ML20045C836

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Forwards Responses to NRC Comments on Startup Test Matl Dtd 930607 & on pre-operational Test Matl Dtd 930614
ML20045C836
Person / Time
Site: 05200001
Issue date: 06/18/1993
From: Fox J
GENERAL ELECTRIC CO.
To: Poslusny C
Office of Nuclear Reactor Regulation
References
NUDOCS 9306240456
Download: ML20045C836 (5)


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u - GENucicar Energy General!!ectac Company 175 Curtner Annae. Son Jose. CA 951?S June 18,1993 Docket No. STN 52-001 l

Chet Poslusny, Senior Project Manager Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of the Nuclear Reactor Regulation

Subject:

Submittal Supporting Accelerated ABWR Schedule - Startup and Pre-operational Test Material

Dear Chet:

Enclosed are respon ;es to NRC comments on startup test material dated June 7,1993 and on pre-operationn' test material dated June 14,1993.

Please provi.J - " of this transmittal to Frank Talbot.

Sincerely,

  • l ack1-3 Advanced Reactor Programs cc: Norman Fletcher (DOE)

IL J. Yang (GE) p

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9306240456' 930618 W

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~1 Response to NRC's Comments dated 6/14/93 Preoperational Test Material open Item 14.2.12.3-2 Cross reference information within SSAR has been added to 14.2.12.1.46 and 14.2.12.1.68. There is no SSAR subsection for the hot water heating system.

However, the acceptance criteria currently existing in 14.2.12.1.31.(3) are based upon the available design document and test requirement specs. Thus, I believe that the test abstract section is adequate without the SSAR cross ref erence information.

TSI 14.2.10.1-1 and 14.2.12.4-1 J. revision to our April 16 response to DFSER TSI 14.2.10.1-1 and 14.2.12.4-1 is being prepared by Cal Tang. I have recommended to Cal on using applicable preop. tests (i.e., 14.2.12.1.6 for scram valve operability and 14.2.12.1.15 for SRNM) rather than referencing to LCOs for resolving this lasua.

Preoperational Test Program Issues ,

Section 14.2.1 The quoted paragraph from May 7, 1993 submittal was incorporated into the second paragraph of 14.2.1. I believe it would be more appropriate to add this paragraph to this location than that origir. ally specified in 5/7/1993 submittal.

Section 14.2.12.1.11 ,

The SSLC verification and validation test is a part of the preoperational phase test and covered by 14.2.12.1.11.(3). Therefore, the quoted sentence

' in Feb.12, 1993 submittal was removed from the prerequisite section. The last two sentences of Feb. 12, 1993 markup were inadvertently combined into one sentence during typing. The removed specific information will be added to the prerequisite section in Amendment 30 to be consistent with 2/12/ 1993 markup submittal.

Section 14.2.12.1.14 The quoted timing criteria is for the seal-in and reset function of the RPS trip logic circuitry. Based on the RPS design, all manual resets shall be automatically inhibited for ten seconds following a full reactor scram. This  ;

verification shall be a part of the RPS preoperational testing and won't bs done in conjunction with the CRD preop, test.

Section 14.2.12.1.21 The quoted missing text per February 12, 1993 markup was removed based on a verifier's comments. The end sentence as statad needs not be repeated since  ;

the flow path for FPCCU system normal mode of operation is readily specified j in the PFD.

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l section 14.2.12.1.30 l The quoted electrical instrument equipment was removed from the prerequisite i section based on a verifier's comments. It is hard to define the content of ]

electrical instrument equipment. Additionally, METES need not be specified in detail as a part of the prerequisite.

Section 14.2.12.1.43 The quoted test for verifying proper functioning of valve positive closure '

devices including valve leak tightness test was . inadvertently omitted during typing. This test item will be added to 14.2.12.1.43.(3) in Amendment 30 to .

be consistent with the original submittal.

Section 14.2.12.1.50 There is no thermal sleeve between CRD housing and drive in accordance with the ABWR design. Therefore, the quoted thermal sleeve installation tool was -

removed from the test item section.

Section 14.2.12.1.51 No change will be made to this item since CUW and RCW are the correct system abbreviations for RWCU and RBCCW respectively per ABWR design terms Section 14.2.12.1.59 Same as response to Section 14.2.12.1.30 comment.

