ML20132F195

Forwards Responses to 12 FSAR-related Questions Re Initial Test Program & Remote Shutdown Capability,Posed During 841219 Meeting W/Reviewers

ML20132F195
Person / Time
Site:	Beaver Valley
Issue date:	07/29/1985
From:	Carey J DUQUESNE LIGHT CO.
To:	Knighton G Office of Nuclear Reactor Regulation
References
TASK-1.G.1, TASK-TM 2NRC-5-110, NUDOCS 8508020205
Download: ML20132F195 (28)

Text

_

O

'Af (4s 78 st41 Nuclear Construction Division Telecopy 6 Robinsor. Plaza Building 2. Suite 210 Pittsburgh PA 15205 July 29, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. George W. Knighton, Chief Licensing Branch 3 Of fice of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Initial Test Program / Question Response Gentlemen:

Attached are the Duquesne Light Company (DLC) responses to 12 ques-tions posed during a meeting with the reviewers on December 19, 1984. These questions provide a more precise definition of remaining concerns resulting from NRC evaluation of the original responses provided by DLC in February, April, and July, 1984.

DUQUESNE LI HT COMPANY 1

By 34Q. Careff Vice President GLB/wjs Attachment cc: Mr. B. K. Singh, Project Manager (w/a)

Mr. G. Walton, NRC Resident Inspector (w/a)

SUBSCRIBED AND S40RN TO BEFORE ME Tills c796/ DAY OF df1 , 1985.

OxUL /I' bh Notary Public l

ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20,1986 8508020205 850729 hDR ADOCK O 2 y l ,

i

I United States Nuclear Regulatory Consnission

! Mr. George W. Knighton, Chief Initial. Test Program / Question Response t

Page 2 1

i, COMMONWEALTH OF PENNSYLVANIA )

j ) SS:

COUNTY OF ALLEGHENY )

l 1

2 On this 4 9e/ day of 7

Mc;- , jffS , before me, a 1 Notary Public in and for said Commonwealth and County, personally appeared 1

j J. J. Carey, who being duly sworn, deposed and said that (1) he is Vice f

Pres ide nt of Duquesne Light, (2) he is duly authorized to execute and file

! the fo regoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.

I

% ) bv

', Notary Public

ANITA ELAINE REITER, NOTARY PUGLIC' ROBINSON TOWNSHIP, ALLEGHENY COUNTY i MY COMMISSION EXPIRES OCTOBER 20,1986 i

-[

f i

l h

l i

l l '

I  !

i i

i ,

i l

l 1

Question 640.9 FSAR Subsection 14 .2 .12.6 .4 (Shutdown from Outside the Control Room and Verification of the Potential for Cold Shutdown) should include test initiation with the turbine generator in operation, or further technical justifica-tion should be provided for not performing this test in accordance with R.G. 1.68.2, initial Startup Test Program to Demonstrate Remote Shutdown Capability fo r Water Cooled Nuclear Power Plants.

Response: Refer to revised position of Regulatory Guide 1.68.2 in FSAR Table 1.8-1. During the test, the only action necessary with regard to the turbine is the reactor trip which is initiated at the switch-gear and results in a turbine trip signal. Under actual condi-tions, the trip would occur prior to evacuating the control room and no further actions regarding the turbine are necessary. There-fore, the purposes specified in the Regulatory Guide (demonstra-tion of design, procedures, procedural familiarity and suf ficient numbers of personnel) are in no way dependent on actual operation of the turbine.

1 1

1 I

Question 640.14 FSAR Subs ect ion 14.2.12 test abstracts should include specific sources of acceptance criteria.

Response: Section 50.34 of 10CFR Part 50 requires, in part , that the appli-cant include " plans fo r preoperational testing and initial opera-tions" in the FSAR. Chapter 14 of Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," prov ides a method acceptable to the NRC staf f pertaining to initial test programs to be included in the FSAR for the NRC to perform its safety evaluations for operating licenses. As stated in our February 1984 response to this question, FSAR Subsect ion 14.2.12 is in full compliance with Regulatory Guide 1.70 which requests only a summary of acceptance criteria. Test descriptions provide " traceability" to the following acceptance criteria sources: control logic, design specifications, technical speci.fi-cations, and core design predictions.

