106 is discussed in Appendix 3A.

Appendix 3A (p. 3A-140b) states that the responsi to.this Regulatory Guide will be provided by amendment.

Modify Appendix 3A to reflect the status.

of compliance to Regulatory Guide 1.106.

Secti'on 14.2.11 states that operating procedu es including r

g (I4*2*II) emergency procedures are available for onsite review 30 days i

prior to initial fuel loading.

Section 14.2.11 states that operating and emergency procedures are trial tested during hot functional testing (6-81/2 months before fuel load) and i

engineered safety feature testing (two weeks to 5 months before j

fuel load).

(1)

Will drafts of all operating and emergency procedures be available for use during hot functional testing?

If not, describe what will be done to ensure that those unvalidated procedures function properly prior to fuel-load.

(2)

Explain how the procedures available for onsite review 30 days prior to initial, fuel load (14.2.11) can be written

~

to incorporate ESFAS test results when that testing won't be conducted until two weeks prior to initial fuel load (14.2.9.a)

Section 14.2.11 states that following fuel load startup testing g,

(14.2.11) spans approximately 8 months for Unit #1.

Figure 14.2-2 indica'.es that Unit #1 has 6 months scheduled for startup testing.

Modify Section 14.2.11 or Figure 14.2-2 to eliminate this inconsistency.

1 49.

Modify Section 14.2.11 to ensure that all procedures are available (14.2.11) for review in accordance with Regulatory Guide 1.68 (Revision 1),

-Appendix B.

Note that it is pemissible to substitute the position stated in Appendix B of Regulatory Guide 1.68 (Revision 2) for the Revision i version.

4 l

Review f the preoperational test phase description disclos d 50.

(14A.1) that the operability of several of the systems and components listed in Regulatory Guide 1.68. (Revision 1 ), Appendix A.,

may not be demonstrated:by the preoperational test phase as described in Appendix 14A.l.

Expand Appendix 14A.1 to address the following items:

1.a.2 Reactor Coolant System Component Tests:

(a)

Pressurizer (f)

Additional Valves (g)

Instrumentation:

1) system performance 2) permissive and interlock functions (h)

Reactor Vessel and Internals (including vent valves)

(i)

Safety Valves 1.a.3 Vibration Tests Monitoring of Reactor Internals and Other Components Such as Piping Systems, Heat Exchangers, and Rotating Machinery 1.d.3 Relief Valves 1.d.7 Main Steam Isolation Valves, Sranch Isolation Valves, and Nonreturn Valves 1.d.9 Condensate Storage 1.d.10 Emergency Cooling Towers 1.d.ll Cooling Water Systems l.e.1 Steam Generators 1.e.2 Main Steam System and Process Steam System 1.e.3 Main Steam Isolation Valve 1.e.4 Steam Generator Pressure Relief and Safety Valves 1.e.S Steam Extraction System 1.f.2 Cooling Towers and Associated Auxiliaries 1.f.3 Ultimate Heat Sink 1.f.4 Raw Water System

1.g.4 DC Electr.ical System 1.h.1 (a)

Expansion and Restraint Tests of the ECCS (b)

Normal and Emergency Power Supply Operation of the ECCS (d)

Overpressure Protection for Low Pressure Cooling Systems 1.h,.5 Prompt Relief Trip Features 1.h.6 Cold Water Interlocks 1.h.8 Ventilation, Recirculation, and Filter Systems to Minimize Radioactive Release 1.h.9 ECCS Tanks and Other' Water. Sources 1.h.10 Containment Recirculation Fans 1.i.2 Isolation Valves Functional and Closure Timing Tests 1.i.5 Air Lock Leak Rate 1.i 6 Containment Integrated Leak Rate Test 1.i.7 Main Steam Line Leakage Sealing System 1.i.8 Primary and Secondary Containment Isolation Initiation Logic 1.i.9 Containment Purge Syste.m 1.1.10 Containment and Containment Annulus Vacuum Breaker Tests 1.i.11 Containment Leak Collecticn and Ex'naust System Tests 1.i.12 Containment Air Purification and Cleanup 1.i.13 Containment Inerting System 1.i.14 Standby Gas Treatment 1.i.15 Containment Penetration Pressurization 1.i.16 Containment Ventilation i

1.i.17 Secondary Containment Vent 1.i.18 Annulus Leak Rate 1.i.21 Containment Penetration Cooling System-t

