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DISTRIBUTION DMB PSRB R/F DHFS R/F (2) bcket Nos. 50-424/425 DLZiemann S p, 8 to g GRMazetis 1ABecker MEMORANDUM FOR:
Thomas H. Novak, Assistant Director for Licensing Division of Licensing FROM:
William T. Russell, Deputy Director Division of Human Factors Safety
SUBJECT:
DRAFT SAFETY EVALUATION REPORT INPUT V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 CHAPTER 14 - INITIAL TEST PROGRAM Georgia Power Company's description of its initial test program and response to TMI Action Plan I.G.1 for the Vogtle Electric Generating Plant test program have been reviewed through Amendment 9 to the FSAR. As indicated in the enclosed Draft SER input, there are items which require additional information from the applicant. We expect to have these items resolved in time for our June 1985 input to the SER, which will also include our SALP input. To date we have not had sufficient interface with the applicant to provide meaningful SALP input.
The review of the Vogtle Electric Generating Plant initial test program is being performed with assistance frc'm Battelle Pacific Northwest Laboratories personnel.
R. Becker, Senior Nuclear Systems Engineer (X29689), is the PSRB reviewer for the Vogtle Electric Generating Plant initial test program.
Questions regarding this evaluation should be directed to him.
The reviewer is not aware of any " Differing Professional Opinions" for the initial test program.
b bhB William. T. flusseTF,hef Deputy irector Division of Human Factors Safety
Enclosure:
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V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DRAFT SAFETY EVALUATION REPORT 14.0 INITIAL TEST PROGRAM The-initial test program encompasses the scope of events that begins with
. completion of system construction and ends with the completion of power ascension testing.
The initial test program consists of the preoperational and the startup test programs. At the conclusion of these test programs a unit is ready for routine power operation.
The preoperational test program begins with system / component turnover from the construction organizati6n to the operations organization, and-ends with the beginning of fuel loading. These tests demonstrate, to the extent practicable, the capability of structures, systems, and components to meet performance requirements, and to satisfy design requirements. To the extent practicable, the. objectives of the preoperational test program are:
(1) to document the perfonnance and operability of equipment and systems, (2) to provide baseline test and operating data on equipment and systems, (3) to operate new equipnient for a sufficient time to identify and correct design, manufacturing, and installation defects, (4) to ensure integrated systems operation, (5) to familiarize plant operating, technical, and maintenance personnel with facility operation, and (6) to confirm the adequacy of normal operating and emergency operating procedures.
, The startup test program begins with fuel loading, is followed by zero power and low power testing, and ends with the completion of power ascension testing. These tests confirm the design bases, and demonstrate to the extent practicable that the plant acerates and responds to transients as designed.
Startup testing is sequenced to ensure that the safety of the plant is not dependent upon the performance of untested structures, systems, or components.
The objectives of the startup test program are:
(1) to accomplish a controlled, orderly, and safe initial core 1.oading, (2) to accomplish a controlled, orderly, and safe initial cr,iticality, (3) to conduct low power testing sufficient to ensure that design parameters are satisfied, and that safety analysis assumptions are correct or conservative, (4) to perform a controlled, orderly, and safe power ascension with requisite testing, terminating at plant rated conditions, and (5) to confirm codes and analytical models used in the reactor design.
The staff review of FSAR Chapter 14 concentrated on the administration of the test program and the completeness of the proposed preoperational and startup tests.
The review consisted of the following parts. The SER-CP was reexamined to determine the principal design criteria for the plant and to identify any specific concerns or unique design features that would warrant special test consideration.
FSAR Chapters 1 through 12 were examined for familiarization with the facility design and nomenclature.
FSAR Chapter 15 was examined to identify assumptions pertaining to performance chara'cteristics that should be verified by testing and to identify all structures, systems, components and design features that were assumed
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,, to function (either explicitly or implicitly) in the accident analyses.
Licensee Event Report Sumaries for operating reactors of similar design were examined to identify potentially serious events and chronic or generic problems that might warrant special test consideration.
The Standard Technical Specifications were examined to identify all structures, systems, and components that would be relied upon for establishing conformance with safety limits or limiting conditions for operation.
Post-TMI related testing
- requirements were examined in conformance with:
NUREG-0660, "NRC Action' Plan Developed as a Result of the TMI-2 Accident;" NUREG-0694, "TMI-Related l
. Requirements for New Operating Licenses;" and NUREG-0737, " Clarification of TMI Action Plan Requirements." And finally, startup test rep, orts for other similar type plants wer,e examined to identify problem areas that should be emphasized in the initial test program.
In'detennining the acceptability of the applicant's test program, the criteria of SRP Section 14.2 were.used.
The staff review process includes
-verification of the following features of the initial test program:
(1) The applicant will develop test procedures using input from the nuclear steam supply system (NSSS) vendor, the architect-engineer, its engineering staff, and equipment suppliers and contractors.
Operating experiences at similar plants will be factored into the development of the test procedures.
(2) The applicant will conduct tests using approved test procedures.
Administrative controls will cover (a) the completion of test prerequisites, (b) the completion of necessary data sheets and other documentation, and (c) the review and approval of modifications to test procedures.
Administrative procedures will also cover implementation of
~ edifications or repair requirements identified as being required by the m
tests and any necessary retesting.
(3) The applicant will review the results of each test for technical adequacy and completeness by review groups including the NSSS vendor and architect-engineer as appropriate.
Preoperational test results will be reviewed prior to fuel loading and the startup test results from each test condition or power level will be reviewed prior to proceeding to the next test condition or power level.
-(4) The applicant will use its normal operating procedures and emergency operating procedures to the extent practicable in performing the initial test program, thereby verifyir g the correctness of the procedures.
c (5) The applicant's schedule for conducting the initial test program allows adequate time to conduct all preoperational and startup teit's.
Preoperational test procedures will be available for NRC regional personnel review at least 60 days prior to scheduled. implementation.
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Startup test procedures will be available for review not less than 60 days prior to the scheduled fuel loading date.
(6) An abstract of each test is presented in FSAR Chapter 14.
The staff verified that there are test abstracts for those structures, systems, components, and design features that:
(a) will be used for shutdown and cooldown of the reactor under normal, transient, and accident conditions and for maintaining the reactor in a safe shutdown condition for an extended period of time; (b) will be used for establishing conformance with safety limits or limiting conditions for operation that will be included in the facility technical specifications; (c) are classified as engineered safety features or will be relied on to support or ensure the operations _ of engineered safety features within design limits; (d) are assumed to function or for which credit is taken in the accident analysis of the facility, as described in the FSAR; or (e) will be used to process, store, control, or limit the release of radioactive materials.
, (7) The test objectives, prerequisites, test methods, and acceptance criteria for each test abstract are in sufficient detail to establish that the functional adequacy of the structures, systems, components, and design features will be demonstrated.
(8)
Exceptions to RG 1.68, "Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors," Revision 2, are identified and adequately justified.
The staff was unable to verify all of the above; therefore, additional information was requested from the applicant (letter from E.,G. Adensam, NRC, to D. O. Foster, Georgia Power Company, dated April 30,1984).
The applicant responded to this request in FSAR Amendments 5 through 9.
Since some-of the responses were incomplete, there are open items that the staff has identified in Table 14-1.
On the basis of its review, the staff has concluded that once the open items identified in Table 14-1 are resolved, the initial test program described in the FSAR will meet the acceptance criteria of SRP Section 14.2 and the regulatory requirements of:
(1) 10 CFR 50.34(b)(6)(fii) that requires inclusion of plans for preoperational testing and initial operations in the FSAR, (2) 10 CFR 50, Appendix B, Section XI, that requires a test program to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures wnich incorporate the requirements and acceptance limits contained in
' applicable design documents, and i
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6-(3) NUREG-0737 Item I.G.1, which requires additional testing and training during the initial test program.
This review and evaluation was performed with the assistance of Battelle Pacific Northwest Laboratories personnel.
Attachment:
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Table 14-1 e
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TABLE 14-1 OPEN ITEMS
. QUESTION NUMBER STATUS 640.03-The Service Air System Preoperational Test (FSAR Subsection 14.2.8.1.56), the Instrument Air System Preoperational Test (FSAR Subsection 14.2.8.1.57), or other test abstracts should be modified to demonstrate that the values identified in FSAR Table 9.3.1-2 (Safety-Related Pneumatically Operated Valves) fail to the safe
. position on loss of instrument air in accordance with position c.8 of Regulatory Guide 1.68.3, Preoperational Testing of Instrument and Control air Systems.
