ML20197A673
| ML20197A673 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 03/03/1998 |
| From: | Joshua Wilson NRC (Affiliation Not Assigned) |
| To: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 9803090345 | |
| Download: ML20197A673 (16) | |
Text
_ _ _ _ _ _ _ _
March 3,1998 Mr. Nicholas J. Liparuto, Manager Nuclear Cafety and Regulatory Analysis Nuclear and Myanced Technology Division Westinghouse Electric Corporation P.O. Box 35ti Pittsburgh, PA 15230
SUBJECT:
OPEN ITEMS IN THE AP600 DESIGN CERTIFICATION REVIEW
Dear Mr. Liparuto:
As a result of the Nuclear Regulatory Commission staff's continuing review of the AP600 design certification application, the Quality Assurance and Maintenance Branch has prepared the enclosed status report on the AP600 Initial Test Program. This report updates the report provided on January 7,1998 and identifies four open items and one confirmatory item that require resolution by Westinghouse before the staff can complete its review. If you have any questions regarding this request, please contact me at (301) 415 3145.
Sincerely,
- original signed by
Jerry N. Wilson, Senlof Policy Analyst Standardization Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003
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Mr. Nicholas J. L!paruto Docket No.52-003 l Westinghouse Electric Corporation AP600 cc: Mr. B. A. McIntyre Mr. Russ Bell Advanced Plant Safety & Licensing Genior Project Manager, Programs Westinghouse Electric Corporation Nuclear Energy Institute Energy Systems Business Uriit 1776 l Street, NW i P.O. Box 355 Suite 300 Pittsburgh, PA 15230 Washington, DC 20006-3706 J
Ms. Cindy L. Haag Ms. Lynn ConNr Advanced Plant Safety & Licensing Doc-Search Associates Westinghouse Electric Ccmoration Post Office Box 34 Energy Systems Business Unit Cabin John, MD 20818 Box 355 Pittsburgh, PA 15230 Dr, Craig D. Sawyer, Manager Advancad Reactor Programs Mr. Sterling Franks GE Nuclear Energy U.S. Department of Energy 175 Curtner Avenue, MC-754 NE 50 San Jose, CA 95125 19901 Germantown Road Germentown, MD 20874 Mr. Robert H. Buchholz GE Nuclear Energy Mr. Frank A. Ross 175 Curtner Avenue, MC-781 U.S. Department of Energy, NE 42 San Jose, CA 95125 Office of LWR Safety and Technology 19901 Ger'nantown Road Barton Z. Cowan, Esq.
Germantown, MD 20874 Eckert Seamans Cherin & Mellott 600 Grant Street 42nd Floor Mr. Charles Thompson, Nuclear Engineer Pittsburgh, PA 15219 AP600 Certification NE.50 Mr. Ed Rodwell, Maneger 19901 Germantown Road PWR Design Certification Germantown, MD 20874 Electric Power Research Institute 3412 Hillview Avenue Mr, Robert Maiers, PE. Palo Alto, CA 94303 Pennsylvania Department of Environmental Protection Bureau of Radiation P' 4ection Rachel Carson State (J, ice Building P.O. Box 8469 Harrisburg, PA 17105-8469
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260,140F - Open items in the initlal Test Program
Background:
By letter dated January 7,1998, the staff provided Westinghouse with the results of its review of all outstanding AP603 Glandard Safety Analysis Report (SSAR) Chapter 14, initial Test Program open items being tracked in the Open item Tre$ lng System (OITS). As a result of this review, nine open items and one confirmatory item were identified.
By letters dated January 23 through 29,1998, Westinghouse provided its response to the staff's January 7,1998 letter. Most of the SSAR changes described in these letters were subsequently incorporated into Revision 20 of the SSAR, dated February 6,1998. Therefore, this status report encompasses the acceptability of changes incorporated in Chapter 14 as a result of Revision 20 to the SSAR as well as those for which Westinghouse has proposed a solution to be inciuded in a future revision to the S' ' R (Confirmatory).
OlTS 1162/DSER Open item iu.4.71(RAI 410.263)
In the DSER, the staff found that Westinghouse should provide procedures for testing feedwater hammer occurrence. Westinghouse responded in their August 13,1996 letter that Subsection 14.2.9.1.7, Expansion, Vibration and Dynamic Effects Testing," was revised to include :esting to start /stop stariup feedwater to the steam generators to venfy that unacceptable feedwater hammer does not occur. Stafireview of th:s subsection determined that it does not provide sufficient information for testing feedwater hammer occurrence. Additionally, Subsection 14.2.9.2.2, " Main and Startup Feedwater System," should be modified to include the following, a) perform FW system test and monitor that no effects due to water hammer are detected.
b) check for water hammer noise and vibration using suitable instrumentation.
