ML20049H785

Forwards Request for Addl Info Re OL Application Review.Response Should Be in Form of Amend to FSAR

ML20049H785
Person / Time
Site:	South Texas
Issue date:	02/16/1982
From:	Miraglia F Office of Nuclear Reactor Regulation
To:	Oprea G HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8203030577
Download: ML20049H785 (20)

Text

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DISTRIBUTION:

Document Control:

HTocket File NRC PDR LB#3 File Local PDR DEisenhut NSIC FEB 16 M RTedesco TERA Docket Nos: 50-498 and 50-499 FMiraglia TIC DSells ACRS (16)

JLee IE IE Region IV W

Mr. George W. Oprea, Jr.

Executive Vict. President D S * *"" (

Houston Lighting & Power Company Post Office Box 1700 97 Hotston, Texas 77001 ch

Dear Mr. Oprea:

5 2

Subject:

Request for Additional Information - South Texa ect

/

/

g The Procedures and Test Review Branch has identified a number o ons that must be addressed prior to completion of their review of your operating license applications. The specific questions are listed in Enclosure 1.

Your response to these questions should be in the form of an amendment to your FSAR.

In view of your current activities with regard to changing contractors, you are requested to provide us with a schedule within 60 days of receipt of this letter by which you plan to respond to this request for additional information.

If you cannot supply a schedule within 60 days, please advi e us when it can be provided.

If you have any questions, contact D. Sells (301) 492-7100, the Project Manager.

Sincerely.

Original signed by, Frank J. Miraglia Frank J. Miraglia, Chief Licensing Branch No. 3 Division of Licensing

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page 8203030577 820216 PDR ADOCK 05000498 A

PDR

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NT.C FORM US tlO 80) NRCM O240 OFFICIAL RECOFiD COPY

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SOUTH TEXAS t

Mr. G. W. Oprea, Jr.

Mrs. Peggy Buchorn Executive Vice President

. Executive Director Houston Lighting and Power Canpany Citizens for Equitable Utilities, Inc.

P. O. Box 1700 Route 1, Box 1684 Houston, Texas 77001 Brazoria, Texas 77422 Mr. J. H. Goldberg William S. Jordan, III Esq.

Vice President - Nuclear Engineering Harmon & Weiss

& Construction 1725 I Street, N.W.

Houston Lighting and Power Canpany Suite 506 P. O. Box 1700 Washington, D.C.

20006

(

Houston, Texas 77001 Mr. D. G. Barker Brian Berwick, Esq.

Manager, South Texas Project Assistant Attorney General Houston Lighting and Power Company Environmental Protection Division P. O. Box 1700 P. O. Box 12548 Houston, Texas 77001 Capitol Station Austin, Texas 78711

~

Mr. M. L. Borchelt Central Power and Light Company Hilliam M. Hill P. O. Box 2121 Resident Inspector / South Texas Project Corpus Christi, Texas 78403 c/o U. S. NRC P. O. Box 910 Mr. R. L. Hancock Bay City, Texas 77414 City of Austin

~

Electric Utility Department P. O. Box 1088 Austin, Texas 78767 Mr. J. B. Poston Mr. Lanny Sinkin Assistant General Manager for Operations Pat Coy City Public Service Board Citizens Concerned About Nuclear Power P. O. Box 1771 5106 Case Oro San Antonio, Texas 78296 San Antonio, Texas 78233 i

Jack R. Newman, Esq.

Mr. Cloin Robertson l

Lowenstein, Nevnan, Axelrad & Toll Manager, Nuclear Licensing 1025 Connecticut Avenue, N.W.

Houston Lighting and Power Company Washington, D. C.

20036 P. O. Box 1700 Houston, Texas 77001 Melbert Schwarz, Jr., Esq.

Baker & Botts Charles Halligan One Shell Plaza Bechtel Power Coi poration Houston, Texas 77002-P. O. Box 2166 Houston, Texas 77001 s

Mr. E. A. Sal tare 111 Brown & Root, Inc.

P. O. Box 3 Houston, Texas 77001

.i ENCLOSURE 1 STAFF POSITIONS AND REQUESTS FOR ADDITIONAL INFORMATION l

SOUTH TEXAS PROJECT - UNITS 1 AND 2 i

INITIAL TEST PROGREM r

640.1 Modify Table 3.12-1 to indicate the degree of compliance with (3.12) the following:

(1)

Regulatory Guide 1.139.

