ML20134B368
| ML20134B368 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 12/19/1996 |
| From: | Joseph Sebrosky NRC (Affiliation Not Assigned) |
| To: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 9701300061 | |
| Download: ML20134B368 (8) | |
Text
.I p.
N Rb T)ct l' t g
UNITED STATES 1
[~
B NUCLEAR REGULATORY COMMISUlON N
E
'f WASHINGTON, D.C. 20066 0 01
~
December 19, 1996
'I Mr. Nicholas J. Liparulo, Nanager Nuclear Safety and Regulatory Analysis i
Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230
SUBJECT:
FOLLOWON QUESTIONS AND DISCUSSION ITEMS ON THE AP600 INITIAL TEST PROGRAM (ITP)
Dear Mr. Liparulo:
As a result of its review of the June 1992 application for design certifica-tion of the AP600, the staff has determined that it needs additional informa-tion.
Specifically, the enclosure to this letter contains a request for additional information and discussion items concerning the AP600 ITP. We propose that the enclosed discussion items serve as agenda items for a currently unscheduled meeting concerning the ITP.
During this meeting the J
staff will determine which of the enclosed discussion items need to be formally addressed by Westinghouse.
i You have requested that portions of the information submitted in the 1
June 1992, application for design certification be exempt from mandatory public disclosure. While the staff has not completed its review of your l
request in accordance with the requirements of 10 CFR 2.790, that portion of I
the submitted information is being withheld from public disclosure pending the staff's final determination.
The staff concludes that these followon ques-tions do not contain those portions of the information for which exemption is sought. However, the staff will withhold this letter from public disclosure for 30 calendar days from the date of thir, letter to allow Westinghouse the opportunity to verify the staff's conclusions.
If, after that time, you do not request that all or portions of the information in the enclosures be withheld from public disclosure in accordance +1th 10 CFR 2.790, this letter will be placed in the Nuclear Regulatory Commission Public Document Room.
O
,\\
l 9701300061 961219 PDR ADOCK 05200003 A
e Mr. Nicholas J. Liparulo December 19, 1996 If you have any questions regarding this matter, you may contact me at (301) 415-1132.
Sincerely, original signed by:
Joseph M. Sebrosky, Project Manager Standardization Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003'
Enclosure:
As stated cc w/ enclosure:
See next page DISTRIBUTION:
Enclosure to be held for 30 days
.* Docket Filec' PDST R/F TTMartin
- PUBLIC DBMatthews TQuay TKenyon DJackson BHuffman 4
JSebrosky WDean, ']-17 G21 ACRS (11)
JMoore, 0-15 B18 EJordan, T-4 D18 JPeralta, 0-9 Al Alevin, 0-8 E23 BGramm, 0-9 Al GHolahan, 0-8 E2 TCollins, 0-8 E23 GThomas, 0-8 E23 i
l t
DOCUMENT NAME: A:ITP SRXB.RAI d'
T2 meelve a copy of this deeunient,iniBsete in the bes: 'C' = Copy wfhout ettechment/ enclosure
'f* = Cop ith ettschment/ enclosure
- N* = No copy 0FFICE PM:PDST:DRPM SC:SRX141)l$A SC:HQMB_:DRCH l C D: POST:DRPM [
NAME JSebrosky:sg./A%
Al~evi&//T \\
BGrammlLO TRQuay 'lW DATE 12/g/96 g/
12//3/95 12/1/,,/96 12/t1/96 0FFICIAL RECORD COPY
\\
Mr. Nicholas J. Liparulo Docket No.52-003 Westinghouse Electric Corporation AP600 cc: Mr. B. A. McIntyre Mr. John C. Butler Advanced Plant Safety & Licensing Advanced Plant Safety & Licensing Westinghouse Electric Corporation Westinghouse Electric Corporation Energy Systems Business Unit Energy Systems Business Unit P.O. Box 355 Box 355 Pittsburgh, PA 15230 Pittsburgn, PA 15230 Mr. M. D. Beaumont -
Mr. S. M. Modro Nuclear and Advanced Technology Division Nuclear Systems Analysis Technologies j
Westinghouse Electric Corporation Lockheed Idaho Technologies Company One Montrose Metro Post Office Box 1625 11921 Rockville Pike Idaho Falls, ID 83415 Suite 350 Rockville, MD 20852 Enclosure to be distributed to the following addressees after the result of the proprietary evaluation is received from Westinghouse:
Mr. Ronald Simard, Director Ms. Lynn Connor Advanced Reactor Programs DOC-Search Associates Nuclear Energy Institute Post Office Box 34 1776 Eye Street, N.W.