640.04 The response to Item 640.04, Part 8, should reference the Pressurizer Heater and Spray Capability and Continuous Spray Flow Verification Test (FSAR Subsection 14.2.8.2.2) since part of the tests referenced in the response are accomplished in this test abstract.
640.07 The Power Coefficient Determination Test (FSAR Subsection 14.2.8.2.26) should be modified to provide appropriate test prerequisites.
640.08 A.
Appropriate acceptance criteria should be provided for the following:
1.
Preoperational test abstract numbers (FSAR Subsection 14.2.8.1):
2, 7, 8, 11, 14-26, 28, 31, 32, 34, 41, 47-50, 53, 59, 63, 64, 71, 74, 76, 80, 84-86, 89-91, 93,95-100, and 102-110 (2, 47, and 80 are to be provided later).
2.
Startup test abstract numbers (FSAR Subsection 14.2.8.2):
2-5, 7, 9, 10, 14, 15, 24, 25, 27, 35, 36, 43-48, 52 and 53.
C.
Preoperational test modifications to FSAR Paragraphs 14.2.8.1:
1, 2, 27, 33, 35-40, 42, 44-47, 51, 52, 54, 58, 78, 79, 82, 83, 87, 92, and 94 to be made later.
640.09 Response to be provided later.
640.11 Response to be provided later.
640.12 The Ventilation Capability Test (FSAR Subsection 14.2.8.2.58), or other test abstracts, should be modified in accordance with the response to this item.
640.14 Response to be provided later.
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640.20 B.
The 125-V de preoperational test abstracts (FSAR Subsections 14.2.8.1.69 and 14.2.8.1.74) should be modified to demonstrate that testing of de loads necessary for safe shutdown is conducted at minimum de system voltage or that the voltage drop at load to these components is measured to verify that the de loads are supplied with appropriate voltage under minimum battery voltage conditions.
640.22 Response to be provided later.
640.30 1.
Operability of main steam bypass valves will be described in a future amendment.
2.
The Reactor Coolant System (RCS) Preoperational Test-(FSAR Subsection 14.2.8.1.7) should provide a test method and acceptance criteria regarding testing of pressurizer safety valves.
, 3.
Testing should verify that the capacity of pressurizer and steam generator power-operated relief valves are in accordance with the accident analysis assumptions for maximum valve capacity (FSAR Subsections 15.6.1 and 15.1.4).
640.32 FSAR Subsection 14.2.8 (Individual Test Descriptions) should be expanded to address the following systems listed in Regulatory Guide 1.68, Revision 2, Appendix A:
1.
Main stop, control, intercept, and intercept stop valves will be addressed in a future amendment (1.e.6).
2.
Feedwater heater temperature, level, and bypass control systems will be addressed in a future amendment (1.J.17).
3.
Isolation features for steam generator blowdown will be addressed in a future amendment (1.1.4).
4.
Isolation features for several ventilation systems will be addressed in a future amendment (1.1.6).
5.
The Fuel Building Hoists and Elevator Preoperational Test (FSAR Subsection 14.2.8.1.60) and the Fuel Transfer System Preoperational Test (FSAR Subsection 14.2.8.1.61) should be modified to include verification of the performance of the dynamic (100%) and static (125%) load tests of cranes and hoists associated with fuel handling and storage in accordance with the response to this item (1.m.4).
. ' ' 1
. 6.
Turbine plant water sampling systems will be addressed in a future amendment (1.n.5).
7.
The Fuel Handling and Vessel Servicing Preoperational Test (FSAR Subsection 14.2.8.1.59) should be modified to include verification of the performance of the dynamic (100%) load tests of the polar crane.
8.
Containment ventilation operability with the reactor coolant system at rated temperature will be addressed in a future amendment (4.j).
9.
Operability of the gross failed fuel detector should be demonstrated at 25% and 100% power (5.q).
- 10. Operability of the gaseous and liquid radwaste systems should be demonstrated during the power ascension test pha,se (5.c.c).
- 11. Ventilation and air conditioning systems will be addressed in a
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8 future amendment (5.f.f).
The response to Part 5.f.f should reference the Ventilation Capability Test (FSAR Subsection 14.2.8.2.58) since this abstract addresses the concerns of this item.
- 12. FSAR Subsection 1.9.68.2 should be modified to provide justification for exception to the loss of or bypass of feedwater heaters test (5.k.k).
OTHER ITEMS 14.A The RCS Leak Rate Preoperational Test (FSAR Subsection 14.2.8.1.10) was modified to delete the test objectives relating to testing of the containment cooler condensate measuring system. The test objectives are now part of the containment, Auxiliary, Control, and Fuel Handling Building Drains Sys.em Preoperational Test (FSAR Subsection 14.2.8.1.54).
The test objectives, test method, and acceptance criteria for the containment cooler condensate system should be included as a whole in either test abstract, rather than arbitrarily separated.
14.B FSAR Tables 14.2.1-1 (Preoperational Test Procedures) and 14.2.1-2 (Startup Test Procedures) should be updated to include FSAR Subsection 14.2.8.1.107-110 and 14.2.8.2.57-58, respectively.
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Test (FSAR Subsect i on 14.2.8.1.$6).
the I n s t r oiw-o t Air System Preoperational Test (FSAR Subhection 14.2.8.1.57), or other tent abstracts should be modified to demonstrate that the val.es i denti fi ed in FGAR Table 9.3.1-2 (Safety-Related Pneumati cal l y Operated Valves) fail to the safe posi ti on on loss of instrument air in accordance with position C.8 of Regulatory Guide.1.68.3, Preoperational Testing of Instrument and Control Air Systems.
640.04 The Power Coefficient Determination Test (FSAR Subsection 14.2.8.2.26) 1should be modified to provide appropriate test prerequi si tes.
640.08 A.
Appropriate acceptance criteria should be provided for the
' f oll owi ng:
1.
Preoperational test abst act numbers (FSAR Subsec t i on 14.2.8.1):
2, 7,
8, 11, 14-26, 28, 31, 32, 34, 41, 47-50, 53, 59, 63, 64, 71, 74 76, 80, 84-86, 89-91, 93,95-100, and 7
102-110 (2, 47, and 80 are to be provided in Amendment 10).
2.
Startup test a b e t. r a c t numbers
( F SAR Subsection 14.2.8.2):
2-5.
7.
9, 10, 14, 15, 24, 25, 27, 35, 36, 43-48, 52 and 53.
C.
Prooperational test acceptance criteria modifications-to be made in Amendment 10.
640.09 Auxiliary feedwater system test abstracts will be revised in a future amendment.
640.11 Response to be provi ded in Amendment 10.
c40.12' The Ventilation Capability Test (FSAR Subsection 14.2.8.2.58). or
~other test abstracts, should be modified in eccordance wi th the response to this item.
640.14 Response t o be provided in Amendment IG.
510.20 B.
The 125-V de pr+opor+tional test abstrects (FSAR Subsections 14.2.8.1.69 snd 14.2.8.1.74) should be modified to demonstrate that' testing of de loads necessary for safe shutcown is conducted.
at minimum de system voltage or that the vol tage c rop at load to these components is measured to verify that the de loads are supplied with appropriate voltage under minimum eattery voltage condi t i ons.
140.22 Response to be provided in Amendment 10.
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40.30 1.
Operab'lity of
' main steam bypass valves will be described in a i
. future amendment.
2.
The Reactor Coolant System (RCS)
Preoperational Test (FSAR Subsection 14.2.8.1.7) should provide a test method and acceptance criteria regarding' testing of pressurizer safety valves.
3.
Testing should verify that the capacity of pressurizer and steam generator power-operated relief valves are in accordance with the accident analysis assumptions for maximum valve capacity (FSAR Subsections 15.6.1 and 15.1.4).
40.32 FSAR Subsection 14.2.8 (Individual Test Descriptions) should be expanded to address the following system listed in Regulatory Guide
- 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plants.
Revision 2 Ap pend i:- A:
1.
