ML20209E076

Forwards Draft SER Re FSAR Chapter 14 Concerning Initial Plant Test Program.Test Program Acceptable & Meets Requirements of 10CFR50

ML20209E076
Person / Time
Site:	Satsop
Issue date:	03/01/1985
From:	Russell W Office of Nuclear Reactor Regulation
To:	Novak T Office of Nuclear Reactor Regulation
References
CON-WNP-1371 GL-82-33, NUDOCS 8503200463
Download: ML20209E076 (10)

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Docket No. 50-508 DLZiemann MAR 011985 GRMazetis 1

RABecker j 11EMORANDUM FOR: Thomas M. Novak, Assistant Director HBClayton p for Licensing WGKennedy j,

Division of Licensing FROM: William T. Russell, Acting Director Division of Human Factors Safety i

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SUBJECT:

. DRAFT SAFETY EVALUATION REPORT WASHINGTON NUCLEAR PLANT, UNIT 3 (WMP-3)

I Enclosed is our DSER for the Initial Plant Test Program, FSAR Chapter 14, as amended through Amendment 5. This represents the current status of the review for Section 14.2 for WNP-3 as requested by memorandum from G. W. Knighton, LB No. 3, to Distribution dated January 29, 1985. The Section 14.2 review was performed with the assistance of Battelle Pacific

, Northwest Laboratnries personnel. The Section 14.2 reviewer for PSRB is Richard Becker (X29689).

In addition, we have review responsibility for FSAR Section 13.5.2, Operating and Maintenance Procedures. Although we have not started the review in this area, we have submitted questions to DL to be fonvarded to the applicant related to the 13.5.2 review based on Generic Letter 82-33. These questions were transmitted to DL by memorandum from D. L. Ziemann, PSRB, to G. W. Knigh'.c,, LB No. 3, dated October 12, 1983. He have no additional input for the 03ER in this area. The Section 13.5.2 reviewer for PSRB is W. G. Kennedy (X24578).

The reviewers are not aware of any " Differing Professional Opinions" relating to this review.

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( liiam T. Russell, Acting Director Division of Human Factors Safety

Enclosure:

DSER CC "'Y.C,vauscf ,

. Knighton B. Singh ~

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s DRAFT $AFETY EVALUATION REPORT WNP-3 FSAR CHAPTER 14 -

INITIAL TEST PROGRAM The initial test program encompasses the scope of events that comences with

- completion of system construction and terminates with the completion of power ascension testing. The initial test program is conducted in three separate ,

and sequential subprograms: system lineup testing, the preoperational test program and the startup test program. At the conclusien of these

• subprograms, a unit is ready for normal power operation. The system lineup testing, preoperational, and startup test subprograms are accomplished in the l following five distinct and sequential major phases:

a. Phase I - System Linerp Testing

b. Phase II - Precperational Testing  ;

c. Phase III - Fuel Loading and Post tore Hot Functiiinal Testing ,

d. Phase IV - Initial Criticality and Low Power Physics Testing ,

e. Phase V - Power Ascension Testing System lineup testing includes cleaning and flushing of piping systems and ,

equipment; electrical equipment checks such as insulation resistance measuremetits, phase verification, continuity checks, voltage r, ear.ure:nents, grounding checks, circuit breaker operation and relay operation; initial operation of motors and valves; calibration of instruments; and adjustments of relief and safety valves.

The preoperational test program comences with system / component turr.over from the construction activity to the operations activity, and terminates with the beginning of unit fuel loading. These tests demonstrate, to the extent practicable, the capability of structures, systems, and components te meet performance reautrements, and to satisfy design requirements. To the extent practicable, the cbjectives of the preoperational test program are to:

a. Document the performance and operability of equipment and systems

b. Provide baseelir.e test and operating data on equipment and systems for future rn.ference

c. Operate new eouipment for a sufficient time pericd so that design, manufacturing, and installation defects can be detected and corrected

d. Ensure that plant systems operate together on an integrated basis

e. Familiarize the plant operating, technical, ar.d maintenance personnel with the plant operation

f. Confirm the adcouacy of plant operating and emergency operating p-ccedures.