The only requirement in the SRP acceptance criteria related to FSAR content is 10CFR50.34 discussed earlier. The SRP cites additional guidance (Regulatory Guide 1.68) which describes a basis acceptable to the NRC staff that may be used to implement 10CFR50.34 and other cited requirements, in regard to info rmat ion to be provided in the FSAR, Regulatory Guide 1.68 gives little guidance, but it does po int out that acceptance criteria wh ich account for uncertainties used in transient and accident analyses should be included as part of each test procedure and approved test procedures fo r satisfying FSAR test commitments should be made available to NRC staf f personnel from the Of fice of Inspec-tion and Enforcement approximately 60 days prior to expected use.

it also points out that these individuals will determine "whether test procedures contain appropriate acceptance criteria." As stated in our February 1984 response, specific acceptance criteria are contained in the detailed test procedures which are available to the NRC as outlined in FSAR 14.2.11.2.

In accordance with procedures which govern preparation of test procedures at BVPS-2, appropriate FSAR information and other sources are considered when developing test procedures and accep-tance criteria. Each acceptance criterion in the procedure normally contains a specific reference to the source of that criterion. Duplicating this type of information in the FSAR is inappropriate and would create unnecessary dif ficulties in making necessary procedure changes during implementation of the test program.

Since: (1) the regulations do not require this anount of detail, (2) the guidance documents that provide an acceptable method fo r satisfying the regulations do not request this info rma t ion , (3) the FSAR and other appropriate sources are considered when developing test procedures and are specifically referenced in the procedures, (4) the approved test procedures which contain the requested information are made available to the NRC, and (5) inclusion in the FSAR will result in unnecessary dif ficulties during test program implementation, DLC concludes that no addi-tional safety would result from revising the FSAR and that it would be unwise to do so.

Question 640.16 FSAR Table 1.10-1 should be revised to provide speci fic reference to whe re the tes t ing and training requirements of NUREG-0737, Item 1.G.1, are addressed.

Res po nse : As previously stated , the training object ives required by NUREG-0737, Item 1.G.1 (see FSAR Table 1.10-1) will be satisfied and operator training will be provided on a simulator which alequately represents BVPS-2 performance with regard to natural circulation.

Test data which could be used to update existing simulator train-ing will be obtained using the approved guidelines of the revised Westinghouse Low Power Test Program (W NS-EPR-2465 dated July 8, 1981) as indicated below:

1. During Hot Funct ional Testing with the Reactor Coolant Pumps supplying heat input to the secondary side, a loss of AC power will be simulated to the Auxiliary Feed pumps, controls and area ventilation. This will demonstrate that the plant can be stabalized utilizing manual control and the steau driven Auxiliary Feedwater Pump. Info rmat ional data will be take n for simulator update as necessary, with no acceptance criteria applied.

2. The existing Initial Startup Test, (Section 14.2.12.8.13),

" Pressurizer Heater and Spray Capability" test will be revised to include a section with one RCP in operation (not to be in loops with Pressurizer surge line or spray line). Pressure will be reduced by turning of f Pressurizer heaters and not ing depressurization rate. The heaters will then be re-established and pressure further reduced by use of auxiliary spray. The ef fects of changes in charging flow and steam flow on margin to saturation temperature will be observed. Test data will be recorded and will be available for simulator update as neces-sary, with no acceptar,:e criteria applied.

3. BVPS-2 does not plan to conduct this Natural Circulation 11st since results of testing previously performed at North Anna-2 are suf ficient to demo ns trat e the alequacy of BVPS-2 design features related to natural circulation. BVPS-1 has ex pe r i-enced loss of AC powe r and has satisfactorly demons trat ed Natural Circulation during this transient.

4. The existing Initial Startup Test (Sect ion 14 .2 .12 .6 .5 ),

" Verification of Plant Pe rfo rmance Following Turbine Trip Coincident with Loss of Of fsite Power at Load" is satisfactory for obtaining the necessary plant cond it ions . Us ing this test, the plant will be brought to stable condit ions using batteries and emergency diesels.