Main stop, control, intercept. and intercept stop valves will be addressed in a: future amendment (1.e.6).
2.
Feedwater heater temperature, level, and bypass control systems will be addressed in a futuro amendment (1.J.17).
3.
1 sol etion f eatures for steam generator blowdown will be addresced in a future amendment (1.1.4).
4.
Isolation
-features for several ventilation s y s t. ems will b,e eddressed-in a future amendment (1.1.6).
5.
The Fuel ~ Building Hoists and Elevator Preoperational Test (FSAR
. Subsection 14.2.8.1.60) and the Fuel Transfer System Preoperational Test (FSAR Subsection 14.2.G.1.61) should be modifi ed to include veri ficati on of the performance of the dynamic (100%)
and static (125%)
load tests of -cranes and hoists associated with fuel handling and storage in accordance with the response to this item (1.m.4).
6.
Turbino plant water sampling systems will be addressed in a-future amendment (1.n.5).
7.
The Fuel Handling and Vessel Servi cing Prec.perati onal Test (FSAR Subsection 14.2.8.1.S9) should be modified to include verification of the perf ormance.of ' the dvnami c (100%) load tests of the polar Crane.
8.
Containment vent i l ati on operability with the reactor coolant system at rated temperature will be addressed in a
future emendment (4.j).
9.
Operability of the gross failed fuel detector should be demonstrated at 25% and 100% power (5.q).
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Containment
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future amendment (4.j).
9.
Operability of the gross failed fuel detector should be demonstrated at 25% and 100% power (5.q).
- 10. Operability of the gaseous and liquid radwaste systems should be demonstrated during the power ascension test phase (5.c.c).
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- 11. Ventilation and air conditioning systems will be addressed
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future amendment ( 5. f. -f ).
- 12. FSAR Subsection 1.9.68.2, Con;f ormance wi th Regulatory Guide 1.68.
should be modi fied to provide juctification for e:: c ep ti on to the loss of or bypass of feedi-sater heaters test (5.k.k).
Other Items 6
The responne to Item 640.04.
Part B,
should reference the Pressuricer Hcater and Spray Capability and Continuous Spray Flow Verification Test (FSAR Subsection 14.2.8.2.2),
as part of the tests refetenced in the response are accomplished in this test abstract.
f.
The response to Item 640.32, Part 5.f.f_
should reference the Ventilation Capability test
( F E AR Subsection 14.2.G.2.58) as this test abstract addresses the concerns of this item.
f.
The RCS Leak Rate Preoperational Test (FSAR Subsection 14.2.G.1.10) was modified to delete the test
- objectives rel ati ng to testing of the centainment cooler condensate measuring system.
The test objectives are now part of the Containment.
Au:: i l i ar y,
- Control, and Ftt el Handling Luilding Deains System Preoperational Test (FSAR Subsection 14.2.8.1.54).
The test objectives, test
- method, end acceptance criteria for the containment cooler condensate system should be included as a
whole in either test abstract, k.-
FSAR Tables 14.2.1-1 (Preoperational Test Froceduses) and 14.2.1-2 (Startup Test Procedures) should be updated to include FSAR Subsection 14.2.8.1.107-110 and 14.2.8.2.57-58. respectively.
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,g, DISTRIBUTION DMB PSRB R/F DHFS R/F DLZiemann ADR 17 1984 gis
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!! Ell 0RANDUM FOR:
Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing FROM:
Dennis L. Ziemann, Chief Procedures and Systems Review Branch Division of Human Factors Safety
SUBJECT:
V0GTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION AND STAFF POSITIONS - INITIAL TEST PROGRN-l Contractor personnel from Battelle Pacific Northwest Laboratories (PNL) have reviewed the initial test programs described in Chapter 14.0, Section 14.2, of the FSAR for the Vogtle Electric Generating Plant Units 1 and 2.
PSRB has reviewed the PNL input and our questions and staff positions are enclosed for,
your transmittal to the applicant.
The PSRB reviewer for this task is R. A. Becker (X29689).
Ort Ir..k.! * :d by osm.:.d.. :r. u. na Dennis L. Ziemann, Chief Procedures and Systeus Review Branch Division of Human Factors Safety
Enclosure:
As stated cc w/ enclosure:
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STAFF POSITIONS AND REQUESTS FOR ADDITIONAL INFORMATION Vogtle Electric Generating Plant Units 1 & 2 INITIAL TEST PROGRAM i
640.02 FSAR Subsection 1.9.68.2 does not provide adequate technical 3
(1.9.68) justification for not demonstrating the operability and automatic (14.2.8) closure of aLL main steam isolation valves (MSIVs) at power in
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accordance with Regulatory Guide 1.68 (Initial Test Programs for Water-Cooled Nuclear Power Plants):
1.
The exception to Regulatory Guide 1.68, Appendix A.5.u, is acceptable only if the operability and response times of the MSIVs are demonstrated at temperature.
The Main Steam System i
Preoperational Test abstract (FSAR Subsection 14.2.8.1.1), or other appropriate test abstracts, should demonstrate proper operation and response times of the MSIVs during hot functional or startup testing.
2.
The exception to Regulatory Guide 1.68, Appendix A'.5.m.m, is
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acceptable only if MSIV system isolation is demonstrated during the initial test program. The Main Steam System Preoperational Test abstract (FSAR Subsection 14.2.8.1.1), or other appropriate, test abstracts, should be modified to demonstrate MSIV system isolation.
640.03 FSAR Subsection 1.9.68.4.2 does not provide adequate technical (1.9.68) justification for not performing loss-of-instrument-air tests in (14.2.8) accordance with Position C 8 of Regulatory Guide 1.68.3 (Preoperational Testing of Instrument and Control Air Systems).
Delete this exception and modify the Service Air Lystem Preoperational Test abstract (FSAR Subsection 14.2.8.1.56), the Instrument Air System Preoperational Test abstract (FSAR Subsection 14.2.8.1.57), or other appropriate test abstracts to demonstrate this testing, or provide technical justification for retaining this exception.
640.04 NUREG-0694, "TMI Related Requirements for New Operating Licenses,"
(14.2.5)
Item I.G.1, requires applicants to perform "a special low power (14.2.8) testing program approved by NRC to be conducted at power levels of greater than 5% for the purposes of providing meaningful technical 1
information beyond that obtained in the normal startup test program I
and to provide supplemental training." The Low-Power Natural l
Circulation Test abstract (FSAR Subsection 14.2.8.2.47) does not reflect the comprehensiveness of the testing or operator training i
requirements.
Modify the Low-Power Natural Circulation Test abstract (FSAR Subsection 14.2.8.2.47). and other test abstracts as appropriate to demonstrate the testing and training requirements, l
or their equivalent, as described in Attachment 4 to a letter from E. P. Rahe (Westinghouse) te H. R. Denton (NRC) dated July 8,1981,
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which contains an acceptable approach for accomplishing the testing objectives listed below. Also, refer to a letter from R. L. Tedesco j
(NRC) to W. E. Ehrensperger (Georgia Power) dated June 10, 1981.
The response should ensure accomplishment of the following i
objectives:
2 Testing--The tests should demonstrate the following plant characteristics:
Length of time required to stabilize natural circulation, core flow distribution, ability to establish and maintain natural circulation with or without onsite and offsite power, the ability to uniformly borate and cool down to hot shutdown conditions using natural circulation, and subcooling monitor performance.
Test data should be used as feedback for simulator verification and update.
Training--Each Licensed reactor operator (R0 or SRO who performs R0 or SR0 duties, respectively) should participate in the initiation, maintenance, and recovery from the natural circulation mode.
Operators should be able to recognize when i
natural circulation has been stabilized and should be able to control saturation margin, RCS pressure, and heat removal rate without exceeding specified operating Limits.
640.05 The description of the approach to criticality in FSAR Subsection (14.2.6) 14.2.6.2 (Post-Loading Tests) or in the Initial Criticality Test (14.2.8) abstract (FSAR Subsection 14.2.8.2.39) should be modified to include the following in accordance with Regulatory Guide 1.68, Appendix A.3:
1.
A neutron count rate at least 1/2 count per second should register on the startup channels before startup begins, and the signal-to-noise ratio should be known to be greater than two.
2.
Criticality should not be achieved on a period shorter than approximately 30 seconds (<1 decade per minute).
