ML20081G798

Affidavit of Jt Merritt Re Hot Functional Testing Program. Testing Will Be Performed,Contrary to Citizens Assoc for Sound Energy Assertion.Certificate of Svc Encl

ML20081G798
Person / Time
Site:	Comanche Peak
Issue date:	11/03/1983
From:	Merritt J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20081G781	List: ML20081G777 ML20081G798
References
NUDOCS 8311070188
Download: ML20081G798 (11)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket No. 50-445 TEXAS UTILITIES GENERATING ) 50-446 COMPANY, et al.

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) ( Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

AFFIDAVIT OF JOHN T. MERRITT, JR.

REGARDING HOT FUNCTIONAL TESTING I, John T. Merritt, Jr., being first duly sworn do depose and state as follows: I am employed by Texas Utilities Se$ vices, Inc. as Assistant Project General Manager for Comanche Peak Steam Electric Station. As such, I am responsible for the conduct of preoperational testing, including Hot Functional Testing ("HFT")

at Comanche Peak. A statement of my educational and professional qualifications was admitted into evidence as Applicants' Exhibit

17. This affidavit describes the Hot Functional Testing Program i at Comanche Peak, the results of the HFT and the corrective actions taken in response to those results.

Purpose of Hot Functional Testing Hot Functional Testing, which is part of the preoperational testing program, is designed to demonstrate the proper  ;

performance of structures, systems and components during Reactor Coolant System ("RCS") heatup, at normal operating temperature and pressure conditions, and during RCS cooldown, in accordance 8311070188 831103 PDR ADOCK 05000445 0 PDR ,

with design specifications, FSAR commitments and NRC Regulatory Guide 1.68 guidance. To the extent practical, the HFT a3so is designed to verify the correctness of assumptions used for predicting plant responses to anticipated transients and postulated accidents by simulating conditions that would be expected to occur in those situations. (Regulatory Guide 1.68, Revision 2, Part B.) The test was not, however, designed, intended or required to simulate all accident conditions.

The Comanche Peak HFT was conducted over a thirteen week period, from February 24 to May 27, 1983. The initial heatup phase lasted until attainment on March 26, 1983, of hot standby conditions corresponding to normal operatEng temperature and __

pressure (557 degrees F and 2235 psig). The hot standby phase of HFT lasted from March 26 to May 22; a total of 58 days. This phase of the program contained the bulk of the HFT testing, while systems were running under normal operating conditions. In general, the testing during the hot standby phase proceeded in a routine manner, with occasional holds and cooldowns for equipment repairs and retests. However, these cooldown periods were also used to obtain optimal conditions for other tests which could be more effectively performed under those conditions.

The final plant cooldown took place over a five day period.

The cooldown was conducted in two separate evolutions, in order to check out each train of the Residual Heat Removal System and its ability to cool down the plant. The HFT was completed on May 1

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27, 1983. In all, 27 preoperational and acceptance tests were performed, involving 52 plant systems. These tests were not limited to the minimum required testing set forth in the FSAR and Regulatory Guide 1.68, but included the maximum amount of testing that could reasonably be accomplished during the time period allotted for HFT.

Overall, the HFT successfully demonstrated the ability of plant systems to heat up the Reactor Coolant System to its normal operating temperature and pressure, to maintain those steady-state conditions, and to cool the plant down to ambient conditions. The ability of some safety-protection systems (in particular, the Residual Heat Removal and Safety Injection Systems) to perform their safety functions was also demonstrated.

In addition, the Turbine Generator was brought to its rated speed, thus providing an adequate checkout of the mechanical and electrical systems associated with electrical generation. In addition, the HFT provided Operations personnel with valuable training and experience in plant operation. The HFT also enabled operating procedures to be tested under actual conditions, thereby permitting correction and refinement of those procedures.