J[

(2)

Regulatory Guide 1.140.

640.2 The response to item 423.9 is not adequate.

Modify Subsection

-i (14.2.11.5) 14.2.11.5 to state that all approved procedures will be avail-ll able for examination as stated, or describe the conditions j

that could be allowed to occur sucn that the procedures would l

not be available as planned.

640.3 List any tests', or portions of tests, described in Subsection (14.2.12) 14.2.12 which you do not intend to perform on Uni

• No. 2 and provide technical justification for the deletion of each.

640.4 Your response to item 423.17, part 3, and item 423.22, part nn, (14.2.12.2) is not acceptable.

It is the staff position that the preopera-tional testing of diesel generator units conform to positions C.2.a and C.2.b of Regulatory Guide 1.108.

Modify Section 3.12 and Phase II test number 81, Standby Diesel Generator Test, I

accordingly.

3 640.5 The response to item 423.19 and the information cqntained in

'l (14.2.10.2)

Subsection 14.2.10.2 does not adequately demonstrate that the approach to initial criticality is conducted in accora-ance with Regulatory Guide 1.68, Appendix C.3.

Modify Sub-section 14.2.10.2 to:

(1)

Ensure that rod withdrawal sequences and patterns are identical to those used in subsecuent startuos;

j (2)

Ensure that the signal-to-noise ratio is '<nown to be greater than two; (3)

Verify that all systems recuired for startup or plant protection are operable and reacy prior to initial criticality;

gn

.s -

(4)

Specify during which mode initial criticality is pre-

.I dicted to occur (dilution or withdrawal);

]3 (5)

Specify what precautions will be taken if criticality 1

is not achieved as predicted during deboration, orier

.[

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to proceeding with rod withdrawal; and (6)

State that a cautious approach to criticality will be conducted so as to prevent passing through criticality 1

on a period shorter than aporoximately 30 seconds (less than 1 decade per minute).

640.6 Your response to item 423.21 is not acceptable.

It is the e

(14.2.5) staff position that the test recuirenents for systems relied on to prevent, to limit, or to mitigate the consequences of q

postulated accidents be completec prior to exceeding 25% power.

j Modify Subsection 14.2.5 and the appropriate test abstracts accordingly.

640.7 Certain terminology used in the individual test descriptions ll (14.2.12) does not clearly indicate the source of the acceptance criteria j

to be used in determining test adequacy.

An acceptable format for providing acceptance criteria for test results includes any of the following:

1 Referencing technical specifications (Chapter 16)

Referencing accident analysis (Chapter 15)

Referencing other specific sections of the FSAR (ex. 7.4.1.2) t 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 jj below to 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.

(1)

Phase 11 Tests (a) required, recuired tolerance, as required, within required limi s I

- = _ -

d 4 !

5.b.2 33.b.3 d

6.b.1 35.b.1 ll.b.1

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16.b.1 59.b.1 i

I 20.b.3 70.b.1 21.b.1 72.b.1 26.b.2 79.b.3 26.b.3 92.b.2 4

27.b.1 9

29.b.2 o

j (b) as designed, appropriate design documents, design l

minimum, within design limits, below cesign maximum,

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in accordance with system design, per design, cesign i

requirements, in accorcance with design, within l

the limits prescribed by system aesign, design, i

design function h

2.b.3 30.b.1 43.b.5 r

5.b.1 30.b.2 44.b 7.b.1 31.b.1 45.b.1 i

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it 12.b.1 (twice) 32.b.3 48.b.1 14.b.1 32.b.4 49.b.1 r

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4 22.b.2 34.b.2 53.b.1

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71.b.1 82.b.2 97.b.2 71.b.2 82.b.3 97.b.3

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(c) within the rating, rated, near rated, within their ratings 2.b.1 l

3.b.4 7.b.1 8.b.1 10.b.5 i

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(u) misalignments 77.b.1 100.b.3 I

(v) change in status, evidence, excessive 37.b.2 l

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acceptable, discrepancy f

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(x) in accordance with approved proceoures, established criteria, code requirements

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(2)

Phase Ill Tests i

(a) design

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22.b.1 27.b.1 31.b.2 31.b.3

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(b) in accordance with those specified, within the limits specified 3.b.1 12.b.1 l

(c) satisfactory 2.b (d) no major deviation 8.b.1 1

(e) consistent i

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.g.