640.06 It is not apparent from the discussion in FSAR Subsections 14.2.6 (14.2.6) and 14.2.7 that the commencement of fuel loading requires (14.2.7) completion of aLL preoperational tests.
For portions of any preoperational tests (including review and approval of test results) which are intended to be conducted after fuel loading:
(a) List each test; (b) state what portions of each test wiLL be delayed until after fuel loading; (c) provide technical justification for delaying these portions; and (d) state when each test will be completed.
640.07 It is not appropriate to indicate that test abstract prerequisites (14.2.8) are " established as required by the test instructions." The following startup test procedure abstracts (FSAR Subsection 14.2.8.2) should contain appropriate prerequisites (Regulatory Guide 1.68, Appendix C.1.a):
7, 8, 10, 12-14, 16, 17, 24-26, 29, 31, 33, 35, 37, 40, and 54.
640.08 The acceptance criteria provided in FSAR Subsection 14.2.8 should
~(14.2.8) include, for all tests subject to FSAR Chapter 17 (Quality Assurance) considerations, acceptance criteria or a discussion of the sources for the acceptance criteria to be used when test procedures are prepared.
This information is necessary for the NRC inspectors who review test procedures and evaluate test results.
The test description should provide " traceability" to acceptance i
= - - -
^
3 criteria sources such as:
specific FSAR Subsections, Technical Specifications, topical reports, vendor-furnished test specifications, and/or accident analysis assumptions.
1.
Appropriate acceptance criteria should be provided for the following listed test abstracts. The individual acceptance criteria could be modified, or a table could be provided which Lists the acceptance criteria (preferably the appropriate FSAR subsection) for each test:
a.
Preoperational test abstract numbers (FSAR Subsection 14.2.8.1):
2, 7, 8, 10, 11, 14-26, 28, 31, 32, 34, 41, 43, 47-50, 53, 59-64, 69, 71, 74, 76, 80, 81, 84-86, 88-91, 93,95-100, and 102-105.
b.
Startup test abstract numbers (FSAR Subsection 14.2.8.2):
2-4, 5, 7, 9, 10, 12, 13, 15-19, 24-27, 31, 33, 35-37, 40, 42-48, 52, and 53.
2.
It is not appropriate to indicate that test ab,stract acceptance criteria are "in accordance with test instructions." The following startup test procedure abstracts (FSAR Subsection 14.2.8.2) should be modified to contain acceptance criteria as noted above:
10, 16, 17, 24-26, 31, 37, 40, and 53, 3.
It is inappropriate (too circumscriptive) when referencing a specific FSAR subsection for acceptance criteria to add the phrase "when.u3ing the above test methods." The following listed preoperational test abstracts (FSAR Subsection 14.2.8.1) should be modified accordingly:
1, 2, 27, 33, 35-40, 42, 44-47, 51, 52, 54, 58, 78, 79, 82, 83, 87, 92, and 94.
640.09 The Motor-Driven and Turbine-Driven Auxiliary Feedwater System (14.2.8)
Preoperational Test abstracts (FSAR Subsections 14.2.8.1.5 and 14.2.8.1.6) should include the following testing:
1.
A 48-hour endurance test on aLL Auxiliary Feed Water (AFW) system pumps, if such a test or continuous period of operation has not been accomplished to date (to comply with Standard Review Plan Section 10.4.9).
Following the 48-hour pump run, the pumps should be shut down and cooled down and then restarted and run for one hour.
(Letter to aLL W System OL applicants from NRC - D. F. Ross, dated March 10, 1980.)
2.
To verify conformance with Item GS-5 of the above referenced Letter, the AFW system should be tested for capability to start and operate for two hours under simulated loss of all AC power conditions.
I 3.
Manual and simulated automatic cold, quick starts for turbine-driven AFW pumps.
At least one simulated automatic cold, quick start should follow an idle period of sufficient duration to demonstrate that the unit is not subject to startup overspeed trip due to drain-down of oil from the speed control i
.~.,_ _
4 meenanism.
l Test acceptance criteria for the above tests should include demonstrating that (a) the pumps remain within design Limits with 4
respect to bearing / bearing oil temperatures and vibration, (b) both normal and backup water supply source flowpaths are verified, and (c) pump room ambient conditions (temperature, humidity) do not exceed environmental qualification limits for safety-related equipment in the room.
640.10 The Containment Spray System Preoperational Test abstract (FSAR (14.2.8)
Subsection 14.2.8.1.26) should include testing to verify that paths for the air-flow test of the spray nozzles overlap the water-flow test paths of the pumps to demonstrate that there is no blockage in that section of the flow path.
640.11 The Nuclear Service Cooling Water System Preoperational Test (14.2.8) abstract (FSAR Subsection 14.2.8.1.33) should include-tests which demonstrate the operability and availability of the ultimate heat sink (FSAR Subsection 9.2.5).
Such tests should demonstrate adequate NPSH and the absence of vortexing at the worst postulated conditions (minimum basin Level and maximum basin temperature).
640.12 The initial plant test program should ensure that the emergency (14.2.8) ventilation systems are capable of maintaining all safety equipment within their design temperature range with the equipment operating in a manner that wiLL produce the maximum heat load in the 1
compartment.
If it is not practical to produce maximum heat loads 1
in a compartment'during preoperational or startup testing, describe the methods that wiLL be used to develop acceptance criteria that verify design heat removal capability of the emergency ventilation systems (i. e., validation of analytical models using part load data).
Note that it is not apparent that post-accident design heat loads wiLL be _ produced in ESF equipment rooms during the scheduled test phage; therefore, simply assuring that area temperatures remain within design limits during this period wiLL not demonstrate the l
design heat removal capability of these systems.
It wiLL be necessary to include measurement of air and cooling water l
temperatures and flows, and the extrapolations used to verify that the ventilation systems can remove the postulated post-accident heat loads.
640.13 The Service Air and Instrument Air System Preoperational Test (14.2.8) abstracts (FSAR Subsections 14.2.8.1.56 and 14.2.8.1.57) should include testing to ensure that credible failures resulting in an increase in the supply system pressure wiLL not cause loss of operability (Regulatory Guide 1.68.3, Position C.11).
l 640.14 The Fire Protection System Preoperational Test abstract (FSAR (14.2.8)
Subsection 14.2.12.1.58) should provide assurance that:
i 1.
Upon automatic sprinkler actuation, adequate drainage in the
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5 affected spaces is provided to preclude flooding (including ~
expected hand-held hose volume).
2.
Nozzles serving indoor facilities are air-flow tested and that these tests overlap the water flow tests.
3.
A walk-down of plant equipment is conducted to identify potential incidences where the actuation of fire suppression systems could cause damage to or inoperability of systems important to safety.
4 See ISE Information Notice 83-41:
Actuation of Fire Suppression System Causing Inoperability of Safety-Related Equipment, June 22, 1963.
640.15 The Diesel Generator Preoperational Test abstract (FSAR Subsection (14.2.8) 14.2.8.1.64) or the Integrated Safeguards and Blaciout sequence Preoperational Test abstract (FSAR Subsection 14.2.8.1.97) should include a description of the following tests (Regulatory Guide 1.108, Periodic Testing of Diesel Generator Units Used as Onsit?
l Electric Power Systems at Nuclear Power Plants):
1.
Full-load-carrying capability test (Regulatory Guide 1.108, Position C.2.a.3) 2.
Simultaneous start of redundant units (Regulatory Guide 1.108, Position C.2.b).
t 640.16 The Main, Unit, and Reserve Auxiliary Transformers Preoperational j
(14.2.8)
Test abstracts (FSAR Subsections 14.2.8.1.66 and 14.2.8.1.67) should demonstrate the proper operation of transformer cooling under rated Load or describe how data from testing under available load wiLL be extrapolated to verify cooling capability under design Loading.
640.17 The Non-Class 1E AC Distribution Preoperational Test abstract (FSAR
{
(14.2.8)
Subsection 14.2.8.1.68) references FSAR Subsection 8.3.2 (DC Power System) as part of the acceptance criterion. This test should be expanded to include testing of the DC distribution system, or a test absract should be provided which demonstrates testing of the DC distribution system.