1.j.2 Main,k'uxiliary,EmergencyFeedwaterControlSystems 1.j.3 Secondary System Steam Pressure Control 1.f.4 Recirculation. Flow Control 1.j.5 Reactor Coolant System Leak Detection 1.j.7 ECCS Leak Detection and Containment Retirculating Spray Systems Located Outside Containment 1.j.8 Automatic Reactor Power Control and T-Average Control Systems 1.j.9 Pressure Control Systems to Maintain Boundary Differential Pressures 1.j.11 Traversing Incore Probe 1.j.12 Failed Fuel Detection 1.j.13 Incore Instrumentation 1.j.14 Water Supply Transfers to Auxiliary Feedwater Pump, ECCS Pumps, and Containment Spray 1.j.15 Automatic Dispatcher Control System 1.j.16 Hotwell Control 1.j.17 Feedwater Heater Temperature Level and Sypass Control 1.j.18 Auxiliary Startup Instrument Tests (Neutron Response) 1.j.19 Instrumentation and Controls Used for Remote Shutdown 1.j.20 External and internal Flooding D,etection 1.j.21 Reactor Mode Switch and Associated Functions 1.j.22 Postulated Accident Tracking 1.j.23 Postaccident Hydrogen Monitors and Analyzers in Ccmbustible Gas Control 1.j.24 Annunciators for Reactor Control and Engineered Safety Features

1.k.2 Personnel. Radiation Monitors 1.1.4 Isolat' ion Features for Steam Generator Blowdown 1.1.5 Isolation Features for Condenser Offgas 1.1.6 Isolation Features for Ventilati'on System 1.1.7 Isolation Features for Liquid Radwaste Effluent 1.ni.2 Refueling Equipment 1.m.3 Refueling Canal and Fuel Storage Pool Leak Jests 1.m.5 Fuel Transfer Devices 1.m.6 Irradiated Fuel Pool or Building Ventilation System 1.n.2 Closed Loop Cooling Water System 1.n.5 Reactor Coolant and Secondary Sampling System 1.n.8 Seal Water System 1.n.14 (b)

Primary Containmerit HVAC (c)

Battery Room HVAC 1.n.15 Shield Cooling System i

1.n.16 Refueling Water Storage Tank Cooling and Heating 1.o.1 Dynamic and Static Load Test of Reactor Component Handling Systems Your response to item 423.2 was not complete.

Your response i

51.

(14.2) to part 15; part 21, subpart 6; and part 30, subpart 3, state 1

that these parts would be answered by amendment.

State your current position on these questions.

I I

I

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52 Review of the startup phase of your testing program has (14A) shown that several tests required by Regulatory Guide 1.68, Rev.1, Aopendix A have not Eeen included.

Expand Sections 14A.3 and 14A.4 of the FSAR to include.the following:

4.u Reactor coolant system natural circulation tests 5.c Core power distribution stability following full and partial length control rod movements d

Control rod pattern exchange e

Core xenon transients i

Controlrodmisalijnment q

Failed fuel detection systems ee Primary containment inerting and purge systems hh Dynamic resoonse to design load swings kk Dynamic response to loss of feedwater heater i

ao Verifications of piping vibrations and movements 53.

Expand the Reactor Coolant Flow and Flow Coastdown Test (14A.2.3) to include the following:

(1)

Establish that vibra. tion levels are acceptable (2)

Demonstrate that differential pressures across the fully loaded core and major RCS comoonents are as expected (3)

Show that piping reactions to transients are as predicted Modify Table 14.2-4 to include testing o'f the Incore 54.

(14A.4.7)

Monitoring System at 100 ". nower.

55.

Online computer che'ckout tests must include verification (14A.4.17) of correct signal input.

All computer safety functions must be validated.

Incorocrate these above items in your

.FSAR.

e __

The response to question 42,3.1 Item 1(2) is not totally acceptable.

56.

(14.2.4)

Modify test abstract 14A.4.12 (page 14A.4-13) to include the

, demonstration of outside the control room cold shutdown ability.

l This can be accomplished by partia'lly cooling down the plant from I

the hot standby condition using controls and instrumentation located outside the control room.

The response to question 211.175 is not totally acceptable.

Expand 57.

(14.2.1) the existing test abstracts, or include additional abstracts, that will demonstrate operab lity of the ECCS in accordance with Regula-tory Guide 1.79, Sections C.l.a.(2) and C.I.c.(1).

The response to question 423.1, Item 1(3) is not adequate.

Modify 58.

(14.2.1) test abstract 14A.1.34 (page 14A.1-35) to ensure conformance with Regulatory Guide 1.80.