5. Previously addressed; see FSAR Table 1.10-1, item 1.G.I.

r Question 640.18 FSAR Subsect ion 14.2.12 test abstracts should be modified to demonstrate that capacities of pressurizer PORVs and main steam line atmospheric dump valves are consistent with the accident analysis assumptions for both minimum and maximum valve capacitles.

Res ponse: In regard to the pressurizer PORVs, Table 5.4-20 of the FSAR describes a capacity of 210,000 lb/hr. The accident analysis assumed a flow at least equal to the safety valve maximum capacity (345,000 lb/hr. from Table 5.4-20) . Therefore, since the accident analysis assumes a flow which is roughly 164% of the PORV capae-ity, suf ficient margin exists to preclude the need for a test.

In regard to the atmospheric steam dump valves (steam generator PORVs), FSAR 15.1.4 indicates a flow of 225 lb/sec. at 1,000 PSIA (810,000 lb/hr.) was assumed in the accident analysis. Using the 26,200 lb/hr. at 10 0 PSIA minimum flow rate speci fied in FSAR 10.3.2 which was used to size these valves, it has been calculated that expected it,ow at 1,000 PSIA is roughly 270,000 lb/hr. Since this is only L/3 of the flow assumed in the accident analysis, m.f ficient margin exists to preclude the need for a test.

Question 640.19 Discrepancies exist between the classification of certain test abstracts in FSAR Subsection 14.2.12 and FSAR Figure 14.2-3. The following test abstracts should be classified as stated:

Test i Section Number Description Type i

14.2.12.16.2 Reactor Coolant System Sampling for Core Load IST 14.2.12.17.1 Turbine Plant Sampling System SOV 14.2.12.31.2 Plant Operation Following Loss of FW Heater IST 14.2.12.54.1 Normal AC Power Distribution System SOV 14.2.12.63.1 Engineered Safety Features Equipment HVAC IST 14.2.12.68.1 Auxiliary and Waste Handling Build-ing HVAC SOV 14.2.12.69.2 Miscellaneous Secondary Plant HVAC Systma SOV 14.2.12.70.1 Cond4nsate Polishing Building HVAC Systems SOV Response: The above inconsistencies were corrected in FSAR Amendment 9.

i l

.- . _ . . _ - . _ _ _ . =.

1 Question 640.20 FSAR Subsect ion 14.2.12 test abstracts should be modified to ensure that the accumulator isolation valves can open under the maximum differential pressure cond it ions of zero RCS pressure and maximum expected accumulator pre-charge pressure or technical justification to R.G. 1.79, j "Preoperational Testing of Emergency Core Cooling System for Pressurized Water Reactors," should be provided in FSAR Table L.8-1.

Response: R.G. 1.79 clearly states the purpose fo r the subject test to be "to insure that inadve rt ant valve closures do not prevent opera-tion of the core flooding system if required." The February,

! 1984, res pons e to this question explains that administrative con-

]' trols and technical specificat ion requirements provide assurance that accumulator isolation valves will never be required to changu

! position in pe r fo rmance of a safety function. These controls include power removal upon opening the valve. Alarms which reflash at regular intervals are provided to alert the operator when, a i valve is not fully open. Technical specifications require pe riodic verification of valve pos it ion , pe riodic verification of powe r

! removal, and plant shutdown if any valve is not opened.

Therefore, the "inadve rt ant valve closures" which are the source of concern for this test are eliminated unless multiple failures are postulated. These failures would include combinations of the following:

)

! l. Failuru to open the valve pe r technical specifications and e operating procedures.