640.13 Provide assurance that NUREG - 0800, Appendix S-A, Branch Technical (14.2.8)
Position PSB 1 voltage measurements wiLL be taken at each load 3 -
required for safe shutdown to assure an acceptable voltage drop from the appropriate Class 1E bus to the Load.
L 640.19.
In accordance with Regulatory Guide 1.41, (Preoperational Testing (14.2.8) of Redundant On-Site Electric Power Systems to Verify Proper Load Group Assignments), Positions C.2 and C.3, abstracts of preoperational tests involving sources of power to vital buses j
should address the fotLowing:
1.
Full-Load testing, or extrapolation to full-Load testing
{
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6 i
conditions, should Le accomplished.
2.
Buses and related Loads not under test should be ionitored to l
verify the absence of voltage.
3.
Verify absence of cross-ties between units which could degrade emergency power on one unit due to testing on the other unit.
640.20 The 125-V DC Preoperational Test abstracts (FSAR Subsection (14.2.8) 14.2.8.1.69 and 14.2.8.1.74) should address the following:
1.
The individual cell Limits should be checked following the discharge test to ensure that they are within Limits CRegulatory Guide 1.68, Appendix A.1.g(4)].
2.
Incorporate testing to verify that at t'he minimum and maximum design battery voltages, required Class 1E Loads can be started and operated.
The battery chargers should not be put in use until after the 1E Loads have started (IEEE 308-1980).
For more information on problems with maximum battery voltage conditions, see ISE Information Notice 83-08, March 9,1983.
640.21 The Reactor Protection System Preoperational Test abstract (FSAR (14.2.8)
Subsection 14.2.8.1.85) should provide assurance that a manual reactor trip wiLL cause both removal of voltage from the undervoltage trip coil as weLL as energization of the shunt trip coil (see 18E Sulletin 83-01, February 25, 1963).
640.22 The Reactor Trip and ESFAS Response Time Test abstract (FSAR (14.2.8)
Subsection 14.2.8.1.106) should include or reference testing that wiLL (Regulatory, Guide 1.68, Appendix A.1.c):
1.
Account for delay times of process-to-sensor hardware (e.g.,
instrument lines, hydraulic snubbers).
I 2.
Provide assurance that the response time of each primary sensor is acceptable.
3.
Provide assurance that the total reactor protection system l
response time is consistent with the accident analysis assumptions.
l NOTE:
Item 2 can be accomplished by measuring the response time of each sensor during the preoperstional test, stating that the response time of each sensor wiLL be measured by the manufacturer within two years prior to fuel Loading, or describing the manufacturer's certification process in sufficient detail for use to conclude that the sensor response times are in accordance with design.
640.23 The Rod Drop Time Measurement Test abstract (FSAR Subsection (14.2.8) 14.2.8.2.14) should include retest (>3 times) of those control rods whose drop time falls outside the two-sigma limit (Regulatory Guide 1.68, Appendix A.2.b).
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L 7
640.24 The RCS Sampling for Core Loading Test abstract (FSAR Subsection (14.2.8) 14.2.8.2.18) should include appropriate acceptance criterion.
640.25 The Load Swing Test abstract (FSAR Subsection 14.2.8.2.27) should (14.2.8) be accomplished at 25%, 50%, 75%, and 100% of full power (Regulatory Guide 1.68, Appendix A.5.h.h).
640.26 The Remote Shutdown Test abstract (FSAR Subsection 14.2.8.2.45)
(14.2.8) should address the following (Regulatory Guide 1.68.2, Initial Startup Test Program to Demonstrate Remote Shutdown capability for Water Cooled Nuclear Power Plants):
1.
The test abstract should state that plant systems are in the normal configuration with the turbine generator in operation (Regulatory Guide 1.68.2, Position C.3).
2.
The test should demonstrate that the plant can be m"aintained at stable hot standby conditions for at least 30 minutes (Regulatory Guide 1.68.2, Position C.3.b).
s 640.27 The Loss of offsite Power at Greater Than 10-Percent Power Test (14.2.8) abstract (FSAR Subsection 14.2.8.2.46) should state that the 4
loss-of power condition is maintained Long enough (>30 minutes) for l
conditions to stabilize (Regulatory Guide 1.68, Appendix A.5.J.j).
640.28 The response to Item 640.1 states that the Primary and Secondary (14.2.M)
Chemistry Test abstract (FSAR Subsection 14.2.8.2.49) wiLL not be included in the initial test program.
Either modify the response to Item 640.1 and provide this test abstract, or modify FSAR l
Subsection 1.9.68.2 to provide technical justification for the exception to Regulatory Guide 1.68, Appendix A.4.h and A.5.a.a).
I 640.29 The Plant Trip from 100-Percent Power Test abstract (FSAR
)
(14.2.8)
Subsection 14.2.8.2.53) states that the " turbine generator is i
manually tripped." The test abstract should state that the trip is initiated by a direct electrical signal such that the turbine generator wiLL be subjected to the maximum credible i
overspeed condition, or a full Load rejection test should be l
accomplished (Regulatory Guide 1.68, Appendix A.5.L.L and i
A.5.n.n).
640.30 Regulatory Guide 1.68, Revision 2, Appendix A.1.a(2), A.1.e, A.4.p, j
(14.2.8) and A.5.t prescribe testing for various valves.
Modify appropriate FSAR Subsection 14.2.8 test abstracts to provide for a more l
complete demonstration of the operability of pressurizer power operated relief and safety valves, main steam Line relief and safety valves, and main steam bypass valves.
Such testing should include verification that:
2 1.
Response times, and open and reclosure setpoints are checked.
i 2.
Open and reclosure setpoints for aLL relief valves are checked i
at temperature.
8' 1
3.
The capacity of the pressurizer power operated relief valves ic and the power operated atmospheric relief valves is consistent with th,e accident analysis assumptions for both the minimum and maximum capacity conditions.
When referencing bench tests instead of performing installed capacity checks, technical justification should be provided.
Where valves are not tested in-situ with the' process fluid, testing should be conducted to verify that discharge piping is clear and wiLL not choke or produce back pressure affecting set-reset pressures and capacities of the valves.
640.31 It is important that motor operated valve torque switches be set at (14.2.8) the manufacturer 1s recommended values to ensure that the valves wiLL operate under accident conditions (ISE Information Notice 84-10).
If preoperational testing is conducted under.l.ow differential pressure conditions, it is possible that torque switch settings may have been reduced to prevent applying excessive force that could cause the valve to jam in the closed or open position during testing.
Appropriate test abstracts (FSAR Subsection 14.2.8) should be modified to include (a) as prerequisites that the torque switch settings are at the ranufacturer's recommended values prior to the beginning of preoperational testing, or (b) testing of valve operability with the torque switch settings at the required values. This may mean repeating tests when at rated differential pressure if Lower torque switch settings were used for earlier testing.
640.32 Our review of the initial test program description disclosed that (14.2.8) the operability of several of the systems and components Listed in Regulatory,Guidex1.68 (Revision 2) Appendix A may not be adequately demonstrated by the initial test program.
Expand FSAR Subsection 14.2.8 (Individual Test De):riptions) to address the following items:
NOTE:
Inclusion of a -test description in FSAR Chapter 14 does not necessari,Ly imply that the test becomes subject to FSAR Chapter 17
~
(Quality Assurance) controls.
Certain tests to be performed prior to fuel loading to verify system operability may be referred to as
" acceptance tests" to distinguish them from "preoperational tests" subject to FSAR Chapter 17 test control, thereby reflecting a
" graded approach" to testing consistent with Regulatory Guide 1.68, Position C.1.
Preoperational Test,ing R.G. 1.68 FSAR Appendix A Section Description 1.d.7 10.2.2 Extraction nonreturn valves 1.d.9 9.2.6 Condensate storage facility
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9 1.e.5 10.3.2 Steam Extraction System 1.e.6 10.2.2 Main stop, control, intercept, and intercept stop valves I
1.e.7 10.4.1 Main condenser hotwell level control system 1.e.11 10.4.10 condensate and feedwater chemical injection system 1.1.21 Containment penetration cooling system tests 1.J.17 10.4.7 Feedwater heater temperature, level, and bypass control systems 1.J.25 Process computers 1.L.4 11.5 Isolation features for steam generator blowdown 1.L.6 11.5 Isolation features for ventilation systems 1.L.7 11.5 Isolation features for liquid radweste effluent systems 1.m.1 9.1.3, 11.5 spent fuel pit cooling system tests of high radiation alarms and low water level alarms 1.m.3 9.1.4 operability and Leak tests of I
sectionalizing devices and drains and Leak tests of gaskets or bellows in the refueling canal and fuel storage pool 1.m.4 9.1.4 cynamic (100%) and static (125%) tests of cranes, hoists and associated fuel 4
storage and handling systems.