NRC Review of HFT The NRC has closely monitored the preparation for conduct and analysis of the HFT. All test procedures associated with HFT were cade available to the NRC Staff prior to approval of the  ;

procedures, and copies of approved procedures were provided to l

l the NRC-prior to the actual conduct of the tests. This Staff l

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involvement commenced with the preparation of procedures and training of the HTT test team, five months prior to the HFT. The NRC Senior Resident Inspector for Operations frequently discussed HFT with Startup personnel prior to and during conduct of HFT, providing comments and recommendations throughout the process.

All documentation of the tests has been available for NRC review.

Test Deficiency Correction To document any deficiency discovered during testing or operation of plant equipment, a Test Deficiency Report ("TDR") is employed. This report provides a standard method for reporting, making organizational assignments for corrective action, tracking the status of corrective action and subsequent verification of the adequacy of actions taken by retesting. The status of TDR's is tracked with a TDR log. TDR's are also entered into the Master Data Base to facilitate communication regarding the deficiency with other project organizations for information purposes, as well as assigning responsibility for actions required by the various project organizations. Depending on the nature of the deficiency, either the Engineering or Startup organizations are responsible for determining necessary corrective action.

Once appropriate corrective action is determined, the action is implemented as soon as practical. When retesting is necessary to verify the adequacy of corrective actions, the Startup organization determines the appropriate timing of the retesting.

Retesting of corrective actions cannot be undertaken until the  !

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• necessary system conditions required for the test can be established. In some instances, necessary system conditions for retest will not be attained until after fuel load and during low power or power ascension testing. Conducting retests in this manner is accepted industry practice and the need to conduct such tests is contemplated by Regulatory Guide 1 68. The determination of the appropriate time to co,nduct those retests will be made after an evaluation of each corrective action. That evaluation will be provided to the NRC Staff prior to the retest.

If retesting is to be performed after fuel load, a sequence of startup tests will be devised so that "the safety of the plant is never totally dependent on the performance of untested structures, systems and components." (Regulatory Guide 1.68, l

Revision 2, Part B, p. 1.68-3.) In addition, the test procedures l

l for power ascension will provide for testing of structures, systems and components at the lowest power level practical so that design or construction-related problems identified during those tests can be most readily and safety rectified. Id.

Test Results The deficiencies detected during HFT for Comanche Peak were of a nature that is expected during this type of testing. HFT is intended not only to test certain systems and components, but to establish conditions for additional system / component testing that is not possible under cold conditions. Thus, the HFT is structured to facilitate anticipated subsequent repair and

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] retesting activities. In addition, the HFT testing activities were scheduled to account for retesting, repair and maintenance activities during the HFT, as practical.

To assess the significance of the HFT results, Test 4

Deficiency Reports are evaluated by Engineering for reportability l

l pursuant per 10 C.F.R. $50.55(e). Only one deficiency identified i

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during the HFT has been determined to require reporting under 10 C.F.R. 550.55(e). The deficiency involved an elevated tempera-ture condition in the reactor vessel support and neutron detector l wells, which exceeded acceptance criteria. This deficiency was 4

first discussed with the NRC SRI-Operations in early April, 1983,  ;

l _ shortly after its identification. Upon complete evaluation of 1

) the deficiency, a final written report was submitted to the NRC

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1 by letter dated September 26, 1983. Thus, the NRC Staff is fully apprised of this matter, and will confirm the adequacy of the 1

corrective actions taken. See 10 C.F.R. l50.55 ( e) (4) .

As a result of the analysis of this deficiency, a determination was made to increase the ventilation / cooling i

capacity in these areas by (1) adding flashing to the top of the reactor vessel insulation to redirect air flow to the detector wells, (2) to modify the upper annulus reactor vessel insulation

support ring to provide additional circulation capacity and (3) to add cooling coils in the supply ventilation ducting to reduce air temperature. These corrective measures have already been i completed. Further testing to confirm the adequacy of these i measures will be conducted.