2. Failure of the power removal circuit or failure to remove j valve power once the valve is open.

l

! 3. Failure of one or more operators to heed the alarm indicat ing a valve which is not fully open or failure of the alarm, i

4. Failure of one or more operators to heed reflash of the alarm, i 5. Incorrect verification of valve position on a periodic basis in violation of technical specifications, j Since combinations of these failures would be required to allow an inadve r t ant accumulator isolation valve closure to occur and not be noticed and corrected, the situation would be highly unlikely, j Protecting or testing for multiple failures is ove r and above standard " single failure" philosophy and is not considered neces-sary. It should be noted that R.G. 1.79 was issued in 1975. This l occurred prior to the initiation of the currently used " power removal techniques" found in the industry today.

I 4

4

~

j.

l 4

I 4 .

l Question 640.23 FSAR Subsection 14 .2 . l2 .6 .5 (Verification of Plant Per-formance Following Turbine Trip Coincident with Loss-of-Offsite Power at Load) should be modified to secure appropriate sections of the Safeguards Area Ventilation i System which are AC powered to simulate loss of AC I conditions during the 2-hour turbine-d r iven auxiliary feedwate r pump test. Also, acceptance criteria (2) should be rewritten as it currently is unclear.

Res pons e

Acceptance criterion 2 of 14.2.12.6.5 will be revised as shown on the attached page, 14.2-46. FSAR Section 14.2.12.32.2 (attached page 14.2-94) will be revised to include the loss of ventilation condition.

i i

f i

1 I

1 l

. I

, O SVPS-2 t.ad b

P

6. The primary domineralized water storage tank makeup water and chemical feed systems will be tested to verify that they will  ?

' functica in accordance with the control logic and design J specifications.

4 Acceptance criteria

)g' g 1. The motor-driven auxiliary feedwater pumps. valves, and the g* primary dermineralised water storage tank makeup water and chemical feed systems function in accordance with the design  !

$ specifications and the control logic.

2. The motor-driven auxiliary feedwater pumpe remain within design q limits, and the pump room ambient conditions do not exceed o(k p$

envirotunental qualification limits for safety-related equipment in the room.

4%[ 14.2.12.32.2 Turbine-Driven Auxiliary Feedwater Pump Test (PC)

% Test objectives

• To verify proper cysratiwn and controls of the turbine-driven auxiliary feedwater pump.

t N Prerequisites b  %~

9k 1. The applicable general prerequisites. as listed in

$u4T {t

• Section 14.2.12.1.1 are met. d*

DW 2. The plant is at normal operating pressure and no load T

{%$ temperature during hot functional testing.

. Test Methods

1. Tfte turbine-driven auxiliary feedwater pump will be tested to verify that the pump functions in accordance with the design (k

9-specifications and the control logic.

g334 % 2. The associated steen inlet valves will be tested to verify the Qg valves function in accordance with the control logic.

jM Q

3. m Tu w d.,um a w ha A 4 4 A eu -r &repW!'enit*W oe dukw/d stM sopf A,tt// be M A NnN o! W W d of htf *f.of 44t

1. 1. Aers:r M/4 &N /4 NOk4b F'o11owing this endurance run. .

the pumps will fSel and eterefe ra /Mst .t%g y;g 4y W"!' **j % w? ream neW/a && m,ege sh lf t down

/

Acceptance Criteria _

1. Pump operating parameters are in accordance with design specifications.

b Amendment 7 14.2-94 .uly 1984

. BVPS-2 FSAR Cf 4.6ti_th the motor-driven auxiliary feedwater pumps s'e M Ihe

' turbine-criven auxiliary feedvater puisp v311 be veriTsad t- old, quick start automatically and operate for at lesw/2 hou ith loss of all offsite power.

Acceptance ' Criteria i

1. The ability of the plant to sustain a turbine trip coincident with loss-of-offsite power at load has been demonstrated, gli

2. The turbine-driven auxiliary feedwater pump automatiegquick ,

starts, and remains within design limits with respect to i

bearing / bearing oil temperatures and vibration. Pump room ambient conditions (temperature, humidity) do not exceed environmental qualification limits for safety-related equipment in the room.

i 14.2.12.6.6 Load Swing Test (IST)

, Test objectives To verify the proper transient response of the plant and the automatic control systems during step and ramp load changes at various plant power levels.

! Prerequisites f 1. Required plant control systems are in the automatic control mode. I l 2. The plant is in operational mode 1 with reactor power level established as required.