- c) visual inspection indicates that the integrity of FW piping, support, and feeding have not been violated.
Therefore, OITS 1162/DSER Open item 10.4.71 remained open.
In its May 9,1997, response to the staff, Westinghouse proposed to include testing of dynamic events (e.g. water hammer) for all applicable systems in subsection 14.2.9.1.7.c (including applicable portions of main and startup feedwater piping) to address the NRC comments.
The staff confirmed that Westinghouse has rev! sed Subsection 14.2.9.1.7,
- Expansion, Vibration, and Dynamic Effects Testing,' to specifically address the testing, monitoring and visualinspection for the effects of water hammer on the feedwater system as requested.
However, these changes will be evaluated in conjunction with Westinghouse's pending response to RAI 410.263, in its January 29,1998, response to RAI 410.263, Westinghouse clarified that testing described
, in subsections 14.2.9.1.7 and 14.2.10.4.18 meet the requirements of Branch Technical Position
, (DTP) ASB 10-2, ' Design guidelines for Avoiding Water Hammers in Steam Generators."
Westinghouse also proposed to modify Subsections 10.4.7.4.3,10.4.9.4.314.2.9.1.7 and 14.2.10.4.18 to clarify that 10sts to monitor Ior the occurrence of water haramer are conducte'1 having no detectica of water hammer effects as the acceptance criteria. Based upon its rev6v of this proposal, however, tha staff conc!uded that Westinghouse is not proposing to subject the AP600 to the effects of a loss of normal feedwater transient as prescribed in BTP ASB 10-2.
Therefore, OITS 1162/DSER Open item 10.4.71 (RAI 410.263) remains open.
J .
-2 l
OITS 1244/D3ER Open item 14.2.84(RAI 260.26)
In the DSER, the staff found that Westinghouse should provide testing of the main control room
- emergency habitability system r>n subsequent AP600 plants. Westinghouse responded in their August 13,1996 letter that Subsection 14.2.9.1.6, " Main Control Room Emergency Habitabuity System Testing, was revsed to inclu6e appropriate testing for each pin.nt, but that a long-term demonstration of this system would be conducted only for the first plant.
Staff review of this subsection determined that sufficient assurance does not exist to conclude
- that the heat l') ads in the main control room area are identical for all AP600 plants. Therefore, Subsection 14.2.9.1.6 should be modified to include applicability of this testing to subsequent AP600 plants, or Appendix 1 A in the SSAR should provide appropriate justification for this ,
exception to RG 1.68, Appendix A, item 1.n.(14)(f). OITS 1244/DSER Open item 14.2.8-6 remained open.
1
, The AP600 does not provide active, safety related HVAC for the main control room, l&C .
l t.quipment rooms, and class 1E de equipment rooms. The habitability of the main control rooms
- _ is provided by operation of the MCR emergency habitability system, and by the passive heat ;
sinks associated with the main control room structure. Likewise, the environmental conditions
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i j- that the qualified l&C equipment and class 1E equipment will be exposed to are based on the_
i passive heat sinks associated with the building and structures that house this equipment.
In its May 9,1997, response to the staff, Westinghouse stated the following: 1 1
"In the AP600, a design basis heatup analysis of the main control room, l&C equipment rooms, and class 1E dc equipment rooms is performed, and the results are discussu 1 SSAR Section
-6.4. This analysis assumes maximum bounding heat loads for the equipment that could be -
located in the main control room and equipment rooms. The AP600 Certified Design Material for 4
the Main Control Room Emergency Habitability System (Section 2.2.5,-ltem Sc, and item oc in Table 2.2.5-4) specifies that an evaluation will be performed using as-built information ind heat loads from installed equipment for the 1) MCR, li) l&C equipment rooms, lii) Class 1E oc equipment rooms. In addition, this evaluation considers the as built passive heat sinks
- associated with these rooms, as specified in Certified Design Material Section 3.3, Nuclear
, Island Building Structures. The acceptance criteria for this heat sink capacity analysis results are that: _1) the temperature rise for the MCR is less than or equal to 15 F for the 72-hour period; li) the maximum temperature for the 72-hour period for the l&C rooms is less than 125 F; lii) the maximum temperature for the 72-hour period for the Class 1E de equipment rooms is less than or equal to 125' F. This evaluation ensures that the as built information for the pertinent buildings and structures, as well as the as-built MCR equipment and l&C and class _1E heat
. loads are less than that assumed in the design basis heatup analysis for the MCR and the-safety-related equipment rooms noted. .