1.n.5 9.3.2 Turbine plant water sampling systems 1.n.8 Seal water systems 1.n.15 Shield cooling systems 1
1.o.1 9.1.5 Polar crane dynamic (100%) and static 1
(125%) Loading tests.
Initial Fuel Loading and Precritical Tests 2.b Control rod decelerating devices 3
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Low power testing 4.d Adequate overlap of source-and intermedfate-range neutron instrumentation i
A 4.}
Containment ventilation operability with RCS at rated temperature MSIV operability and response time 4.k tests at rated temperature (see Item 640.02) 4.n Computer Power Ascension Tests 5.q Failed fuel detector 5.r computer 5.w s.< containment penetration coolers.
Provide a preoperational test description or, on those penetrations where coolers are not used, provide a startup test d'scription that wiLL e
demonstrate that concrete temperatures surrounding hot penetrations do not exceed design limits.
5.c.c Gaseous and liquid radwaste systems 5.f.f Ventilation and air conditioning systems 5.g.g ATWS systems which may be installed in~
the future l
I 5.k.k Loss of or bypass of feedwater heatefs 640.33 List and provide technical justification for any tests or portions (14.2.8) of tests described in FSAR Chapter 14 which you believe should be exempted from the License condition requiring prior NRC notification of major test changes to tests intended to verify the proper design, construction, or performance of systems, structures, or components important to safety EfulfiLL General Design Criteria (GDC) functions and/or are subject to 10 CFR 50 Appendix B Quality Assurance requirements].
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OBallelle Pacific Northwest Laboratories P.O. Box 999 Richland. Washington U.S A. 99352 Telephone (509' 375-3621 Telen 15 2874 April 4, 1984 Mr. William O. Iong Procedures and Systems Review Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Bill:
SUBJECT:
Q Inputs for Chapter 14 (FSAR) Initial Plant Test Program Review --
Vogtle Electric Generating Plants Unit 1 and Unit 2 The attached sheets include staff positions and requests for additional information developed during our review of the Vogtle initial plant test program. The review was conducted through Amendment 4 (2/84). The attachment 640.33) which represents outstanding items includes a listing (640.02 requiring resolution.
Note that Items 640.01 has already been asked and responded to by the applicant in Amendment 1.
A copy of this item has been enclosed for your information.
It is expected that following a comprehensive review of these Q inputs, the PSRB will forward the applicable items to the project manager for transmittal to the applicant (Vogtle).
Please feel free to call at any time to discuss individual items, or the collective review.
S+incerely, W 51..M Robert L. Gruel Project Manager FSAR CH 14 Reviews
/c Attachments Bo
L STAFF POSITIONS AND REQUESTS FOR ADDITIONAL INFORMATION Vogtle Electric Generating Plant Units 1 & 2 INITIAL TEST PROGRAM 640.02 FSAR Subsection 1.9.68.2 does not provide adeauate technical (1.9.68) justification for not demonstrating the operability and automatic (14.2.8) closure of all main steam isolation valves (MSIVs) at power in accordance with Regulatory Guide 1.68 (Initial Test Programs for Water-Cooled Nuclear Power Plants):
1.
The exception to Appendix A.5.u is acceptable only if the operability and response times of the MSIVs are demonstrated at temperature. The Main Steam System Preoperational Test abstract (FSAR Subsection 14.2.8.1.1), or other appropriate test abstracts, should demonstrate proper operation and response times of the MSIVs during hot functional or startup testing.
2.
The exception to Appendix A.5.m.m is acceptable 'o~nly if proper operation of the MSIV trip function is demonstrated during the initial test program. The Main Steam System Preoperational Test abstract (FSAR Subsection 14.2.8.1.1), or other appropriate test abstracts, should demonstrate proper operatfori of the'MSIY trip function during preoperational or startup testing.
640.03 FSAR Subsection 1.9.68.4.2.does not provide adequate technical
' (14.2.8) justification for not performing loss-of-instrument-air tests in 1.9.68)
(
accordance with Position C.8 of Regulatory Guide 1.68.3 (Preoperational Testing of Instrument and Control Air Systems).
Delete this exception and modify the Service Air System Preoperational Test abstract (FSAR Subsection 14.2.8.1.56), the Instrument Air System Preoperational Test abstract (FSAR Subsection 14.2.8.1.57), or other appropriate test abstracts to demonstrate this testing, or provide technical justification for retaining this exception.
640.04 NUREG-0694, "TMI Related Requirements for New Operating Licenses,"
(14.2.5) ltem I.G.1, requires applicants to perform "a special low power (14.2.8) testing program approved by NRC to be conducted at power levels of greater than 5% for the purposes of providing meaningful technical information beyond that obtained in the normal startup test program and to provide supplemental training." To comply with this requirement, modify the Low-Power Natural Circulation Test abstract t
(FSAR Subsection 14.2.8.2.47) and other test abstracts as appropriate to demonstrate the testing requirements, or their equivalent, as described in Attachment 4 to a letter from E. P.
Rahe (Westinghouse) to H. R. Denton (NRC) dated July 8,1981, which contains an acceptable approach for accomplishing the testing objectives listed below. The response should ensure accomplishment of the following objectives:
l l
l.
2 Testing--The tests should demonstrate the following plant characteristics:
length of time required to stabilize natural circulation, core flow distribution, ability to establish and maintain natural circulation with or without onsite and offsite power, the ability to uniformly borate and cool down to bot shutdown conditions using natural circulation, and subctal ~ng monitor performance. Test data should be used as feedbac*r for simulator verification and update.
Training--Each licensed reactor operator (R0 or SR0 who performs RO or SR0 duties, respectively) should participate in the initiation, maintenance, and recovery from the natural circulation mode. Operators should be able to recognize when natural circulation has been stabilized and should be able to control saturation margin, RCS pressure, and heat removal rate without exceeding specified operating limits.
640.05 The description of the approach to criticality in FSAR Subsection (14.2.6) 14.2.6.2 (Post-loading Tests) or in the Initial Criticality Test (14.2.8) abstract (FSAR Subsection 14.2.8.2.39) should be modified to include the following in accordance with Regulatory Guide 1.68, Appendix A.3:
1.
A neutron count rate at least 1/2 count per second should register on the startup channels before startup begins, and the signal-to-noise ratio should be known to be greater than two.
2.
Criticality should not be achieved on a period shorter than approximately 30 seconds (<1 decade per minute).
640.06 It is not apparent from the discussion in FSAR Subsections 14.2.6 (14.2.6) and 14.2.7 that the commencement of fuel loading requires (14.2.7) completion of all preoperational tests. For portions of any preoperational tests (including review and approval of test results) which are intended to be conducted after fuel loading:
(a) list each test; (b). state what portions of each test will be delayed until after fuel loading; (c) provide technical justification for delaying these portions; and (d) state when each test will be completed.
640.07 It is not appropriate to list that test abstract prerequisites are (14.2.8)
" established as required by the test instructions." The following startup test procedure abstracts (FSAR Subsection 14.2.8.2) should contain appropriate prerequisites:
7, 8, 10, 12-14, 16, 17, 24-26, 29, 31, 33, 35, 37, 40, and 54.
3 640.08 The acceptance criteria provided in FSAR Subsection 14.2.8 should (14.2.8) include, for all tests subject to FSAR Chapter 17 (Quality Assurance) considerations, acceptance criteria or a discussion of the sources for the acceptance criteria to be used when test procedures are prepared. This information is necessary for the NRC inspectors who review test procedures and evaluate test results.
The test description should provide " traceability" to acceptance criteria sources such as:
specific FSAR Subsections, Technical Specifications, topical reports, vendor-furnished test specifications, and/or accident analysis assumptions.
1.
Appropriate acceptance criteria should be provided for the following listed test abstracts. The individual acceptance criteria could be modified, or a table could be provided which lists the acceptance criteria (preferably the appropriate FSAR subsection) for each test:
a.