Cabin John, MD 20818 Suite 300 Washington, DC 20006-3706 Mr. Robert H. Buchholz GE Nuclear Energy Mr. James E. Quinn, Projects Manager 175 Curtner Avenue, MC-781 LMR and SBWR Programs San Jose, CA 95125 GE Nuclear Energy i
175 Curtner Avenue, M/C 165 Mr. Sterling Franks i
San Jose, CA 95125 U.S. Department of Energy NE-50 Barton Z. Cowan, Esq.
19901 Germantown Road Eckert Seamans Cherin & Mellott Germantown, MD 20874 600 Grant Street 42nd Floor Pittsburgh, PA 15219 Mr. Charles Thompson, Nuclear Engineer i
AP600 Certification I
Mr. Frank A. Ross NE-50 U.S. Department of Energy, NE-42 19901 Germantown Road Office of LWR Safety and Technology Germantown, MD 20874 19901 Germantown Road Germantown, MD 20874 Mr. Ed Rodwell, Manager PWR Design Certification Electric Power Research Institute 3412 Hillview Avenue Palo Alto, CA 94303 J
l f.
1 h
Request for Additional Information and Discussion Items on the AP600 ITP Although the Nuclear Regulatory Commission (NRC) staff does not anticipate finalizing its review of SSAR Chapter 14, Initial Test Program (ITP), before the end of February 1997, there are certain technical issues, related primari-ly to testing of safety-related passive systems, that the staff feels must be addressed by Westinghouse as soon as possible to avoid the possibility of i
schedule conflicts, to identify the potential need of additional interactions as a result of proposed solutions to such issues, and to expedite or enhance the overall review process whenever possible. To this end, the staff has decided to forward to Westinghouse the following request for additional information (RAI) and Discussion Items on the AP600 ITP.
Reauest For Additional Information on the AP600 ITP 260.90 5 52.47(a)(1)(1) requires, in part, that an application for design certification contain the technical information which is required of applicants for construction permits and operating licenses by 10 CFR Part 50 and its appendices.
1 50.34, Appendix A to 10 CFR Part 50, and Section XI, " Test Control," of Appendix B to 10 CFR l
Part 50 reauire that a test program be established to ensure that structures, systems, and components will perform satisfactorily in service.
5 50.34 also requires, in part, that the applicant include plans for preoperational testing and initial operations in the final safety analysis report (FSAR).
Chapter 14 of Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," provides guidance on the information pertaining to initial test programs to be included in both the preliminary safety analysis report (PSAR) and the FSAR for the NRC staff to perform its safety evaluations for construc-tion permits and operating licenses.
Regulatory Guide 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plants" describes the general scope and depth of initial test programs i
acceptable to the NRC staff for light-water-cooled nuclear power l
plants.
Section B, " discussion," of RG 1.68 states, in part, the following:
j (a)
"The primary objectives of a suitable program are (1) to provide additional assurance that the facility has been adequately designed and, to the extent practical, to vali-date the analytical models and to verify the correctness or conservatism of assumptions used for predicting plant re-sponses to anticipated transients and postulated accidents and (2) to provide assurance that construction and installa-tion of equipment in the facility have been accomplished in accordance with design."
l l
)
Enclosure l
1 r
.J
l 1
(b)
"If new, unique, or first-of-a-kind principal design fea-i tures will be used in the facility, the in-plant functional i
testing requirements necessary to verify their performance need to be identified at an early date to permit these test requirements to be appropriately accounted for in the final design."
(c)
"Preoperational testing, as used in this guide, consists of those tests conducted following completion of construction and construction-related inspections and tests, but prior to fuel loading, to demonstrate, to the extent practical, the capability of structures, systems, and components to meet performance requirements to satisfy design criteria."
i (d)
"The initial test program should be designed to demonstrate the performance of structures, systems, components, and 2
design features that will be used during normal operations of the facility and also demonstrate the performance of standby systems and features that must functica to maintain 4
the plant in a safe condition in the event of malfunctions
]
or accidents."
(e)
"To the extent practical, the plant conditions during the j
tests should simulate the actual operating and emergency conditions to which the structure, system, or component may a
be subjected. To the extent practical, the duration of the tests should be sufficient to permit equipment to reach its 4
normal equilibrium conditions. e.g.. temperatures and pres-sures, and thus decrease the probability of failures, in-cluding "run-in" type failures, from occurring during plant operation."
Based on the need to demonstrate satisfactory performance of systems, struc-tures, or components during plant conditions that simulate, to the extent oractical, "the actual operating and emergency conditions to which the structure, system, or component may be subjected," the staff's position is j
that testing of the Passive Core Cooling System (ADS, CMT, IRWST, Accumula-tors, and PRHR) during the preoperational testing phase (14.2.9.1.3, " Passive Core Cooling System Testing") will not demonstrate "the capability of struc-tures, systems, and components to meet performance requirements to satisfy l
design criteria."