The first plant only test specified in i4.2.9.1.6 is a test of the long term heatup characteristlcs of the main control room, l&C and class 1E equipment rooms. It is performed to demonstrate the heatup characteristics of these rooms when they are subjected to a known heat load. This test can be used to provide date for comparison to the design basis analyses. However, testing is
3 not required on subsequent plants, since these plants are required to be built to the requirements specified in the Certified Design Material. As a passive heatup of these rooms is not dependent on the proper cperation of a system, but is rather a function of the heat loads and passive heat sinks provided in the design, a verification of these parameters (via the ITAAC ,
process)is sufficient to verify the safety of an AP600 built to the specifications contained in the <
Certified Design Material."
Proposed AP600 SSAR Changes An exception to RG 1.68, f rpendix A,8 tem 1.n.(14)(f) has been added to SSAR Appendix 1A that states this test needs to be performed for the first plant only provided the det,ign basis heat loads used as assumptions in the heat sink capacity analysis bound the actual as built information and heat loads.
The staff is evaluating Westinghouse's proposal to perform first plant only testing of long term performance of the main control room habitability system on the basis that requirements in the certified design material (CDM) provide adequate assurance that future plants will comply with the design and performance requirements of the first plant. However, during preliminary discussions on this issue, Westinghouse was informed that a "filst plant only" test approach is unacceptable.
i While the staff agrees Wat "The ability of the habitability system to maintain the main control l room environment as we'l as temperatures in the protection and safety monitoring system cabirtet and emergency switchgear rooms during a long term loss of the nuclear Island l nonradioactive ventilation system may be verified with a limited duration test (emphasis added)."
l The staff does not agree that such testing: (1)is so impractical or burdensome that it should be performed on the first olant only, (2) should not include soecific verification and duration acceptance criteria. Therefore, UlTS 1244/DSER Open item 14.2.8-6 (RAI 260.26) remained open.
In its October 23,1997 response to the staff, Westinghouse stated that Subsection 14.2.9.1.6,
- Main Control Room Emergency Habitability System Testing,' would be revised to require testing of the main control room habitabihty (item e) as part of tne preoperational testing for all plants. In addition, SSAR Section 6.4 would be revised to specify the criteria for air quality and temperature. This test would be specihed to be performed for a sufficient duration to verify that criteria are met at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Testing to verify that protection and safety monitoring system cabinet and emergency switchgear rooms heatup at a rate consistent with the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> temperature limit criteria (item f), would be revised to be performed as a preoperational test for all plants The staff finds that the acceptance criteria changes to subsection 14.2.9.1.6, (items (e) and (f)],
in SSAR Revision 17, do not establish measurable parametnrs for verifying that tha protection and safety monitoring system cabinet and emergency swi'.chgear rooms heatup at a rate consistent with the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> temperature limit criteria. Westinghouse has modeled the Main Control Room (MCR), the protection and safety system cabinets, and the emergency switchgear rooms heatup rate. Therefore, Westinghouse should be able to establish a more specific time
4 duration for the test (i.e. the time frame which is necessary to validate the model).
Absent an objective validation of the heatup rate model, a complete 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> test would be required. Additionally, Westinghouse should remove the exception to RG 1.68, Appendix A, item 1.n.(14)(f) from Appendix 1A of the SSAR.
The staff reviewed Subsection 14.2.9.1.6, SSAR Revision 20, and finds that it adequately establishes measurable parameters for verify;ng that the protection and safety monitoring system cabinet and emergency switchgear rooms heatup at a rate consbtent with the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> temperature limit criteria. However, Westinghouse still needs to include a reference to SSAR Subsection 6.4.3.2 under Subsection 14.2.9.1.0, stems f) and g). Therefore, DSER Open item 14.2.8-6 (RAI 260.26) remains open pending a revised SSAR incorporating these changes.
. OITS 1256/DSER Open item 14.2.0.4 1 In the DSER, the staff found that the preoperational and startup test phase descriptions in Section 14.2.8 of the SSAR did not provide assurance that the operability of several of the systems and components listed in the following RGs would be demonstrated. The test abstracts of Section 14.2.8 of the SSAR should be expanded to address the following items, or Appendix 1 A of the SSAR should be revised to provide technicaljustification for any exceptions taken.
- RG 1.68.2, " Initial Startup Test Program to Demonstrate Remote Shutdown Capability for Water Cooled Nuclear Power Plants"- Preoperational test at,stract 14.2.8.1.94,
- Remote Shutdown," does not provide sufficient detail to verify conformance with the following Regulatory Positions (RP) of RG 1.68.2: '
- Hot Standby Demonstration (RP C.3), including the following:
- With initial conditions of the reactor at a rnoderate power level (10 to 25 percent),
demonstrate that plant systems are in the normal configuration with the turbine generator in operation and with the minimum shift crew
- Using only credited remote shutdown equipment, demonstrate the capability to achieve hot standby status, and maintain stable hot standby conditions for at least 30 minutes.