1 Test Methods

1. Design step and ramp load changes will be applied at each power level (approximately 30, 75, and 100 percent) during power ascension testing.

2. The primary and secondary plant parameters will be monitored as required to verify the proper response of the plant and its automatic. control systems.

Acceptance Criteria Plant parameters remain within design specifications throughout the application of each load change, and the automatic control systems s

t re-establish stable operation at each new power level. .

l l

Amendment 6 14.2-44 April 1984

Question 640.25 (1) FSAR Question 410.24 does not necessarily address flood-

ing caused by automatic and/or manual Iire protection (water) systems. Provide assurance that adequate drainage is provided to preclude flooding.

(2) FSAR Subsection 14.2.12.50.2 (Wet P ipe and Deluge Sprin-kler System Test) should be modified to verify that nozzles serving indoor facilities are air-flow tested and that these tests overlap the water flow tests.

Response: (1) The analyses described in response to Question 410.24 include spurious actuation of automat ic fire suppression systems.

Spurious actuation of manual systems is not considered cred-ible because of their seismic design. Deliberate actuation o1 l

a manual system would only be in response to a fire, in which case the entire fire area is assumed to be destroyed by the i

fire itself with no adverse impact to plant safety.

(2) The following test method will be added to FSAR Section 14.2.12.50.2:

7. Nozzles serving indoor facilities will be air- flow tested. These tests will overlap the water flow tests.

I i

I_

i i

i i

i f

Question 640.26 (2) FSAR Question 430.11 deals with the Class 1E ac system.

1 Demonstrate that Class IE de loads necessary for safety I shutdown are operable at minimum de voltage.

i I Res ponse: The res pons e to Question 430.11 includes all Class IE loads.

Letter No. 2NRC-4-140 dated September 7, 1984, speci fically identifies a schedule for analysis of de loads.

I I

l I

i t

l e

i I

n i

1 i

i  !

i l

l

Question 640.26 (3) FSAR Subsection 14 .2.12 has yet to be modified to add full load testing of vital bus inverters.

Res pons e: FSAR 14.2.12.56.1 will revised as shown on the attached page

, 14.2-124.

i 6

y 4

'I i

4 1,

o

lh )

[S B! FPS-2 FSAR (9

tk.pt.%.i //04

~3

7. The operation of the 125 V de bus ground detectors will be -

8. j- ( s iw erhrs Wil'Tb k* b%e lld',LMBD, hs u God ev.ittr mrce. /

f Acceetance Criteria

1. Battery ch'rger a and inverter outputs are in accordance with design parameters.

2. Loss of the preferred power supply is detected, and transfer to and from the standby power sources can be accomplished.

3. Each battery has adequate capacity to perform its design duty ,

cycle.

4, Iverite cohd d $1l W is it) occord'ctnce. L0th design porqsM 5, i 14.2.12.56.2 Instrumentation, Anqunciator Circuitry, and >

Emergency Lighting Supply Systems Test (50V)

Test objectives To demonstrate the operation of 125 V de instrumentation, annunciator circuitry, and the emergency lighting supply system.

Prerequisites The applicable general. prerequisites, as listed in Section 14.2.12.1.1, are met. ,

,s C T..t n.sh.u

.. )

1. The emergency lighting supply system will be verified to function in accordance with the control logic and design specifications.

2. Proper operation of alarms panels will be verified.

'3. Each 125 V de switchboard breaker will be operated and the alarm l indication will be verified.

Acceptance Criteria

1. The emergeney lighting supply system functions in accordance with design.spacifications and the control. logic.

2. The . operation of the annunciator circuits is in accordance with design specifications,. based upon 125 V de control system alarms set points.

14.2.12.54.3 Non-Class 1E 125 V' dc Operability Test (50V) ,

Test objective

. To Verify the performance of the non class 1E 125 V de charging systems and the uninterruptible power supply.