59. (14.2.1)

Define the term " Mode 6" as it appears on page 3A-142.

ine response to question 423.1, Item 1(5) is not totally acceptable.

60.

(14.2.1)

Perform the following:

a) 1)

Modify test abstract 14A.l.42 (page 14A.1-44) to include operational testing of the diesel generators (manual and automatic controls), interlocks, and trips anc cperation following a simulated loss of all A.C. voltage.

2) include provisions which will verify that voltage require-ments are met and that overspeed limits are not exceeded during diesel generator load shedding.

b)

Modify position on Regulatory Guide 1.108 (page 3A-142) to run the diesel generator at the 2-hour rating for 2-hours.

61.

Include in Table 14.2-1 description of test (s) which will assure (14.2.1) compliance to Regulatory Guide 1.20 for a non-prototype category II system.

This includes as a minimum system analysis, limited measurements, and full inspection.

Include verification testing in the preoperational tests (Table 62.

(14.2.1) 14.2-1) for the utility's position on Regulatory Guide 1.95.

Also include gross leakage characterization of the control room and a statement of emergency procedures to be initiated in the event of a chlorine release.

Include a statement regarding your level of conformance with 63.

(14.2.1)

Regulatory Guide 1.128.

Modify the auxiliary feedwater system test abstract 14A.l.5 (page 64.

(14.2.1) 14A.1-6) to include operability verification with either only onsite or only offsite power available.

65.

Perform the following to the DHRS Test 14A.l.11 (page 14A.1-ll)

(14.2.1) sections:

a) 3.1.1 - 3.1.8:

Add sufficient detail to ensure proper verification of test purpose, b) 3.2:

Include demonstration of pump protective devices from failures that could possibly r,esult from overheating and cavitation.

Modify. test abstract 14A.l.27 so the following will be demon-(14.2.1) strated:

a)

Radiciodine removal efficiency, per testing requirements of RDT MIG-IT.

b)

Proper air flow distribution through the filter and absorber.

banks.

Certain terniinology used in the individual test description 67.

(14.2) does not clearly indicate the source of the acceptance criteria to be used in determining test adequacy, an accep-table format for provi~ ding acceptance criteria for test results includes any of 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 cannot be provided in any of the above ways)

Modify the individual test description abstracts presented below to provide adequate acceptance criteria for all items in the respective test sumaries 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.

a)

Specified, within specification (s), specified limits, as specified, verified, is proper, within required limits of the everall system requirement, specified systems, within technical specifications limits, within specif sed toierance, specified runback conditions, 14A.l.3 pg. 14A.1-3 14A.l.10 pg. 14A.1 -10 14 A.1.18 pg. 14A.1-19 14A.1.36 pg. 14A.1-38 (three times) i 14A.l.37 pg. 14A.1-39 (two times) 14A.l.42 pg. 14A.1-44a (two times) 14A.1.43 pg. 14A.1-46 14A.1.50 pg. 14A.1-53 14A.l.52 pg. 14A.l 56 I

14A.l.53 pg. 14A.1-56a 14A.l.60 pg. IdA.1-63 14A.I.66 pg. 14A.1 -71 14A.l.67 pg. 14A.1-72 14A.2.7 pg. 14A.2-7 (two times) l

14A.2.8 pg. 14A.2-8 14A.3.2 pg. 14A.3-2a (four times) 14A.3.2 pg. 14A.3-2 14A.3.3 pg. 14A.3-3 14A.3.4 pg. 14A.3-4 14A.4.4 pg. 14A.4-5 14A.4.4 pg. 14A.4-5 14A.4.6 pg. 14A.4-7 14A.4.15 pg. 14A.4-16 14A.4.16 pg. 14A.4-17 14A.4.17 pg. 14A.4-18 14A.4.18 pg. 14A. 4-19 14A.4.19 pg. 14A.4-20 14A.4.20 pg. 14A.4-21 b) design quality, operate as designed, with specified design specification, perfonn as designed, reets design specifications, function as designed, des.ign capacity, as described, under design conditions, design pressure, design predictions,* design specficiations, design cold setting, within design limits, within design tolerances, 14A.l.3 pg. 14A.1-3 14A.l.4 pg. 14A.1-5 14A.1.9 pg. 14A.1-9 14A.1.12 pg. 14A.1 -12 a 14A.1.17 pg. 14A.1-17 (two times) 14A.l.17 pg. 14A.1-18 (three times) 14A.l.29 pg. 14A.1-30 14A.l.29 pg. 14A.1-30a (two times) 14A.l.49 pg. 14A.1-52 14A. l. 61 pg. 14A.1-64 14A.1.62 pg. 14A.1-65 14A.l.63 pg. 14A.1 -66 14A.'l. 65 pg. 14A.1-70 14A.l.74 pg. 14A.1-80 x