Preoperational test abstract numbers (FSAR Subsection 14.2.8.1):
2, 7, 8, 10, 11, 14-26, 28, 31, 32, 34, 41, 43, 47-50, 53, 59-64, 69, 71, 74, 76, 80, 81, 84-86, 88-91, 93,95-100, and 102-105.
b.
Startup test abstract numbers (FSAR Subsection 14.2.8.2):
2-4, 5, 7, 9, 10, 12, 13, 15-19, 24-27, 31, 33, 35-37, 40, 42-48, 52, and 53, 2.
It is not appropriate to list that test abstract acceptance criteria are in accordance with test instructions." The following startup test procedure abstracts (FSAR Subsection i.
14.2.8.2) should be modified to contain appropriate acceptance criteria:
10, 16, 17, 24-26, 31, 37, 40, and 53.
3.
When referencing a specific FSAR subsection for acceptance criteria,'it is overly restrictive to state that the system operates.as designed in section... "when using the above test methods? The following listed preoperational test abstrac.ts (FSAR Subsection 14.2.8.1) should be modified accordingly:
1, 2, 27, 33, 35-40, 42, 44-47, 51, 52, 54, 58, 78, 79, 82, 83, 87, 92, and 94.
640.09 The Motor-Driven and Turbine-Driven Auxiliary Feedwater System l
(14.2.8)
Preoperational Test abstracts (FSAR Subsections 14.2.8.1.5 and 14.2.8.1.6) should include the following testing:
1.
A 48-hour endurance test on all Auxiliary Feed Water (AFW) system pumps, if such a test or continuous period of operation i
has not been accomplished to date (to comply with Standard i
Review Plan Section 10.4.9). Following the 48-hour pump run, the pumps should be shut down and cooled down and then j
restarted and run for one hour.
(Letter to all W System OL applicants from NRC - D. F. Ross, dated March 1071980.)
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2.
To verify conformance with Item GS-5 of the above referenced i
letter, the AFW system should be tested for capability to start and operate for two hours under simulated loss of all AC power conditions.
3.
Manual and simulated automatic cold, quick starts for turbine-driven AFW pumps. At least one simulated automatic cold.. quick start should follow an idle period equal to the surveillance interval unless it can be shown that, without credit taken for check valves, the unit is not subject to startup overspeed trip due to drain-down of oil from the speed control mechanism.
Test acceptance criteria for the above tests should include demonstrating that (a) the pumps remain within design limits with respect to bearing / bearing oil temperatures and vibration, (b) both normal and backup water supply source flowpaths are verified, and (c) pump room ambient conditions (temperature, humidity) do not exceed environmental qualification limits for safety-related equipment in the room.
640.10 The Containment Spray System Preoperational Test abstract (FSAR (14.2.8)
Subsection 14.2.8.1.26) should include testing to verify that paths for the air-flow test of the spray nozzles overlap the water-flow test paths of the pumps to demonstrate that there is no blockage in that section of the flow path.
640.11 The Nuclear Service Cooling Water System Preoperational Test (14.2.8) abstract (FSAR Subsection 14.2.8.1.33) should include tests which demonstrate the operability and availability of the ultimate heat sink (FSAR Subsection 9.2.5).
Such tests should demonstrate adequate NPSH and the absence of vortexing at the worst postulated conditions (minimum basin level and maximum basin temperature).
640.12 The initial plant test program should ensure that the emergency (14.2.8) ventilation systems are capable of maintaining all safety equipment within their design temperature range with the equipment operating in a manner that will produce the maximum heat load in the compartment.
If it is not practical to produce maximum heat loads l
in a compartment during preoperational or startup testing, describe the methods that will be used to develop acceptance criteria that verify design heat removal capability of the emergency ventilation systems.
Note that it is not apparent that post-accident design heat loads i
will be produced in ESF equipment rooms during the scheduled test phase; therefore, simply assuring that area temperatures remain within design limits during this period will not demonstrate the l
design heat removal capability of these systems.
It will be necessary to include measurement of air and cooling water
.m
4 5
4 temperatures and flows, and the extrapolations used to verify that the ventilation systems can remove the postulated post-accident heat loads.
640.13 The Service Air and Instrument Air System Preoperational Test (14.2.8) abstracts (FSAR Subsections 14.2.8.1.56 and 14.2.8.1.57) should include testing to ensure that credible failures resulting in an increase in the supply system pressure will not cause loss of operability (Regulatory Guide 1.68.3, Position C.11).
-640.14 The Fire Protection System Preoperational Test abstract (FSAR 4
l (14.2.8)
Subsection 14.2.12.1.58) should provide assurance that:
1.
Upon automatic sprinkler actuation, adequate drainage in the affected spaces is provided to expected hand-held hose volume) preclude flooding (including 2.
Nozzles serving indoor facilities are air-flow tested and that these tests overlap the water flow tests.
3.
A walk-down of plant equipment is conducted to identify potential incidences where the actuation of fire suppression systems could cause damage to or inoperability of systems important to safety.
See ISE Information Notice 83-41: Actuation of Fire Suppression System Causing Inoperability of Safety-Related Equipment, June 22, 1983.
640.15 The Diesel Generator Preoperational Test abstract (FSAR Subsection (14.2.8) 14.2.8.1.64) or the Integrated Safeguards and Blackout Sequence Preoperational Test abstract (FSAR Subsection 14.2.8.1.97). should include a des ~cription of the following tests (Regulatory Guide 1.108, Periodic Testing of Diesel Generator Units Used as Onsite i
Electric Power Systems at Nuclear Power Plants):
1.
Full-load-carrying capability test (Position C.2.a.3) 2.
Simultaneous start of redundant units (Position C.2.b).
J 640.16 The Main, Unit, and Reserve Auxiliary Transformers Preoperational (14.2.8)
Test abstracts (FSAR Subsections 14.2.8.1.66 and 14.2.8.1.67) should demonstrate the proper operation of transformer cooling under rated load or describe how data from testing under available load will be extrapolated to verify cooling capability under design loading.
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640.17 The Non-Class 1E ac Distribution Preoperational Test abstract (FSAR (14.2.8)
Subsection 14.2.8.1.68) references FSAR Subsection 8.3.2 (DC Power System) as part of the acceptance criterion. This test abstract should include testing of the dc distribution system if that is the intent, or a reference should be provided to a test abstract where-de distribution system testing is cecomplished.
640.18 Provide assurance that the voltage measurements specified by Branch (14.2.8).
Technical Position PSB-1, NUREG-0800, will be taken at each load required for safe shutdown to assure an acceptable voltage drop from the appropriate Class 1E bus to each load.
I 640.19 In accordance with Regulatory Guide 1.41, (Preoperational Testing (14.2.8) of Redundant On-Site Electric Power Systems to Verify Proper Load Group Assignments), Positions C.2 and C.3, abstracts of preoperationaT tests involving sources of power to vital buses should address the following:
1.
Full-load testing, or extrapolation to full-load testing conditions, should be accomplished.
4 2.
Buses and related loads not under test should be monitored to -
verify the absence of voltage.
4 3.
Verify absence of cross-ties between units which could degrade emergency power on one unit due to testing on the other unit.
640.20 The 125-V dc Preoperational Test abstracts (FSAR Subsection (14.2.8) 14.2.8.1.69 and 14.2.8.1.74) should address the following:
1.
The individual cell limits should be checked following the discharge test to ensure that they are within lipits
[Regulato'ry Guide 1.68, Appendix A.I.g(4)].
2.
Incorporate testing to verify that at the minimum and maximum
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design battery voltages, required Class IE loads can be started and operated. The battery chargers should not be put in use until after the 1E loads have started (IEEE 308-1980). For more information on problems with maximum battery voltage t
conditions, see I&E Information Notice 83-08, March 9, 1983.
640.21 The' Reactor Protection System Preoperational Test abstract (FSAR (14.2.8)
Subsection 14.2.8.1.85) should provide assurance that a manual reactor trip will cause both removal of voltage from the undervoltage trip coil as well as energization of the shunt trip coil (see I&E Bulletin 83-01, February 25, 1983).