- Cold Shutdown Demonstration (RP C.4), including the following:
- with the plant at hot standby conditions;
- with the procedurally designated crew positions;
- using only credited remote shutdown equipment, demonstrate the capability to perform a partial cooldown by performing the following actions:
- lower reactor coolant pressure and temperature sufficiently to permit operation of the
5-residual heat removal (RHR) system initiate and control operation of the RHR system
- establish a heat transfer path to the ultimate heat sink reduce reactor coolant temperature approximately 50 F using the RHR system
+
RG 1.68.3, *Preoperational Testing of Instrument and Control Air Systems" Preoperational test abstract 14.2.8.1.6, " Compressed and Instrument Air Systems," does not provide sufficient detail to verify conformance with the following RPs of RG 1.68.3:
After coolers, oil separators, air receivers, and press 9-reducing stations (RP C.2)
Flow, temperature, and pressure ineet design specihcations (RP C.4)
Total air demand with leakage meets design (RP C.5)
- Single failure criterion (RP C.7)
Sudden and gradualloss of system pressure and appropriate response of air power l equipment (RP C.8)
Functional test for increase in the air supply system pressure does not cause loss of operability (RP C.11)
RG 1.140 Preoperational test abstracts 14.2.8.1.28," Containment Air Filtration System,"
I 14.2.8.1.29, " Radiologically Controlled Area Ventilation Test," and 1418.1.88, "High-Efficiency Particulate Air Filters and Charcoal Absorbers" do not provide sufficient detail to verify confonnance with the following RP of RG 1.140.
heaters (RP C.3.a)
- pre 9!!ers (RP C.3.m)
HEPA filters DOP tests (RPs C.3.b and C.S.c) ductwork (RP C.3.f) fans and motors mounting and ductwork (RP C.3 l)
- dampers (RP C.3.1) es 7tber sections / cells and activated charcoal (RPs C.3.h and C.S.d)
These issues were previously identified by the staff in Q260.31. This was identified in the DSER as Open item 14.2.8.4 1.
In ite August 13,1996 response to the NRC, Westinghouse stated the following:
" Subsection 14.2.9.1.12 has been revised to include testing to verify the ability to initiate actuation signals to the systems / components required for reactor shutdown from the remote shutdown workstation. Note that the AP600 remote shutdown workstation provides the operator l
s
- 6 with the same capability to maintain the plant at hot shutdown conditions, or to cool the plant down; as is provided from the main control room. Therefore, the operttor does not need to perform manual actions or operate equipment from local control panels. In addition, test abstracts for the instrument and compressed air system and appropriate HVAC systems have been revised.
In its November 8,1996 response to Westinghause, the staff concluded that Westinghouse had not satisfactorily revised test abstracts to demonstrate the requested items, in general, the revised test abstracts provide less detail than did their predecessors. A detailed review of the SSAR will be conducted to determins whether the test abstracts accurately reflect appropriate test conditions. Therefore, DSER Open item 14.2.8.4 1 remained ope.1.
In its December 6,1996 response, Westinghouse stated the following: l
' Westinghouse would appreciate specific comments from the staff on the appropriate test abstracts so that we can address the staffs concerns in these areas more readily.
For the instrument and control air systems, and the containment air filtration system, it should be noted that these are non safety systems in the AP600 and therefore may not require as explicit details for testing these systems /'
During its review of Revision 11 of the SSAR, the staff concluded that Westinghouse has satisfactorily address the staffs concerns related to RG 1.140. However, the following issues remain with respect to RG 1.68.2 and RG 1.68.3:
l HG_1&fL2 Section 1.9, Appendix 1 A, states that an exception has been taken regarding testing of the AP600 remote shutdown workstation in accordance with Regulatory Guide 1.68.2. The basis for this exception is the similarily of the remote shutdown station (RSS) to the main control room workstations, the testing of plant control capability from the main control room, and the testing of the RSS controls and indications during pre operational testing.
The RSS testing in the ITP is described in Subsections 14.2.9.1.12 and 14.2.9.2.12.
l Sut'section 14.2.9,1.12, Protection and Safety Monitoring System Testing," tests, in part, manual reactor trip capability from the RSS, and also tests the processing of manual actuation commands from the RSS to the protection logic cabinets through simulated command inputs to the logic cabinets and simulMed logic cabinet outputs on component ttatus to the RSS.
Subsection 14.2.9.2.12 "R : Control System Testing," provider testing of RSS control function 3 based on simulated inputs at the RSS and verification of proper outout through contac' operation, component actuation, or electrical test.
While similarity of the RSS workstations to those in the main control room, and successful testing of the main control room workstations and individual RSS process signals can provide a certain level of confidence with regard to proper RSS operation, they do not suffice as a replacement for integrated control system tecting of the RSS. In addition, although the control room and RSS workstations may be similar, the working environment is different to the operator
7 from V.at of the control room which is the normal workspace. The operators should demonstrate the ability to perform plant controlin an abnormal work environment with the minimum set of controls and indications available under postulated control room evacuation scenanos. The Section 14 test abstracts should therefore be modified to demonstrate the remote shutdown capability of the plant in accordance with RG 1.68.2.