While it is not expected that these systems / design features be tested at i
actual conditions representative of desion, the staff believes Westinghouse l
should tions or(1) modify the subject test descriptions to establish testing condi-performance envelopes (temperature, flow, pressure, power level, etc.) necessary and sufficient to demonstrate (at conditions other than i
4 4
t
) -
i
" representative of design") the capability of the systems / design features to i
perform their design bases functions; and (2) conduct such testing during the power-ascension test phase (post-fuel load).
In its response to this RAI Westinghouse should address these two items.
i l
i i
Discussion Items Level of Detail i
While the staff agrees that the function-based approach can be an acceptable alternative, the ITP as provided for the AP600 is deficient in its level of detail.
The staff is also concerned that when Westinghouse made the transi-l tion to-Revision 9 of the ITP relevant detail related to specific structures, systems, components or design features previously found in Revision 1 of the ITP were not " relocated" accordingly. Using the evolutionary plant ITP abstracts as a benchmark, the AP600 abstracts,.in general, provide insuffi-cient detail to guide the development of detailed test procedures for the tests. Specific examples, include:
j 14.2.9.1.3. " Passive Core Coolina System Testina" 1.
The abstracts for safety injection system tests in the CE 80+ documenta-l tion include details on test methodology that are missing in the AP600 abstra:ts.
l 2.
The CE 80+ abstracts specify as a prerequisite that any required instru-mentation has been installed and calibrated.
Some of the AP600 abstracts state that temporary instrumentation will or may be required to perform the required tests, but do not indicate when the instrumentation should be installed, nor that it requires calibration.
3.
The CE 80+ abstracts specify the types of data that are required; this information is also not indicated for the AP600.
4.
The CE 80+ abstracts contain specific reference to tests of an ECC sampling system to monitor SI chemistry and debris content.
There is no indication in the AP600 ITP documentation as to whether an analogous system exists for the AP600.
Since the sources of ECCS inventory are borated, the staff assumes that some means of chemistry monitoring and control is required.
Similarly, because of the relctively low driving heads available for the passive SI systems, debris that could result in blockages appears also to be parameter that should be monitored.
Testing of these systems should be appropriately indicated, including the types of data required.
In a similar vein, the PXS test abstracts indicate that the testing includes " emergency makeup and boration function;" data to verify the makeup function are discussed (in very broad terms), but there is no guidance given as to how to verify proper operation of the i
boration function of these systems.
4 5.
Passive RHR system:
a test during the startup program (post-fuel loading) is needed to provide adequate assurance of system function in natural circulation.
The current ITP provides only for a natural circulation test during hot functionals, with no heat source.
The staff believes that a more extensive test, bith a constant heat source, is required to confirm PRHR system capabilities (This item is related to RAI No. 260.90, above).
i h
l 2
6.
Some tests are indicated as being required for "first plant only."
Although, conceivably, the "heatup characteristics of the IRWST water" may be necessary only for the first plant, other "first plant only" tests of the PXS should not be designated as such. These include: recirculation testing of the CMTs, and ADS 1/2/3 blowdown.
For both of these systems, the staff believes that an " integral" test is valuable to determine system response characteristics that may be overlooked during the
" separate-effects" type of functional testing specified in the other abstracts, and that such a test should not be restricted to the first plant.
7.
It is not clear from the abstracts as written how the ADS actuation function of the CMT level instrumentation will be tested.
8.
It is not clear how the pH control function can be verified simply by inspection of the trisodium phosphate baskets.
9.
It is not clear from the abstracts how the functionality of the contain-ment sump instrumentation will be demonstrated during PXS testing.
- 10. The original version of the ITP had an " integral" PXS test included that was designed to verify that no adverse systems interactions would occur.
That. test seems to have been eliminated. The staff believes that such a test should be included.
Further, this test may need to include an examination of potential interactions between DID and PXS systems (such as RNS and CMTs).
14.2.9.1.1. " Reactor Coolant System Testina" 1.
Pressurizer, Reactor Coolant Pumps and Pressurizer Safety Valves are major components and hence there should be separate sections for each of them. Add separate test sections for Pressurizer, Reactor Coolant pumps j
and Safety Valves.
{
2.
Testing of RCP motors is excluded. Add testing of RCP motors.
3.
Pressurizer heaters, pressure and control systems can be tested before the hot functional tests by simulating different conditions. Include the testing of these systems in the pre-operational tests.
Comments on Test Descriotion Format 1.
Test Method and Acceptance Criteria sections are combined. They should be separated. The Acceptance Criteria should be given separately to clearly identify the acceptance criteria.
l 2.
It may be acceptable to refer to the pertinent SSAR section for purposes of the system description and operation, but the process parameters and other aspects should be in the individual test sections.
Instead of referring to other sections of the SSAR for information, provide the necessary information in the test section itself. Most of the references i
are not specific and hence the relevant portion can not be located.
Chapter 14 should not be a mere list of references.
i o