Amenhent 9 14.2-124 December 1984 e

! Question 640.27 FSAR Subsection 14.2.12.55.1 (Emergency Diesel Generator

! System Test) should be modified to demonstrate proper i

operation during complete loss of load or technical i just ificat ion should be prov ided fo r exception to R.G.

l 1.103, Periodic Testing of Diesel Generator Units used as Onsite Electric Power Systems at Nuclear Power Plants.

\

l Res ponse: A full load rejection test was performed by the vendor fo r the l BVPS-2 diesel generators. Since the diesel auxiliary support systems used by the vendor do not affect results for this test, there is no need to repeat it during initial testing at BVPS-2.

It should also be noted that the accident analyses never take credit for regaining a diesel generator once it is lost for any reason. Therefore, further consequences to the diesel need not be cons ide red if it is appropriately isolated from other safety-related equipment. .

I I

l

I Question 640.30 (L) Provide technical justification as to why FSAR Subsection 14.2.12.8.11 (Reactor Vessel Internals Ins pect ion) has been deleted. This test is used to prov ide conformance with R.G. l.20, Comprehens ive Vibration Assessment Pro-gram, as stated in FSAR Table 1. 8- l and FSAR Subsection 3.9N.2.4 (l.a.3, 4.s, 5.p).

Response: FSAR 14.2.L2.8.11 was erroneously deleted and will be replaced in the FSAR. This inspection is performed as part of a contractually required vendor inspection program and is not categorized as a preoperational test.

t 4

Quest ion 640.30 (2) FSAR Subsect ion 14.2.12 test abstracts should be modified 4

to address le ak detection systems located out s ide of containment (1.j.7).

Res ponse: The res ponse to Question 640.30, Amendment 7, will be revised as shown on the at t ached pages, Q640.30-3 and Q640.30-3A. These systems are covered by the calibration program rather than the test program.

1 I

t i

f I

i i

i

BVPS-2 FSAR lC84 g (frC 30 'y The instrumentation described con-3 (7) and sists of various sump level indi-1.j (20) '

Jcators,includingindicatorsin g/

radioactive sumps for safety-

' D 1- d related equipment areas outside \

' containment. These level indi- /\

U cators are checked for agreement with actual level in section

, b ' g,y -3 A) k14.2.12.10.2.

1 3 (22) Q e containment wide-range pres- .

sure indicators are tested t (Section 14.2.12.14.1.) {

' /

The reactor water level monitors are checked to be in agreement $

g/ /

with level glass indications while ' s i

filling the reactor in Section Y g 14.2.12.10.2.

I High range radiation detectors f are tested in Section 14.2.12.61.1.

The containment humidity monitors (N'aw.so-1$ are noresafety related and are tested in Section 14.2.12.13.1.

Containment sump level indicators re checked in Section 14.2.12.10.2.y Post-accident monitoring instru-mentation are verified in the system test to which the instru-ment belongs.

1.n.12 See revised Section 14.2.12.9.3, Amenck. tent 7.

4.1 See revised Section 14.2.12.3.5, Amenhent 7. ,

5.o RC5 leak rate test is performed during hot functional testing with the reactor at temperature and pressure (Section 14.2.12.8.12),

i Leak detection instrumentation is l

previously verified in various tests (see 1.j.5).

5.s Verification of proper calibration of the hotwell level control valves is done prior to fuel load in Q640.30-3 July 1984 Amenchnent 7 ,

.wp QV

% 2 r9 QlOBR)

W.xo,49 auni -

M i azt m zz 5 Wu<x 1J. y% iuGa A m AxA .ua t;i;,g< 2L La. t

..<t.csu4 M '

fdL p p $rnG+.f a.ad ,.g.<1 6Le

,u4f

1. ^ l.'*' & + 4 eL A<-

( m ,

. siz<.a aes - m p u jajieas,;

ghp Ascd. a. ~ku,&a'M swsCYem- nfu M .x.c. 4 ,s+ c . Lee p m:Ed- .s <-.fw Ag a.a. spktp ex, -

aya . a4. # Amu. aaa .a N a n.a W.. smt ' su.Jax 2.sGA a. d 4 w ty.a ,.ta.. /0,3.