RG 1.68.3 During the March 21,1995 meeting, Westinghouse committed to resolving RAI 410.1tii (Item No. 244) by including pre operational testing as described in RG 1.68.3, "Preoperational Testing of Instrument and Control Air Systems"in Subsection 14.2.9.4.10, " Compressed and instrument Air System Testing." Specifically, the following information stil! needs to be added to the test abstract.
- a. All safety related pneumatically operated valves should 1:o v?rified to fallin the position specified in SSAR Table 9.3.1 1 upon a complete and sudden loss of instrument air pressure and a gradual loss of instrument air pressure,
- b. The instrument air system should be functionally tested to ensure credible failures resulting in an increase in instrumer,t air system pressure will not cause loss of operability.
I
- c. The instrument air system air quality shou;d be tested to meet ANSl/ISA S7.3, " Quality Standard for Instrument Air."
- d. While at instrument air system normal steady state conditions, if practical, simultaneously operate those plant components requiring large quantities of instrument air for operation, to verify pressure transients in the distribution system do not exceed acceptable values.
j e. Verify that the total air demand at normal steady state conditions, including leakage from the 1 systems, is in accordance with design,
- f. Additionally, the test abstract should include the following statements:
" Demonstrate the operability of the air compressor dryers and filters, intercoolers, aftercoolers, moisture separators, and air receivers."
" Verify appropriate differential pressures (e.g., delta P across prefilters and afterfilters)."
. ' Verify relief valve settings."
Therefore, OITS 1256/DSER Open item 14.2.8.41 remained open, in its May 9,1997, response to the staff, Westinghouse stated the following:
1.68.2 A test of the remote shutdown workstation has been added as subsection 14 2.10.4.2'1.
9
8 1.68.3 Westinghouse has modified the Compressed and Instrument Air System preoperational test (subsection 14.2.9.4.10) to provide sufficient detail to show conformance to the applicable portions of RG 1.68.3.
The staff finds Revision 13 to SSAR Section 14.2.10.4.28, ' Remote Shutdown Workstation,'
acceptable. However, the exception to RG 1.68.2 in Appendix 1A of the SSAR should be deleted based on the new test for the remote shutdown station as described in Subsection 14.2.10.4.28 of the ITP.
Revision 13 to SSAR Subsection 14.2.9.4.10 adequately incorporated the staffs comments on the test abstract with the exception to a specific reference to ANSl/ISA S7.3," Quality Standard for Instrument Air " Nevertheless, the test abstract also states that testing will verify system functions as described in SSAR Section 9.3.1. Subsection 9.3.1.4, " Tests and Inspections,"
cites the standards for air quality, including ANSI /ISA S7.3. Therefore, Subsection 14.2.9.4.10 is acceptable. On this basis, OITS 1256/DSER Open item 14.2.8.41 remained open pending revision to the exemption in Appe'idix 1 A of the SSAR for Regulatory Guide 1.68.2.
In its October 23,1997, rcaponse to the staff, Westinghouse stated that the exception in Appendix 1 A of the SSAR for RG 1.68.2 would be deleted based on the previously revised testing for the remote shutdown station as described in Subsection 14.2.10.4.28.
The staff confirmed that Westinghouse has deleted the exception to RG 1.68, Appendix A.6, regarding the remote shutdown station from SSAR Section 1.9, Appendix 1 A, but inadvertently (apparently)left intact the same exception to RG 1.68.2.
While Westinghouse has addressed the staffs concerns with respect to SSAR Subsection 14.2.9.4.10 as described above, Westinghouse has not satisfaciority addressed the staffs concerns identified in RAI 410.308. Specifically, Westinghouse's changes to Subsection 14.2.9.4.10 only clarify the reference to SSAR Section 9.3.1 and do not address the inconsistencies it, the testing enteria between Sections 3.9.6,9.3.1.4, and 14.2.9.4.10, as described in RAI 410.308.
Section 14.2.9.4.10 references 9.3.1.4 which specifies air operated valve testing in accordance with RG 1.68.3. As noted in 410.308, Section 14.2.9.4.10 states that air operated valves in safety systems will be tested as part of the test program for the individual system, and the test abstract for the individual system typically reference Section 3.9.6 for valve testing requirements which does not address RG 1.68.3 testing.