Section 14.2.12.1.61 Yes. The RSW heat exchanger testing has been incorporated into one of the startup phase test item in Section 14.2.12.2.23.

Section 14.2.12.1.62 The quoted test 14.2.12.1.62.(3).(n) was inadvertently added ro the text during typing and will be removed from the text in Amendment 30.

Section 14.2.12.1.64 Yes. The TSW heat axchanger testing has been incorporated into one of the startup phase test item in Section 14.2.12.2.23. l Section 14.2.12.1.67 Same as response to Section 14.2.12.1.30 comment.

Section 14.2.12.1.68 ,

same as response to section 14.2.12.1.30 camment.

Section 14.2.12.1.72 The quoted item 14.2.12.1.72. (3) . (d) . (iv) has been moved to the preceding Jriteria statement of 14.2.12.1.72.(3).(d) for consistency throughout the text.

, 1-a i Response to NRC's Cazment on June 7, 1993 Submittal Startup Test Material

1. Page 14.2-129 of 6/7 document i

The quoted words "for those systems incorporated" will be removed from the description section in Amendment 30.

2. 14.2.12.2.6 Neutron Monitoring There is no such requirement to calibrate BRNM to indicate actual core thermal power base on (Ae currently existing Technical Specificationa.

However, a requirement to calibrate SRNM and APRM based on a constant heatup rate heat balance calculation during initial heatup will be added to the description section in Amendment 30.

3. 14.2.12.2.6 Neutron Monitoring As stated in the response to Itam 2 above, there is no requirement in current Tech Specs to calibrate BRNM to read actual core thermal power.

However, a requirement will be added to description section to ensure SRNM and APRM read reasonable core thermal power during initial heatup.

Both Level 1 and 2 criteria concerning the calibration will be changed -

accordingly in Amendment 30.

4. 14.2.12.2.12 As stated in the 14.2.12.1.52 test abstract section, flow testing is to be done during RRS/RPV internal hot functional test at rated volumetric core flow, at rated temperature and pressure conditions without fuels in the core. However, startup phase of reactor internal vibration testing is done with fuel loaded in the core. The flow conditions are different with and without fuels since flow resistance is different between these two cases.
5. 14.2.12.2.10 Tho quoted words were inadvertently amitted during typing and will be added to the description section in Amendment 30.
6. Table 14.2-1 Ganged rod motion test was moved from OV to HU. With mode switch at REFUEL position during OV phase, it is not allowed to withdraw rods in-ganged groups for demonstration or realignment, if necessary.

Four slowest rods will be determined during full core scram as stated in the text. Full core scrams are required to be performed at HP. Note is misleading and will be revised in Amendment 30.

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SRNM response / calibration test at LP plateau was inadvertently omitted and will be added to Table 14.2-1 in Amendment 30.

Reactor coolant temperature measurements are required in conjunction with RIP trip and restarts and during steady state operation at various power levels. Note is misleading and will be revised in Amendment 30.

Suppression pool cooling can be demonstrated in conjunction with the SRV flow demonstration and operability testing which is scheduled at LP.

Additionally, this test can also be done when test with heat adding to lne suppression pool is being performed as stated in the text. The words "In conjunction with SRV test or after ..." will be added to the note in Amendment 30.

The word " hand" under CUW performance test is a typo and should be " head" instead. However, this word " head" will be deleted from Table 14.2-1 in ,

Amendment 30 to be cor.sistent with the "RPV Spray Mode" statement in the description section.

Turbine trip and load rejection is a correct title for this test. A turbine trip will initiate generator trip and vice versa. A load L rejection (not generator load rejection) at greater than or equal to 40%

of rated thermal power, mismatch between turbine first stage pressure and generator output trips only control valves and intercept valves. Note that turbine is not tripped and generator remains on line in response to this event.  :

As stated in the description section of 14.2.12.2.38, a separate radwaste system performance testing is not necessary. Testing specific to the main condenser offgas system is done separately in 14.2.12.2.35. Radiochemical analysis on liquid and gaseous effluents from radwaste system is performed in 14.2.12.2.1. Therefore, 14.2.12.2.38 is a duplicated testing and should be optional.

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