ML20045G945

Forwards Set of Design Descriptions & Insps,Tests,Analyses & Acceptance Criteria for ITAAC Sys 80 for Initial Test Program

ML20045G945
Person / Time
Site:	05200002
Issue date:	06/29/1993
From:	Brinkman C ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
LD-93-104, NUDOCS 9307160174
Download: ML20045G945 (4)

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A RD EB LFARH99 ASEA BROWN DOVERf June 29, 1993 LD-93-104 Mr. Dennis M. Crutchfield Associate Director for Advanced Reactors & License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Special ITAAC Submittal Reference- Letter, R. A. Matzie (ABB-CE) to S. J. Chilk (NRC),

dated May 27, 1993

Dear Mr. Crutchfield:

We have submitted, by separate correspondence, the set of Design Descriptions and Inspections, and Acceptance Criteria (DD/ITAAC) for System Tesg 80+ , hichAnalyses w ABB-CE believes are needed to meet 10 CFR Part 52 requirements.

The NRC staff has requested three additional DDs and two additional ITAAC covering the Initial Test Program (ITP), the Design Reliability Assurance Program (D-RAP), and Plant Operating Procedures (POPS). ABB-CE objects to the inclusion of these DDs and ITAAC because we regard them as programmatic and, therefore, unnecessary and not readily amenable to unambiguous and meaningful acceptance criteria.

In the reference letter, we recited in detail our objections to elevating the D-RAP to DD/ITAAC status. We acknowledge your response saying our arguments did not change the staff's opinion.

We continue to await the Commission's decision on this issue. In the meantime, so as to avoid impacting the System 80+ review schedule, we are forwarding a proposed D-RAP DD which can be used during the ITAAC reviews with the understanding it will be retracted if the Commission agrees with our request.

The ITP DD/ITAAC is submitted on the same basis and we ask the staff to reconsider its necessity when the Commission rules on the D-RAP issue.

ABB Combustion Engineering Nuclear Power

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l Mr. Dennie M. Crutchfield LD-93-104 June 29, 1993 Page 2 We believe the POP issue should be a COL action item and not be elevated to DD/ITAAC status as a programmatic ITAAC. We are deferring submittal of a POP DD/ITAAC pending the outcome of further discussions on this issue.

We hope this submittal will facilitate the System 80+ review whila preserving ADB-CE's right to request reconsideration of staff positions we believe not to be in the best interest of the ultimate COL holder.

Thank you for your cooperation in this matter.

Very truly yours, b kbn A~

C. B. Brinkman Acting Director Nuclear Systems Licensing GDH/ak cc: P. Lang (DOE)

J. Trotter (EPRI)

K. Karr (INPO)

R. Mcdonald (ARC)

T. Wambach (NRC)

A. Heymer (NUMARC) w . ,

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SYSTF.M 80+"  !

2.11 INITIAL TEST PROGRAM l

An Initial Test Program (ITP) is performed following completion of construction  ;

activities and construction-related inspections and tests and extends to a declaration of commercial operation. The ITP has preoperational and startup test phases.

The preoperational test phase of the ITP consists of those test activities conducted prior to fuel loading. Preoperational testing is conducted to demonstrate that structures, systems, components, and design features of the as-built plant meet the performance requirements of the design. Equipment functional tests, system operational tests, and system vibration and expansion measurements are conducted during preoperational testing.

The startup test phase of the ITP begins with fuel loading and extends to a declaration of commercial operation. Startup testing is conducted to demonstrate that the integrated plant with the nuclear fuel in the reactor pressure vessel meets the

• performance requirements of the design. Startup testing is performed with the plant operating at power levels ranging from zero power to full rated power. Startup testing is conduct ed at five test conditions: open vessel (fuel load), heatup, low power, mid-power, and high power. Startup testing includes testing of:

nuclear fuel system performance, steady-state plant performance, control system performance, and transient performance.

The ITP is performed using detailed preoperational and startup procedures to control the conduct of testing. Detailed test procedures delineate the test methods to be used and the applicable acceptance criteria against which performance is evaluated.

Test procedures are developed from preoperational and startup test specifications.

Administrative procedures are used to control the conduct of the test program; the review, evaluation and approval of test results; and test record retention.

The tests specified in Section 2.0 are a subset of the ITP.

2.11 . . -

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SYSTEM 80+"

3.3 DESIGN-RELIABILITY ASSURANCE PROGRAM A Design-Reliability Assurance Program (D-RAP) is conducted during the detailed design and through the equipment selection phase. 'Ihe D-RAP provides a means to factor into the detailed design, important reliability aspects from risk assessment.

The D-RAP identifies those systems, structures, and components (SSCs) whose reliability is significant to plant safety based on risk assessment. Relevant experience with significant SSCs can also be factored into the D-RAP.

The D-RAP factors the relative safety importance of SSCs into the detailed design and procurement processes, such that the reliability of SSCs of the certified design maintains the bases for the risk assessment.

The D-RAP provides risk significant information as input to the COL applicant for  ;

use in developing operating and maintenance programs for the plant.

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