The issue identified in 410.308, therefore, remains unaddressed. Westinghouse may resolve this issue in several ways: (1) Section 3.9.6 could be revised to address air operated valve testing in accordance with RG 1.68.3, (2) the individual test abstracts for systems with safety related air operated valves could be revised to reference Subsection 9.3.1.4 for air-operated valve testing requirements, or (3) Subsection 14.2.9.4.10, Ceneral Test Method and Acceptance Criteria d), could be revised to state the following:
"d. Testing is performed to verify the fail safe positioning of safety-related air operated valves for sudden loss of instrument air or gradualloss of pressure as described in SSAR i
s ,
9 Section 9.3.1.4."
in its January 23,1998, response to the NRC, Westinghouse proposed to revise Subsection 14.2.9.4.10 to reference SSAR 9.3.1.4 as suggested by the staff.
The staff finds that Subsection 14.2.9.4.10, SSAR Revision 20, adequately addresses the . sues identified in DSER Open item 14.2.3.4-1 and RAI 410.308 and is, therefore, acceptable.
However, SSAR Appendht 1 A needs to be revised to Indicate conformance of the AP600 design to RG 1.68.2 (inadvertently deleted from Appendix 1 A in Revision 20 to the SSAR). Therefore, DSER Open item 14.2.8.41 remains open pending incorporation of this change in a revised SSAR.
. OITS 5321/Q260.93 Section 14.2.5, " Utilization of Reactor Operating and Testing Experience in the Development of Test Program," rtates that "special tests" used to establish a unique performance parameter of the AP600 design that will not hange from plant to plant are to be performed on the first plant only. Westinghouse should re.. e this section to include the following:
- a. Selection (screening) crheria used by Westinghouse to identify such special tests
- b. Provisions or programmatic controls that will be utilized by Westinghouse and/or the COL applicant to establish that system configuration or design engineering changes do not invalidate previous special test results.
1 in its May 9,1997, response to the staff Westinghouse addressed these issue as follows:
- a. The screening criteria that was used by Westinghouse as presented in Section 14.2.5 has been revised as follows:
Special tests to further establish a unique phenomenological performance parameter of the AP600 design features beyond the testing performed for Design Certification and that will not 5nge from plant to plant, are performed for the first plant only. Because of the
,ndardization of the AP600 design, these special tests (designated as first plant only tests) re not required on follow plants. These first plant only tests are identified in the individual test descriptions. (See subsections 14.2.9 and 14.2.10.)
- b. This item is addressed by the provisions 10 CFR Part 52.47 which stipulates that changes to Tier i documentation requires new rulemaking, ud that changes to Tit r 2 will require a 50.59 type evaluation th.t will assess the impact to the SSAR including Chapter 14.
v .anges identified that impact these special tests will be identified, and tests may be modified or repeated as appropriate.
Based on this response, the staff found the following:
- a. The revised criteria is not responsive to the staff request for a " screening" or selection criteria. Westinghouse should include clear, concise, and objective criteria that establishes
s '.
10-the basis for designating first plant only tests. Alternatively, given that the number of first plant only tests is limited, Westinghouse could identify the individual tests in Section 14.2.5 and the associated justification for the first plant only designation. This approach would allow the staff to review and approve the justifications, as opposed to generic selection criteria that may be difficult to develop given the diversity of the systems involved and the parameters being tested.
- b. While the staff agrees a change to Tier 1 information would require rulemaking in accordance with the requirements of 10 CFR Part 52.47, "special tests" or first plant only test abstracts are, bv definition, not part of the AP600 ITAAC, i.e., not Tier 1 information.
Themfere, Westinghouse should describe in Section 14.2.5 of the SSAR how the control mechanisms for Tier 2 infonnation would establish that syskn configuration or design engineering changes do ru invalidate previous special test results. The issue here is not only control of changes, but verification that the design, construction, fabrication, and operation of future plant systems are consistent with those of the prototype plant for which first plant only testing is proposed. Westinghouse should describe the general approach that is to be followed to ensure that future plant configurations are consistent with the design, construction, operation, and testing performed for the first plant. On these bases, OITS 5321/0260.g3 remained open, in its October 23,1997, response to the staff Westinghouse addressed these issues as follows:
(a) Section 14.2.5 has been modified to include a list of first niant only tests. The general criteria for designation of certain tests as first plant only is provided in SSAR section 14.2.5.
The following is the detailed justification by Westinghouse for designating these tests as first plant only.
IRWST Heatup Test (14 2.9.1.3 ltem (h))
During e , vational testing of the passive' core cooling system, a natural circulation test of the passive . ' val heat removal (PRHR) heat exchanger is conducted (item f). For the first plant only, thermocouples are placed in the IRWST io observe the thermal profile developed during the heatup of the IRWST water dunng PRPR heat exchanger operation. This test will be usefulin confirming the results of the AP600 Design Certification Program PRHR tests with regards to IRWST mixing, and is useful in quantifying the conservatism in the Chapter 15 transient analyses.