640.8 Our review of your test program description and your response (14.2.12) to item 423.22 disclosed that the enerability of several of the systems and components listed in Regulatory Guide 1.68

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(Revision ]) Appendix A may not be demonstrated by your initial test program.

Expand your test description to address the

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followiag items :

1 (1)

Precoerational Testina 1.a (2)(i) - Expand the preoperational test phase such

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that the safety valves of the reactor coolant i

system are tested at temperature.

1.e(5), (10) - Expand the preoperational test pnase such 4

that the steam extraction system and feeowater heater and orain systems are tested.

1.h(10)

- Verify that containment recirculation fan

]

motor current is within its design value at conditions representative of accident condi-tions.

Address such issues as air density,

. temperature, humidity, fan spe'ed, and blade i

angle.

4 1.j(17)

- Expand Phase 11 test number 65, Main Feedwater System, to include testing of feeowater heater temperature and level control systems.

1.j(22)

- Expand the preoperation test phase such that the following instrumentation used to track the course of postulated accidents i

is tested:

4 a) containment wide range pressure indicators i

b) containment sump level monitors c) humidity monilors 1

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10-1 1.k(4) - Modify the aopropriate test abst-acts to ensure r

that testing in accordance with Regulatory Guide l

1.52, position C.S.-a, is accomplished (in-place ll DOP (dicctyi phthalate) tests).

(4)

Low P6wer Testina

4. k -

Modify Phase 11 test number 58, Feedpump Turbine

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(FPT) and FPT Gland Steam Test, such that testing of the main feedwater pump is included.

4.t -

(See 423.56)

I

l (5)

Power Ascension Tests

5. o.-

Include an abstract of the leak integrity test which will be performed as standard operating procedure every time the reactor head is removed.

5.w -

Provide a preoperational test description to test containment penetration coolers.

On these penetrations where coolers are not used, provide a startup test description that will demonstrate that concrete temperatures surrounding hot pene-t trations do not exceed design limits.

5.kk -

Revise Phase II test number 32, Feedwater Tem-

I perature Reduction Test, such that the' testing occurs at both 50% and 90% power levels.

5.mm -

Either provide technical justification for per-i forming the MSIV closure test at 15% power and

^

demonstrate how the results of this test can be extracolated to show proper plant response at full power, perform this test at a higher power level where such a justification or extrac-Olation can be made, or perform this test at full power.

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640.9-In addition to committing to cond'ucting those tests not yet

'(14.2.12.3) submitted for review at the appro'priate power levels, some

~i of the test abstracts you have.provided need ccmmitments to be conducted at various power levels.

Alter your test abstracts toincludetestingatthefollowing,powerlevels:

(1)

Control rod withdrawal and insert speeds ano sequences, interlocks and scram timing:

(a)

Following fuel load

!o!

(b)

< 5%

lj (c) 25%

h.

(2)

Pseudo rod ejection test:

(a) < 5%

(b)

>10%

1 (3)

Neutron and gamma radiation surveys:

(a)

<5%

(b) 50%

l.

(c) 100%

(4)

Process and effluent radiation monitors:

.i (a) <5%

(b)

>25%

(5) Main steam and branch steam isolation valves:

)

(a) <5%

j-(b) 25%

f (c) 50%

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(6)

Dynamic response to load swings:

3 l:

(a) 25%

l II (b) 50%

(c) 75%

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(d ',

100%

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8

a 640.10 Verify that sources of water used for long-term core cooling i

(14.2.12) are tested to demonstrate adequate flPSH (net positive suction head) and the absence of vortexing over range of basin level

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from maximum to the minimum calculateo 30 days following LOCA.

640.11 Our review of licensee event reports has disclosed that many (14.2) events have occurred because of dirt, condensec moisture, or other foreign objects inside instruments and electrical

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components (e.g., relays, switches, breakers).

Describe any

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tests or inspections that will be performed or any adminis-j trative controls that will be implemented during your initial test program to prevent component failures such as these at your facility.

640.12 Review of licensee event reports disclosed that a number of (14.2.12) sensing lines'were rendered inoperable'due^to being frozen and/.or blocked with crud, dirt, and entraoped gas.

Provide a description of the inspections or stests that will be per-formed to ensure that the sensingt lines are clear prior to j

utilization.