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Specific Test Deficiencies and Conditions certain test deficiencies and conditions discussed in the October 13, 1983, Motion for New Contention filed by the intervenor in the licensing proceeding for Comanche Peak are 3

discussed below. Each of these deficiencies is of the type expected to be detected during HFT, and is being evaluated and dispositioned in accordance with the guidance in Regulatory Guide s 1.68, Revision 2.

Incomplete / missing supports The intervenor discusses in its Motion various items or components which were not installed at the time of HFT. They appear to be concerned particularly with restraints and snubbers that were not in place at the time of the HFT. They represent that these items were required for HFT and thus the HFT results are invalid. In fact, prior to the conduct of the HFT all items f

which were not yet installed were identified and documented on TDR's. This effort includes both supports (with and without snubbers) and restraints ( Motion at 20) . Each of those items was reviewed prior to the HFT to assure that its absence could not affect the validity of the test results, as provided for in Regulatory Guide 1.68, Revision 2, Part C, Section 1. Items not installed at the time of the HFT which require testing will be appropriately tested. The TDR's on these items will not be closed until actual monitoring of the item is performed and the results accepted'by an engineering review.

O, I&E Report 83-36 The intervenor states in its Motion that observations of the NRC Senior Resident Inspector-Operations regarding the status of work activities on the Component Cooling Water ("CCW"), Chemical and Volume Control ("CVCS") and Containment Spray Systems are related to the HFT ( Motion at 12-13) . In fact, none of the observations discussed in that Report related to the HFT, nor will they affect the validity of HFT results. Specifically, observations with respect to the CCW System related to piping modifications to facilitate certification of the containment spray pump coolers and maintenance of the drain pump motors. The observations with respect to the containment spray system related to maintenance and incomplete work on valves. The observations with respect to the CVCS system related to incomplete installation of a new design and incomplete construction of remote valve operators.

System Turnover The intervenor asserts that the turnover of systems to the Operations organization is related to and would restrict pipe support design reviews ( Motion at 19-21) . In fact, the turnover of systems to the Startup organization occurs when practical to permit initial component and equipment testing. Those systems are subsequently turned over to Operations to maintain system l l

operational control by that organization. These turnover i processes proceed independently of the pipe support design verification efforts.

( 3 IfFT on Unit 2 Contrary to the assertions of the intervanor in its Motion (Hotion at 3), Not Functional Testing will be performed for Comanche Peak, Unit 2.

[ihn T. Merri , Jr ."

County of Dallas ) Subscribed and sworn to before me State of Texas ) this 3rd day of November 1983,

.< M .d s . $'A- 1 dotary Public This is a telecopy facsimile. The original will be transmitted under separate cover.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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i TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 and COMPANY, _et _al. ) 50-446 (Comanche Peak Steam Electric ) (Application for .

Station, Units 1 and 2) ) Operating Licenses)  !

i CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants'

Answer to Case's Motions (1) To Add a New Contention and (2) For Discovery" in the above-captioned matter were served upon the following persons by deposit in the United States mail on the 3rd of November, 1983.

Peter B. Bloch, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear, Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

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Mr. Scott W. Stucky Dr. Walter H. Jordan Docketing & Service Branch 881 W. Outer Drive U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom Dean, Division of Engineering Architecture and Technology Stuart A. Treby, Esq.

i Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory Mr. John Collins Commission Regional' Administrator, Washington, D.C. 20555

! Region IV i U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel 611 Ryan Plaza Drive U.S. Nuclear Regulatory suite 1000 Commission Arlington, Texas- 76011 Washington, D.C. 20555.

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I David J. Preister, Esq. Mrs. Juanita Ellis Assistant Attorney General President, CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O. Box 12548 Capitol Station Austin, Texas 78711 Lanny A. Sinkin 114 W. 7th Street Suite 220 Austin, Texas 78701

( r L N ls M William A. Horin W cc: Homer C. Schmidt Spencer C. Relyea, Esq.

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