Ac e /'45'bs m aeo

% .ma-c u 44 - n kia.se.

a a. Cuoffdw M $ta . /4. t .

)%.Asae& emeg M A~ f ,tt.u.4. M

-+u ~. kl mn s a u,u . u.4 a s ea/L .zi cec

.be 1" lmbesLba.a;t Aaw 2Et.<, ?s .,ed4Gs.u M a.a J

.d.u A w / f As D%eco f

f W'~ fA<,/s./OS SLG-cK ,,& g,i

.d-tc

/ . 2.t.1.ca/. / . A

% .4hh.xO $ou.esz xc.a.us lM su,s.,ch. Q . a

a. ,. w k

. m p n- y c,, J u krms.

it a. ia . '7 3. /\

i i

I g ,Q 64o.30 m

-3 A

Question 640.30 (3) FS AR Subsection 14.2.12.14.1 (Containment Leakage Monitoring System) should specify which atmospheric parameters are monitored (1.j.22).

Response: FSAR Section 14.2.12.14.1 will be revised as shown on the attached page 14.2-70a.

J k

+U qJ'g -

BUPS-3 FSAR . - ~

lbN -

Test Methods

1. The vacuum pumps and associated valves will be tested to verify that the equipment functions in accordance with the control logic and design specifications.

2. The containment air ejector will be verified that it can establish a vacuum in containment in accordance with design specifications.

Acceptance Criteria The CVS is capable of establishing and maintaining a reduced pressure in accordance with design specifications.

14.2.12.14 containment Leakage Monitor System

/

/ 14.2.12.14.1 Containment Leakage Monitoring System Test (PO)

Test objectives l To verify the capability of the containment leakage monitoring y u' instruments to measure containment atmospheric parameters during normal operation.

Prerequisites

} 1. The applicable general prerequisites, as listed in

% Section 14.2.12.1.1 are met.

\

~~

[2. Temporary instrumentation installed for Type A testing T j available.

. t N Test Methods

(

{ W.; Q The operation of systeeg

'" W instruments used ermeasure vu r -z

[s g c... A. 6. 6 aunospneric p i _--_ 4during both normal operation and periodic containment integrated leak rate testing will b4

.; verified.

< /

2. A containment resistance temperature detector (RTD) location and

• L accuracy will be verified using temocrarv instrumentation. j '

Acceptance criteria The operation of the containment leakage monitoring instruments is in accordance with design specifications.

Amendment 9 14.2-70a December 1984

--~- . - - . , , , - . - - - - , - - - , - ,- - - - - - - . - - , . . , - - . - - - - -

- . , , . . , , - - --,,.,.._,n-- - -

Question 640.30 (4) FSAR Subsection 14.2.12.13.1 (Containment Vacuum System Test) or other appropriate test abstract should include testing of containment humidity monitors (1.j.22).

Res ponse: FSAR Section 14 .2 .12.7.3 will be revised as shown on the attached page 14.2-50.

i 4

i N

4

..si>

%?

• {

p' SVPS-2 FSAR

'b v

/064 3.* Loss of power will be initiated to activate the battery backup feature of computer memory. 1 i

l Acceptance Criteria

1. Diagnostic tests fbr individual computer equipment operate in ,

accordance with design specifications.

2. Automatic failover will not cause loss of computer functions. l

3. Loss of power will cause no main memory loss for period of time l '

specified in design specifications.

V 14.2.12.7.3 Verification of Performance Calculation (50V)

Test objectives To verify that the computer generated performance calculations and -

nuclear steam supply system (N555) and balance of plant (BOP) a programs are accurate at various power levels.

Prerequisites The plant is in operational mode 1 with reactor power level established as required.

Test Methods

1. Computer input signals from process sensors will be verified correct at various power levels.

2. It will be verified that the computer will correctly perform and report computer calculations to ,obtain plant operating characteristics from the primary and secondary plants. The ,

1',

accuracy of, plant operating characteristics will be verified. Car,me Ttts be un f tk inded.t:. Centatted hwiA aM hew'tratu H M M h. r t . )\

/,

Acceptance Criteria The plant operating characteristics calculated by the computer are accurate and in accordance with design specifications and tolerances.