640.13 Review of lic~ensee event reports disclosed that some instrumen-(14.2.12) tation drift problems are due, in part, to extremes of local temperature and humidity.

Provide a description of the inspec-ions or tests that will be performed to minimize setpoint drift due to local temperature and humidity extremes.

}

640.14 We could not conclude from our review of the preoperationai

(

.2.12.2) test phase description (Phase II tests) and the responses 3

to item 423.23 that comprehensive testing is scheduled for i

several systems and components.

Therefore, clarify or expand the description of the preoperational test phase to address the following-(1)

The response to item 423.23'(f) is inadecuate.

Modify your test descriptions to ensure that incividual cell limits are not exceeded during the design discharge test and to demonstrate that the DC loads will function as necessary to assure plant safety at c battery terminal voltage equal to the acceptance criterion that has been es*.ablished for minimum cattery terminal voltage for the discharge load test.

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(2)

The response to item 423.23 (k) is inadequate.

Modify Phase Il test number 31, Containment HVAC Insolation VaTve Critical Subsystem Test, such that all auxiliary feedwater pumps are in operation to assure that design heat loads are produced in the AFW pump areas.

Note -

this can be done in conjunction with the Hot Functional Test (Phase II test number 98) test methods 9 and 16.

I a

(3)

Recently the Westinghouse Water Reactor Division's Safety 1

(i Review C)mmittee identified a potential control and protection system interaction concern involving Volume Control Tank (VCT) level instrument'ation.

The concern involves failure of the VCT level control system result-ing in a-loss of suction to the c'harging pumps.

Modify Phase II test number 80, Chemical and Volume Control System (CVCS) Test, to verify that adequte procedures, j

testing, operator training, design changes, and/or cir-4j cuitry modifications are being conducted prior to fuel

{

loa ~ ding to address this potential safety system-failure.

(4)

Modify Phase II test number 85, Auxiliary Feedwater (AFW)

System, to address the following:

g (a)

Include testing to ensure that a loss of auxiliary feedwater (AFW) flow will not occur due,to pump runout and subsequent tripping of the AFW pump motors.

j (b)

Our review of licensee event reports has disclosed

]

several instances of emergency feedwatsr pumo 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 oump startup and to demonstrate the reliabil-l ity of your emergency cooling system, state your plans to demonstrate at least five consecutive, successful, cold, quick pump starts during your initial test program.

i

o I

^

(5)

The response to item 423.23 (kk) is inadequate.

Include in Phase Il test number 86,. Fuel-Handling Eauipment Test, the polar crane and cask handling crane.

Furthermore, specify the levels of the static (125% rated load) and dynamic (100% rated load) tests.

(6)

The response to item 423.23 (mm) is inadeouate.

Include l

testing of the compartment watertight doors in Phase II test number 88, Essential Cooling Water System (ECWS)

Test.

4" (7)

Expand the Reactor Coolant System (RCS) Hot Functional Preoperational Test Summary (Phase II test number 98) or other tests to adoress the following:

(a)

Modi.fy test method 8 to reference the pre and post-hot functional examinations presented in Subsection 3.9.2.4.

(b) Modify test method 23 or provide an additional l

Phase II test abstract that demonstrates conformance

'i.

1 with Regulatory Guide 1.68.2, position C.4 -(Cold d

Shutdown Demonstration Procedure).

)

640.15 The response to item 423.27 is inadequate.

Expand Phase II

~i (14.2.12.2) test number 2, Unit Startup Transformer test to include test-1 ing of the automatic transfer feature as stated in the response to item 423.27.

640.16 Your response to item 423.29 is not totally acceptable.

Describe (14.2.12) the manufacturer's tests in sufficient detail or provide a test abstract to demonstrate that the capacity of each valve l

is within the minimum and maximum values assumed in the accident analysis.

640.17 The response to item 423.31 is inadequate.

Provide assurance (14.2.12.2) that any preoperational tests unintentionally not completed prior to fuel load will be completec and that rescheduling information (cite power level at whicn test will ce performed) will acccmoany the technical justification submitted to the NRC.

J 3

}

640.18 The response to item 423.32 is not adequate.

Provide a (14.2.12) table which lists all Phase III tests and indicates the power level and/or defined test condition (plateau) at which each

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test will,be conducted.

l 640.19 We could not conclude from our review of the startup test (14.2.12) phase description (Phase III tests) and the responses to item 423.33 that. comprehensive testing is scheduled for

~

several systems and components.