Due to the standardization of the AP600, the heatup and thermal stratification characteristics of the IRWST will not vary from plant to plant. The PRHR heat exchanger design, and the size and configuration of the IRWST are standardized, such that the heatup characteristics will not significantly change from plant to plant.
Therefore, since the phenomenon to be tested (i.e. heatup and mixing characteristics of the IRWST) will not vary significantly from plant to plant due to standardization, a first plant only test of the IRWST heatup chracter", tics is justified.
Core Makeup Tank Heated Recirculation Tests (14.2.9.1.3 Items (k) and (w))
)
During preoperational testing of the passive core cooling system, tests of the core makeup tanks are performed to venfy the CMT inlet and inlet piping resistances. In addition, cold draining tests of the CMTs are conducted that verify proper operation of the CMTs. For the first plant only, two additional CMT tests are conducted during hot functional testing of the RCS. These tests are a natural circulation heatup of the CMTs followed by a test to verify the ability of the CMTs to transition from a recirculation mode to a draindown mode while at elevated temperature and pressure.
Operation of the CMTs under natural circulation is conducted on the first plant only for the following rearons:
Natural circulation of the CMTs will not vary from plant to plant, provided that the other verifications discussed above are performed as specified.
Natural circulation testing of the CMTs was extensively tested in the various Design Certification Tests including the CMT separate affects test and the SPES2 and OSU integral tests.
Performance of this test results in significant thermal transiento on Class 1 components including the CMTs and the direct vessel injection nozzles, ADS Blowdown Test (14.2.9.1.3 Item (s))
During preoperational testing of the passive core cooling system, the resistance of the automatic depressurization system Stage 1,2,3 flowpath(s)is verified. For the first plant only, an automatic depressurization blow down test is performed. This test is performed during hot functional testing of the RCS, and results in a significant blowdown of the RCS into tne IRWST. This tests verifies proper operation of the ADS valves, and demonstrates the proper operation of the ADS spargers to limit the hydrodynamic loads in containment to less than design limits. This test is performed on the first plant only for the following reasons:
The operation of the ADS, and the resultant hydrodynamic loads will not vary from plant to plant.
Full scale automatic depressurization testing was performed in the AP600 Design Certification Program. Testing was conducted to conservatively bound ADS flow rates and resultant hydrodynamic loads that will be experienced by the plant during ADS operation.
Performance of this test results in significant thermal transients on Class 1 components
} including the primary components. It also results in hydrodynamic loads in containment I incluaing the IRWST.
Pressurizer Surge Line Stratification Evaluation (14.2.9.1.7 Item (d))
l As part of the AP600 conformance to NRC Bulletin 88-11, a monitoring program will be implemented by the Combined License holder at the first AP600 to record temperature
12 -
distributions and thermal displacements of the surge line piping riuring hot functional testing and during the first fuel cycle, as discussed in SSAR section 3.9.3.
Reactor Vessel Internals Vibration Testing (14.2.9.1.9)
The preoperational vibration test program for the reactor internals of the AP600 conducted on the first AP600 is consistent with the guidelines of Regubtory Guide 1.20 for a comprehensive vibration assessment program. This program is discussed in SSAR section 3.9.2.
Natural Circulation Tests (14.2.10.3.6,14.2.10.3.7)
Natural circulation tects using the steam generators and the passive residual heat removal heat exchangers are performed at low core power during the staitup test phase of the initial test program for the first AP600 plant. This testing of the heat removal systems meets the intent of the requirement to perform natural circulation testing and the results of this testing is factored into the operator training. Justification for performing these natural circulation tests for the first plant only is provided in SSAR section 1.9.4.
i l
Load Follow Demonstration (14.2.10.4.22)
A load follow demonstration test is not required by Regulatory Guide 1.68. However, the AP600 performs load follow with grey rods, as opposed to current Westinghouse PWRs which manipulate RCS boron concentration to perform load fohow operations. Therefore, Westinghouse has included a proof of principle load follow demonstration for the first AP600 plant, to demonstrate the ability of the AP600 plant to follow a design basis daily load follow cycle.
(b) In response to item (b), section 14.2.5 has been modified to include a description of the general approach that is to be followed such that future plant configurations are consistent with the design, construction, operation, and testing performed for the first plant, as recommended in part (b) of the RAl.
Based on this response, the staff found that:
(a) Westinghouse's response to item (a)is acceptable with respect to SSAR Subsections 14.2.9.1.3 Item (h),14.2.9.1.7 Item (d),14.2.10.3.6,14.2.10.3.7, and 14.2.10.4.22.
However, the justifications for the first time only testing should be included in Chapter 14, section 14.2.5, of the SSAR. For subsection 14.2.9.1.9, Westinghouse needs to clarify which portion (s) of the test are to be conducted on the first plant-only.
