ML20198R660

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Summary of 971109 Telcon W/Westinghouse to Discuss RAI Responses Related to TS & Sys Level Testing
ML20198R660
Person / Time
Site: 05200003
Issue date: 10/30/1997
From: Huffman W
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9711130345
Download: ML20198R660 (7)


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NUCLEAR REGULATORY COMMISSION

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. [, , , *# October 30, 1997 APPLICANT: Westinghouse Electric Corporation PROJECT: AP600

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCE WITH WESTINGHOUSE TO DISCUSS REQUEST FOR ADDITIONAL INFORMATION (RAI) RESPONSES RELATED TO TECHNICAL SPECIFICATION (TS) AND SYSTEM LEVEL TESTING On October 9,1997, the Nuclear Regulatory Commission (NRC) staff and Westing-house (see Astachment 1) conducted a telephone conference (telecon) concerning RAI responses from a Westinghouse letter dated August 27,1997,(NSD NRC-97-5278). The telecon involved additional discussions on system level testing and other TS related issues. In preparation for the telecon, the NRC had faxed Westinghouse a list of discussion iteras which would form the agenda o for the call (see Attachment 2).

The following is a summary of discussion highlights from the telecon:

RAI 440.667 The Westinghouse response to RAI 440.667 discussos the system icvel operability test requirements of standard safety analysis report (SSAR)

Table 3.9-17. The operability tests will includo measurements of flow resistances for the accumulators, CMTs, in-containment refueling water storage tankheat for the PRHR (IRWST) exc hanger. injection However, therelines, is no and heat transfer discussion in the characteristics SSAR on how the values relate to Chapter 15 analyses. Westinghouse \ I stated that these flow resistances and heat transfer rates are consis-tent with those used in Chapter 15 analyses. The staff stated this information is necessary to complete its safety evaluation and that it (L)Z should be documented in the SSAR. Westinghouse said it would revise SSAR Table 3.9-17 to define the relationship of these values to Chap-ter 15 analyses.

The staff noted that for the IRWST injection line, the flow resistance was different from values cited in inspection, test, analysis, and acceptance criteria (ITAAC). In addition, the PRHR heat exchanger heat transfer value was also different from ITAAC. The staff noted that there is currently no discussion in the SSAR or how the ITAAC flow resistance relate to the Chapter 15 analysis. Westinghouse said that the IRWST line resistance and the PRHR HX heat transfer rates are consistent with Chapter 15 analyses and committed to clarify thit in the Table 3.9-17 notes. The staff also questioned why system level opera-bility tests fail to require any periodic confirmation of the CMT pressure balance line flow resistance and do not measure the complete resistance of the IRWST injection line as is done for ITAAC. Westing-house explained that the CMT balance line is r. simple line with a single  ;

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-?- October 30, 1997 l normally open motor operated gate valve. It's resistance was not included in Table 3.9-17 because it has an ordcr of magnitude less resistance than the discharge line resistance. However, it does prcvide confidence that the balance line resistance is not significantly above its anticipated value. The staff stated that this tvoe of dnformation js important and it should be documented < n the SSAR. Soecd fically. the staff felt that_ Westinohouse should document in the SSAR why the system lgvel testina_did not have to test the flow resistances to the same extent as__in ITAAC. Westinohouse said it would orovide an explanation I _in an VI response (if the staff < ssued a formal RAli but did not feel

,thtt_1,11J information was aooroort ate for the SSAR.

Westinghouse clarified the extent of the IRWST flow resistance testing.

It explained that the IRWST line was flow tested periodically from the IRWST to the squib valve. The only components not flow tested are the squib valves and the injection line from the squib valves to the direct vessel injection (DV!) line. Westinghouse said it would provide clarification in the SSAR as to the extent of the flow resistance testing.

RAI 440.668 The staff discussed the new Actuation Device Test proposed by Westing-house for instrumentation & control related TS surveillances. The staff was concerned that, based on the definition, the TS surveillance could be accomplished by " continuity tests" for all actuated components rather than by verifying the component will actually move. Westinghouse stated that the continuity test was only for the squib valves and that other component actuations (valve repositioning) would be accomplished via manual actuation of the component when performing inservice testing on the valve. The NRC staff did not think this was sufficient and stated that all valves which actuate in response to an engineered safety feature signal should have a tech spec surveillance requirement to verify the valve responds to an actuation signal. The staff noted that the TSs already contain a similar requirement for the containment isolation valves in AP600 TS Surveillance Requirement (SR) 3.6.3.5.

Westinohouse did not aaree to modify the TSs to address the staff's s,pncerns.

Westinghouse agreed to modify Surveillance Requirements 3.3.2.7, 8, and 8 to clarify which applies to valve actuations, which applies to the squib valve continuity test, and which applies to the pressurizer breaker test.

RAI 440.670

+

The staff stated that it has no further concern about the Westinghouse response to RAI 440.C70 based on a followup letter from Wastinghouse dated September 23, 1997.

October 30, 1997 RAI 440.671

  • Westinghouse provided clarification to the staff on the basis for the structure of the ADS valve TS. The staff expressed its concern that the ba:is for the coinpletion times in the RAI response was the standard tech s)ec power-operated relief valve limiting condition for operation w11ch the staff felt had no relationship to the function of ADS. '(LCO)

Westinghouse clarified that the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time was also comparable to STS for any train of a two train ECCS.