Therefore, clarify or expand the description of the preoperational test phase to i

address the following:

(1)

The response to item 423.33 (b) is inadequate.

Include i

the testing of the bank insertion monitor in the Rod Position Indicator Test (Phase III test number 2).

(2)

Expand your Rod Control System Alignment Tests (Phase III test number 3) to specifically include demonstrating the operability of sequences a.1d inhioit or block func-tions.

(3)

The response to item 423.33 (d) is inadequate.

Modify h

method 4 of the Rod Drop Time Measurement Test (Phase III test number 5) to satisfy Regulatory Guide 1.68 f

(Appendix A, 2.b) retesting criteria:

for each test condition, those control rods whose scram times exceed the two-sigma limit of the scram time data for all con-i trol rods :hecid be retested a minimum of three times A

to ensure prcper performance during plant eneration.

.- (4 ) The Reactor Coolant System Flow Test (Phase III test

]

number 6) is inadequate.

Expand your acceptance criteria 1

to include acceptable core and major component differ-ential pressure and acceptable reactor internal and component vibration levels.

)

(5)

Expand the Plant Response to Loao Charges Test (Phase l

III test number 20) as follows:

?

1 (a)

The response to item 423.33 (k) is inadecuate.

Modify the acceptance criteria such that acceptacle l

7 overshoot, undersnoot, or oscillati:n are icentified.

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3 (b)

Verify that the step load changes shown in the plant response to load change,s test are the plant design ioad swings, or demonstrate how load swings of less than design value can validate plant cesign.

The plant dynamic response to load swings should also include ramp load changes.

This test must l

also be conducted at 50 percent power level.

~

(6)

The Evaluations of Core Performance Test (Phase III test 4

I number 22) lacks sufficient content.

Commit to sufficient

)

measurements to establish that the following parameters are in accordance with design values:

1 (a)

Flux distributions (b) local surface heat flux (c)

Linear heat rate (d)

Departure from nucleate boiling ratio (e)

Ratial and axial power peaking factors (f)

Quadrant powe'r tilt 640.20 The response to item 423.34 is inadequate.

Commit 'to testing-4 (14.2.12) any future design features incorporated into the plant design which prevent or mitigate anticipated transients without scram (ATWS).

I The preceding twenty questions reference the following regulatory guides:

1 1.52 Design, Testing,and Maintenance Criteria for Post Li Accident Engineered-Safety-Feature Atmosphere l

Cleanup System Air Filtration and Absorption i

Units of Light-Water-Cooled Nuclear Power Plants 1

1.68 Initial Test Proarams for Water-Cooied Nuclear

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Power Plants 1.68.2 Initial Startup Test Program to Demonstrate Remote Shutdown Cacability for Water-Cooled Nuclear Power Plants 1.108 Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants 1.139 Guidance for Residual Heat Removal l

1.140 Design, Testinc, and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants l;

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-17 640.21 By letter dated August 17, 1981, you stated your intent to comply with the TMI-2 Action Plan Item I.G.1 testing requirements by referencing the results of testing completed at " comparable plants".

You also indicated you intend to comply with the training requirements by use of your simulator.

1 Comparisons of South Texas Project Units 1 and 2 with other plants reveal design differences in electrical distribution systems, circulating water systems, HVAC systems, and possibly other support systems.

Therefore, it is considered unlikely that any other plant is comparable with South Texas Project Units 1 and 2.

However, if you can provide adequate 3

verification that the results of natural circulation tests performed at another plant are valid for South Texas, we will accept l

your position.

In particular, we are interested i

in the results of testing that verified the ability to feed and steam the steam t

generators in the event of Loss of All A/C Power.

Your response should discuss all aspects of each of the testing items of our June 12, i

1981 letter.

NOTE:

An acceptable response to this concern j

is contained in a letter from E. P. Rahe s

I (Westinghouse) to H. R. Denton dated P

July 8, 1981 (NS-EPR-2465).

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With respect to the " training" objectives, being

!-l accomplished by the use of a simulator, you l

should verify that your -simulator training program includes the natural circulation operations noted in our June 12, 1981 letter.

Furthermore, it should be demonstrated that I

the simulator to be used for natural circulation q

training tracks real plant behavior by comparing the simulator responses with test data from a plant which has perforined the tests.

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