With respect to subsections 14.2.91.3 Items (k) and (w), and 14.2.9.1.3 Item (s), the staff does not share Westinghouse's confidence that other testing and verific1tions will, in all instances, prevent minor engineering or construction variances from affecting test results obtained on the first plant, or from introducing uncertainties into such results. Absent some empirical data to support such conclusions, the staff is unable to conclude that these tests need not be repeated on subsequent plants, e
s .
13-(b) The staff findt that the changes to Section 14.2.5 as described in item (b), unacceptable.
The changes to Section 14.2.5 describe the approach to address design changes that could affect the applicability of first plant only tests. The staff interprets this change to ,
address only planned design changes, and not the potential variances that can occur in design, construction, fabrication, and operation from one plant to another. The approach described in Section 14.2.5 should also address potential variances discovered during the engineering and construction process, i.e., between the as built plant and the certified design.
In its January 28,1998, response to the NRC, Westinghouse proposed to include justification for first plant-only and first three plant testing under SuasMion 14.2.5 and to revise Subsection 14.2.9.1.3 accordingly. Subsection 14.2.5 would also address potential variances between the as built plant and the certified design disco &d voring the engineering and construction phases.
The staff confirmed thm the new Section 14.2.10.3.7,
- Passive Residual Heat Removal Heat Exchanger (First Plant Only),' provides for natural circulation testing of the PRHR system during startup testing of the initial plant. In addition, all plants are subjected to natural circulation testing of the PRHR during hot functional testing as described in Section 14.2.9.1.3.(e), (f), and (g). The staff finds that these testing provisions, in conjunction with SSAR subsection 1.9.4.2.1, item 1.G.1, and the exception to RG 1.68, Appendix A.4.t in SSAR Appendix 1 A, adequately address natural circulation testing for the AP600 design. Therefore, OITS 5321/Q260.93 is confirmatory pending the revision of Subsection 14,2,5, including justification for first.
plant only and first three plant testing, as described in Westinghouse's January 28,1998 letter to NRC.
OITS 1124/DSER Open item 9.5.1.4 7: In Subsection 9.5.1.4.8, Preoperational Testing," of the DSER, the staff found that additionalinformation was required from Westinghouse to establish the acceptability of the fire protection system (s) preoperational test program in complying with Section C.4.e of BTP CMEB 9.51. This issue was identified as DSER Open item 9.5.1.4-7.
In its August 13,1996, response to the NRC, Westinghouse stated that Subsection 14.2.9.2.8 would be revised to state that the system operates as specified in Subsection 9.5.1 and in appropriate design specifications. These documents identify the applicable NFPA standards for the testing of individual components in the fire protection system. Subsection 14.2.9.2.19 and 14.2.9.4.13 describe testing of the plant lighting and communication systems, respectively. The breathing apparatus provided at the plant and the use of this equipment will be identified by the COL applicant, as part of the fire protedion personnel training.
However, upon reviewing Revision 11 to the AP600 SSAR Chapter 14, Subsection 14.2.9.2.8, the staff concluded that it needed to be modified to encompass testing of the AP600 fire protection system in an integrated manner, i.e., fire doors, fire dampers, smoke control systema, automatic fire detection, underground fire main, fire pumps, automatic suppression systems, electrical isolation devices for non safety related equipment in opposite divisional fire areas, and trained fire brigade. This conclusion was documented in a March 20,1997, NRC letter to Westinghouse.
s e, In its May 9,1997, response to the staff, Westinghouse proposed that SSAR Subsection 14.2.9.2.8 be revised to incorporate the NRC cornments with certain exceptions.
Upon reviewing SSAR subsection 14.2.9.2.8, Revision 17, the staff concluded that it needed
- furtner modifications under General Test Method and Acceptance Criteria, items a) and c) to include pressure testing for the seltimic standpipe water supply, and testing of the HVAC smoke control and exhaust systems section, respectively. This conclusion was documented in a January 7.- 1998. NRC letter to Westinghouse.
In its January 23,1998, response to the staff, Westinghouse provided clarification on test provisions relevant to hydrostatic oressure testing of the seismic standpipe water supply, and proposed to revise subsection 14.2.9.2.8 to include verification of the proper operation of the portions of the HVAC systems used for smoke control and exhaust.
While the staff finds that Subsection 14.2.3.2.8, SSAR Revision 20, adequately addresses the l staff's concerns with respect to verification of the proper operation of the portions of the HVAC l
systems used for smoke control and exhaust, Westinghouse still needs to include _ verification that adeaunte crassure Is available to orovide ef'ective home streams, i.e., a preoperational test that demonstrates system performance in accordance with design, for the seismic standpipe .
water supply as part of this subsectien. Therefore, DSER Open item 9.5.1.4 7 remains open.
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