~

14A.'1.75 pg. 14A.1-81 14A.2.6 pg. 14A.2-6 14A.4.4 pg. 14A.4-5 c) required setpoint, required by the system design, required opening forces, performs its design functions, between all design sources, between systems, as

required, 14A.1.10 pg. 14A.1 -10 14A.1.12 pg. 14A.1-12a (two times) 14A.1.36 pg. 14A.1-38 14A.1.38 pg. 14A.1-40 14A.1.39 pg. 14A.1-41 14A.1.40 pg. 14A.1 -42 14A.1.41 pg. 14A.1-43 14A.1.70 pg. 14 A.1 -75 14A.4.5 pg. 14A.4-6 d) maximum flow conditions, adequate clearance, within the minimum and maximum values, minimum allowable flowrate calculated, the guaranteed rating 14A.l.14 pg. 14A.1-14a 14A.1.74 pg. 14A.1-80 14A.2.3 pg. 14A.2-3 (two times) 14A.4.5 pg. 14A.4-6 e) proper operation, proper vacuum and remove non-condensible gases, do not exceed the alara setting, function properly, are documented, are acceptable, properly received, not exceed the minimum D"BR or maximum linear heat rate limits, can be controlled, compare, have been recorded, 14A.l.19 pg. 14A.1-20 14A. l. dl pg. ldA.1-43 14A.l.56 pg. 14A.1-60 14A.l.70 pg. 14A.1-75
laA.3.5 pg. 14A.3-5 m1 R w.

r.

14A.4.1 pg. 14A.4.1 14A.4.9 pg. 14A. 4.10 14A.4.10 pg. 14A.4-11 14A.4.12 pg. 14A.4-13 f) installed, removed, stored, adjusted applicable areas satisfactorily adjusted, properly calibrated, operable, within the specified factor, predict adequate perfor-mance, consistant and reasonable, is demonstrated,

compare, 14A.1.36 pg. 14A.1-38 14A.1.47 pg. 14A.1-50 14A.1.74 pg. 14A.1-80 14A.l.75 pg. 14A.1-82 14A.2.1 pg.14A.2-1 (two times) 14A.2.5 pg. 14A.2-5 14A.2.6 pg. 14A.2-6 14A.4.4 pg. 14A.4-5 14A.4.7 pg. 14A.4-8 14A.4.8 pg. 14A.4-9 14A.4.13 pg. 14A.4-14 g) requirements given in regulatory guide 1.52,14A.l.27, pg. 14.1-28.

Review of licensee event reports disclos'ed that a number of 68.

(14.2) sensing lines were rendered inoperable due to being frozen

(

and/or blocked with crud, dirt, and entrapped gas.

Provide a description of the inspections or tests that will be performed l

to ensure that the sensing lines are clear prior to utilizaticn.

69.

Review of licensee event reports disclosed that some instrumenta-tion drift problems are due, in part, to extremes of local tempera-ture and humidity, provide a description of the inspections or tests that will be performed to minimize setpoint drift due to local temperature and humidity extremes.

I

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MEETING NOTICE DISTRIBUTION Docket File Jo - 32 </

HRC PDR Local PDR FEBRUARY 10, 1982 TIC.

NSIC TERA LBf4 r/f E. Case D. Eisenhut/R. Purple Q

T. Novak p

S. Varga D

D. Vassallo ECpf R. A. Clark 2

EO

$2 1 R. Tedesco rg E. Adensam J. Youngblood

/

A. Schwencer g'

F. Miraglia A

t3 J. R. Miller O

G. Lainas D. Crutchfield W. Russell R. Vollmer W. Johnston D. Muller R. Mattson L. Rubenstein T. Speis B. Grimes J. Kramer S. Hanauer F. Schroeder M. Ernst ACRS (16)

Attorney, OELD 01&E (3)

OSD (7)

Receptionist J. LeDoux, I&E I&E Headquarters I&E Region I I&E Region II IAE Region III I&E Region IV I&E Regior: V Project Manager R. Hernan Licensing Assistant M. Duncan m

NRC PARTICIPANTS S. MacKay R. Hernan i

i