The staff noted that because of schedule constraints, it would probably not have time to issue formal requests to Westinghouse for the changes discussed above and that the item; may become FSER open items.

original signed by:

William C. Huffman, Project Manager Standardization Project Dirc::torate Divisimi of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003 ,

Attachment:

As stated cc w/att: See next page DISTRIBUTION w/atts:

Docket File POST R/F TKenyon PUBLIC BHuffman JNWilson JSebrosky- DScaletti DISTRIEUTION w/o atts:

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DFFICIAL RECORD COPY

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Westinghouse Electric Corporation Docket No.52-003 cc: Mr. Nicholas J. Liparulo, Manager Mr. Frank A. Ross Nuclear Safety and Regulatory Analysis U.S. Department of Energy, NE-42 Nuclear and Advanced "echnology Division Office of LWR Safety and Technology Westinghouse Electric Corporation 19901-Germantown Road P.O. Box 355 Germantown, MD 20874 Pittsburgh, PA 15230 Mr. Russ Bell

.Mr. B. A. McIntyre Senior Project Manager, Programs Advanced Plant Safety & Licensing Nuclear Energy Inst'tute Westinghouse Electric Corporation 1776 I Street, NW Energy Systems Business Unit Suite 300 Box 355 Washington, DC 20006-3706 Pittsburgh, PA 15230 Ms. Lynn Connor Ms. Cindy L. Haag Doc-Search Associates Advanced Plant Safety & Licensing Post Office Box 34 Westinghouse Electric Corporation Cabin John, MD 20818 Energy Systems Business Unit Box 355 Dr. Craig D. Sawyer, Manager Pittsburgh, PA 15230 Advanced Reactor Programs GE Nuclear Energy Mr. M. D. Beaumont 175 Curtner Avenue MC-754 Nuclear and Advanced Technology Division San Jose, CA 95125 Westinghouse Electric Corporation One Montrose Metro Mr. Robert H. Buchholz 11921 Rockville Pike- GE Nuclear Energy Suite 350 175 Curtner Avenue, MC-781 Rockville,-MD--20852 San Jose,-CA 95125-Mr. Sterling Franks Barton Z. Cowan. Esq.

U.S. Department of Energy. Eckert Seamans Cherin & Mellott NE-50 600 Grant Street 42nd Floor 19901 Germantown Road Pittsburgh, PA 15219 Germantown, MD 20874 Mr. Ed Rodwell, Manager Mr. Charles Thompson, Nuclear Engineer PWR Design Certification

-AP600 Certification Electric Power Research Institute NE 3412 Hillyiew Avenue 19901 Germantswn Road Palo Alto, CA 94303 Germantown, MD 20874 4

WESTINGHOUSE /NRC AP600-TECHNICAL SPEC!f! CATION RAI RESPONSE TELECCNFERENCE PARTICIPANTS OCTOBER 9, 1997 HABE ORGANIZATION TERRY SCHULZ WESTINGHOUSE CHIP SUGGS WESTINGHOUSE ROBIN NYDES WESTINGHOUSE GENE HSII NRC HULBERT LI NRC BILL EUFFMAN NRC Attachment I-I

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September 22, 1997 T0: Robin ilydos FROM: Bill Huffman SUBJ: AP600 RAI Responses in Westinghouse Letter DCP/NRC0993 Dated 8/27/97 I would like to set up a telephone call with you, Terry Schulz, and whomever else to discuss the subject Westinghouse responses. Gene Hsii still has issues which we may need to turn into additional RAls. However, I would like to discuss them with you first to see if there may be some clarification which can help.

The following items need to be discussed:

RAI 440.667 Regarding Table 3.9-17 a) What are the basis for the cited flow resistances? They are not discussed elsewhere in the SSAR. It is unclear how they relate to Chapter 15 analysis, b) Footnote #3 discusses flow resistance between the CMT and the reactor vessel. What about flow resistance between the cold leg and the CMT?

c) Footnote #4 for the PRHR heat transfer is different from the ITAAC value?

Why not provide an overall heat transfer coefficient? How does the value cited in tech specs or ITAAC relate to Chapter 15 analysis?

d) Footnote #5 discusses the flow resistance of the IRWST injection lines to the injection line check valves. What is the status of the downstream squib valves while this resistance measurement is made? How can a flow measurement be made if the squib valve is installed and intact?

e) Footnotes #5 and #5 state that the IRWST injection line from the check valve to the DVI line and the recirculation portions c,f the injection line are inspected (without operating the squib valves). Why are there not flow resistances for these lines? How are the flow capabilities determined by inspection?

Attachment 2

i RAI 440.668 The staff needs to have a better understanding of the Actuation Device Tests (ADT).

For example; the definition states that the ADT may consist of verification of actual operation but shall, at a minimum, consist of a continuity check.

Does the continuity test apply to squib valves only?

How can a continuity test demonstrate an appropriate response for the device to be actuated (typisally a power operated valve)?

How does inservice testing relate to an ADT7 (e.g.,seenoteinSR 3.3.2.7)

Westinghouse states that SR 3.3.2.7/7/8/9 ADT's verify automatic change of the PCS valves using manual controls? Explain how the revised tech specs accomplishes verification of PCS valves to the actuating signals starting with item 26 of Table 3.3.2-1. For example, where is the list of valves the be actuated by SR 3.3.2.7 defined and how is it tracked for tech spec purposes?

RAI 440.670 Westinghouse stated in its response that the required actions and completion times of Condition F for LCO 3.5.4 in the June 6,1997 markup were correct.

It appears, however, that the revised LCO 3.5.4 continues to reflect the June 18, 1997, submittal. Please explain?

RAI 440.671 The arguments for the ADS tech spec completion times in LCO 3.4.12 are still not convincing to the staff. We need to discuss this LCO in detail, cc: TRQuay BMcIntyre ,

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