14.2.12.8 Reactor Coolant System 14.2.12.8.1 Cold Hydrostatic Test of The Reactor Coolant System (70)

Test objectives To verify the mechanical integrity and leak tightness of the reactor l coolant system (RCS). ,

Prerequisites l

l I

14.2-50 )

i

Question 640.30 (5) FSAR Subsection 14.2 .12 test abstracts should include testing of conde nse r hotwell level control system at power or technical justification should be taken to R.G.

l.68 (5.s).

Res pons e: R.G. 1.68 applies to BWRs as well as PWRs. The condenser hotwell level control system at BVPS-2 serves no safety related function, is not power dependent , and is clearly not governed by the regula-tory bases cited in R.G. 1.68 (10CFR50 append ices A and B).

Testing performed on this system will be reasonable and prudent as determined by DLC, but is not appropriate for discussion in the FSAR.

r Question 640.30 (6) FSAR Figure 14.2-3 should be modified to identify testing of gaseous and liquid radwaste systems at power (5.c.c).

Res pons e: The respose to Question 640.30, Amendment 7, will be revised as shown on the attached page Q640.30-4. Since the pe r fo rmance of these systems is independent of plant power level, testing can be accomplished at any time.

• l c.<

b BVPS-8 FSAR -

,'/0M u

Section 14.2.12.27.1.

5.v See Section 14.2.12.33.1.

5.c.c Verification of operation and design of liquid and gaseous rad-waste systems is performed in Sections 14.2.12.21.1 and 14.2.12.23.1p nequired suur.iny . i. ,4 er is also performed in the ,

5.g.g BVPS-2 has no ATW5 modifications.

5.i.i Reactor coolant pump trip tran-sients are tested in Section 14.2.12.8.16 in hot stan& y mode.

Flow transients and control rod response will be measured and compared to Section 15.3. Greater than .30 percent reactor power is simulated to ensure proper plant response (i.e. reactor trip) to RCF trips.

n .

M MO -

A M M aa y V

.cu- M G<24 p k % f

,lud. %. .auaxL y Q LLL.-

Oxai M W M *  %*

A4l*'

• Amendment 7 Q640.30-4 July 1984

Question 640.31 FSAR Subsect ion 14 .2 . 1.2 states that System Operability  ;

Verification (SOV) tests are pe r fo rmed as part of the Preoperational Test Phase. However, the following SOV tests are to be accomplished partially or completely during the initial Startup Tests, or FSAR Subsections 14.2. L 2 and 14.2.1.3 should be rewritten to clarify the use of SOV tests during both the Preoperational and initial Startup Test phases.

Section Number Description 14.2.12.7.3 Verification of Performance Calculation 14.2.12.17.1 Turbine Plant Sampling System 14.2.12.28.2 Condensate Polishing System capability 14.2.12.30.L Feedwater Heater Drain System Test 14.2.12.33.l Automatic S.G. Level Control Test 14.2.12.36.2 Turbine Overspeed Trip Test 14.2.12.38.1 Moisture Separation and Reheat Control System 14.2.12.39.1 Turbine Stretch Test 14.2.12.44.2 Cooling Tower Performance Test 14.2.12.57.L Plant Communications Test 14.2.12.63.2 Fuel, Decontamination Building and Pipe Tunnel HVAC 14.2.12.71.1 Loose Parts Monitoring System Test Res pons e: Sect ion 14.2.1.2 , " Pre-operational Test Phase," will be revised to include the following:

" Selected non-safety-related systems, structures and compo-nents are determined to be operational through the performance of System Operability Verification (SOV) Tests, in general, it is expected that the majority of testing identified during this phase will be completed before fuel loading. However, in some cases, it will be necessary to defer certain Pre-opera-tional and System Operability Verification Testing until af ter fuel loading. In such cases, sufficient testing will be pe r-fo rmed prior to fuel loading to provide reasonable assurance that the post loading tests will be successful."

. Section 14.2.1.3 requires no changes.

L