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7 640.22 The Reactor Trip and ESFAS Response Time Test abstract (FSAR (14.2.8)
Subsection 14.2.8.1.106) should include or reference testing that will (Regulatory Guide 1.68, Appendix A.1.c):
1.
Account for delay times of process-to-sensor hardware (e.g.,
instrument lines, hydraulic snubbers).
2.
Provide assurance that the response time of each primary s;ensor is acceptable.
3.
Provide assurance that the total reactor protection system response time is consistent with the accident analysis assumptions.
NOTE:
Item 2 can be accomplished by measuring the response time of each sensor during the preoperational-test, stating that the response time of each sensor will be measured by the manufacturer within two years prior to fuel loading, or describing the manufacturer's certification process in sufficient detail for use to conclude that the sensor response times are in accordance with design.
640.23 The Rod Drop Time Measurement Test abstract (FSAR Subsection (14.2.8) 14.2.8.2.14) should include retest (>3 times) of those control rods whose drop time falls outside the two-sigma limit (Regulatory Guide 1.68, Appendix A.2.b).
640.24 The RCS Sampling for Core Loading Test abstract (FSAR Subsection (14.2.8) should include appropriate acceptance criterion.
640.25 The Load Swing Test abstract (FSAR Subsection 14.2.8.2.27) should (14.2.8) be accomplished at 25%, 50%, 75%, and 100% of full power (Regulatory Guide 1.68, Appendix A.5.h.h).
640.26 The Remote Shutdown Test abstract (FSAR Subsection 14.2.8.2.45)
(14.2.8) should address the following (Regulatory Guide 1.68.2, Initial Startup Test Program to Demonstrate Remote Shutdown Capability for Water Cooled Nuclear Power Plants):
1.
The test abstract should state that plant systems are in the normal configuration with the turbine-generator in operation (Position C.3).
2.
The test should demonstrate that the plant can be maintained at stable hot standby conditions for at least 30 minutes (Position C.3.b).
640.27 The Loss of Offsite Power at Greater Than 10-Percent Power Test (14.2.8) abstract (FSAR Subsection 14.2.8.2.46) should state that the loss-of-power condition is maintained long enough (>30 minutes) for conditions to stabilize (Regulatory Guide 1.68, Appendix A.5.j.j).
8 640.28 The response to Item 640.1 states that the Primary and Secondary (14.2.8)
Chemistry Test abstract (FSAR Subsection 14.2.8.2.49) will not be included in the initial test program.
Either modify the response to Item 640.1 and provide this test abstract, or modify FSAR Subsection 1.9.68.2 to provide technical justification for the exception to Regulatory Guide 1.68, Appendix A.4.h and A.S.a.a).
640.29 The Plant Trip from 100-Percent Power Test abstract (FSAR (14.2.8)
Subsection 14.2.8.2.53) should state that the trip is initiated by a direct electrical signal such that the turbine-generator will be subjected to the maximum credible overspeed condition (Regulatory Guide 1.68, Appendix A.5.1.1 and A.S.n.n).
640.30 Regulatory Guide 1.68, Revision 2, Appendix A.1.a(2), A.1.e, A.4.p.
(14.2.8) and A.5.t prescribe testing for various valves. Modify appropriate FSAR Subsection 14.2.8 test abstracts to provide for a more complete demonstration of the operability of pressurizer power operated relief and safety valves, main steam line relief and safety valves, and main steam bypass valves. Such testing should include verification that:
1.
Response times, and open and reclosure setpoints are checked.
2.
Open and reclosure setpoints for all relief valves are checked at temperature.
3.
The capacity of the pressurizer power operated relief valves and the power operated atmospheric relief valves is consistent with the_ accident analysis assumptions for both the minimum and maximum capacity conditions.
When referenc'ing bench tests instead of performing installed capacity checks, technical justification should be provided.
Where valves are not tested in-situ with the process fluid, testing should be conducted to verify that discharge piping is clear and will not choke or produce back-pressure affecting set-reset pressures and capacities of the valves.
640.31 It is important that motor operated valve torque switches be set at (14.2.8) the manufacturer's recommended values to ensure that the valves will operate under accident conditions (I&E Information Notice 84-10).
If preoperational testing is conducted under low differential pressure conditions, it is possible that torque switch settings may have been reduced to prevent applying excessive force that could cause the valve to jam in the closed or open position during testing. Appropriate test abstracts (FSAR Subsection 14.2.8) should be modified to commit to:
1.
Ensure that torque switch settings are at the manufacturer's recommended values prior to the end of preoperational testing.
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Ensure that testing of valve operability is conducted with the torque switch settings at the required values. This may mean repeating tests when at rated differential pressure if lower torque switch settings were used for earlier testing.
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640.32 Our review of the initial test program description disclosed that (14.2.8) the operability of several of the systems and components listed in Regulatory Guide 1.68 (Revision 2) Appendix A may not be adequately demonstrated by the initial test program.
Expand FSAR Subsection 14.2.8 (Individual Test Descriptions) to address the following items:
NOTE:
Inclusion of a test description in FSAR Chapter 14 does not necessarily imply that the test becomes subject to FSAR Chapter 17.
{ Quality Assurance) controls. Certain tests to be performed prior to fuel loading to verify. system operability may be referred to as
" acceptance tests" to distinguish them from "preoperational tests" subject to FSAR Chapter 17 test control.
Preoperational Testing R.G. 1.68 FSAR Appendix A Section Description 1.d.7 10.2.2 Extraction nonreturn valves 1.d.9 9.2.6 Condensate storage facility 1.e.5 10.3.2 Steam Extraction System i
1.e.6 10.2.2 Main stop, control, intercept, and intercept stop valves 1.e.7 10.4.1 Main condenser hotwell level control system 1.e.11 10.4.10 Condensate and feedwater chemical injection system
' 1.1.21 Containment penetration cooling system tests 1.j.17 10.4.7' Feedwater heater temperature, level, and bypass control systems
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1.1.4 11.5 Isolation features for steam generator blowdown
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10 1.1.6 11.5 Isolation features for ventilation systems 1.1.7 11.5 Isolation features for liquid radwaste effluent systems 1.m.1 9.1.3, 11.5 Spent fuel pit cooling system tests of high radiation alarms and low water level alarms 1.m.3 9.1.4 Operability and leak tests of sectionalizing devices and drains and leak tests of gaskets or bellows in the refueling. canal and fuel storage pool 1.m.4 9.1.4 Dynamic (100%) and static (125%) tests of cranes, hoists and associated fuel storage and handling systems.
1.n.5 9.3.2 Turbine plant water sampling systems 1.n.8 Seal water systems 1.n.15 Shield cooling systems 1.0.1 9.1.5 Polar crane dynamic (100%) and static
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Initial Fuel Loading and Precritical Tests 2.b Control rod decelerating devices Low power testing 4.d Adequate overlap of source-and intermediate-range neutron instrumentation 4.j Containment ventilation operability with RCS at rated temperature 4.k MSIV operability and response time tests at rated temperature (see Item 640.02) 4.n Computer Power Ascension Tests
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Provide a preoperational test description or, on those penetrations -
where coolers are not used, provide a startup test description that will demonstrate that concrete temperatures surrounding hot penetrations do not exceed design limits.
5.c.c Gaseous and liquid radwaste systems 5.f.f Ventilation and air conditioning systems 5.g.g ATWS systems which may be installed in 4
the future 5.k.k Loss of or bypass of feedwater heaters 640.33 List and provide technical justification for any tests or portions -
(14.2.8) of tests described in FSAR Chapter 14 which you believe should be exempted from the license condition requiring prior NRC notification of major test changes to tests intended to verify the proper design, construction, or performance of systems, structures, or components important to safety [ fulfill General Design Criteria (GDC) functions and/or are subject to 10 CFR 50 Appendix B Quality Assurance requirements).
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VEGP-FSAR-Q Question 640.1 Either supply-the test abstracts identified as "later" or l(
provide a schedule for submitting the information.
Response
The only outstanding test abstract in this section was paragraph C.
14.2.8.2.49, the primary and secondary side chemistry test.
This test abstract has been deleted, since there will not be such a test and procedure in our initial test program.
The objectives of this test will be accomplished in the preoperational testing phase and in the startup test reactor system sampling for core loading.
In addition, technical specifications or administrative procedures will dictate other requirements for plant chemistry.
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