The startup test program commences with fuel loading, and terminates with the completion of power ascension testing. These tests confirm the design bases and demonstrate, to the extent practicable, that the plant operates 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 to:

a. Accomplish a controlled, orderly, and safe initial core loading

b. Accomplish a controlled, orderly, and safe initial criticality

c. Conduct low pcwer testing sufficient to ensure that design parameters are satisfied, and that safe:y analysis assumptiens are correct or conservative l d. Perform a controlled, orderly, and safe power ascension with requisite testing, terminating at plant rated conditions.

The applicant has made extensive reference to the Combustion Engineering Standard Safety Anslysis Report (CESSAR), Preoperational and startup test l abstracts pertinert to Combustion Engineering's " System 80" Nuclear Steam Supply System (N.'.SS) are contained in CESSAR, as are other NSSS-related l

topics (e.g., s.$ stem descriptions, accident analysis, and Standard Technical Specifications). CESSAR was evaluated in NUREG-0852.

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Our review of Chapter 14 of the applicant's FSAR concentrated on the administration of the test program and the completeness of the preoperational and startup tests. The Safety Evaluation Report which was issued at the completion of the Construction Permit review was reexamined to detennine the principal design criteria for the plant and to identify any specific concerns or unique design features that would warrant special test consideration.

Chapters 1 through 12 of the FSAR were reviewed for familiarization with the facility design and nemenclature. Chapter 15 was reviewed to identify assumptions pertaining to performance characteristics that should be verified by testing and to identify all structures, systems, components and design features that were assumed to function (either explicitly er implicitly) in the accident analyses. Licensee Event Report Sumaries for operating reactors of similar design were reviewsd to identify potentially serious events and chronic or generic prcblems that might warrant special test corsideraticn. Standard Technical Specifications were reviewed to identify all structures, systems, and components that would be relied upon for establi: *.g confomance with safety limits or limiting conditions for operation. Post-TMI related testing requirements were reviewed in conformance with: NUREG-0660, "NRC Action Plan Developed as a Result of the THI-2 Accident;" NUREG-0694, "TMI-Related P.equirements for New Operating Licenses;" ano NUREG-0737, " Clarification of TMI Action Plan Pequirements."

And finally, Startup Test Reports for other Combustien Engineering reactor plants were reviewed to identify problem areas that should be emphasized in the initial test progre.m.

i In determiring the acceptability cf the applicant's test program, the criteria of the Standard Review Plan, NUREG-0800, Section 14.2 were used.

Our review included verificatien of the following features of the initial test progran:

1. The applicart plans to develop test procedures using input from the NSSS vendor, the architect-engineer, the applicant's engineering staff, I

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i and other equipment suppliers and contractors. Operating experiences at similar plants are being factored into the development of the test procedures.

2. The applicant plans to conduct tests using approved test procedures.

Administrative controls 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. The applicant has stated that administrative procedures also cover implementation of modifications or repair requirements identified as being required by the tests and any necessary retesting.

3. The applicant plans to review the results of each test for technical adequacy ano completeness by review groups that include the NSSS vendor and architect-engineer as appropriate. Preoperational test results will be reviewed prior to fuel loading and the startup from each test condition or power level will be reviewed prior to proceeding to the next test condition or power level.

4 The applicant plans to use normal plant cperating and emerpency procedures in performing the initial test program, thereby verifying the correctness of the procedures to the extent practicable.

5. The schedule for ccnducting the initial test program allows adequate time to conduct all preoperational and startup tests. Preoperational test procedures will be available for NRC Regional Administrator reriew at least 60 days prior to scheduled implementation. Startup test procedures will be available for review not less than 60 days prior to the scheduled fuel leading date.

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6. A description of each test is presented in Chapter 14 of the FSAR. We verified that there are test descriptions 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 condition for an extended shutdcwn period; (b) will be used for establishing.conformance with safety limits or limiting conditions for operation that will be included

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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 description are in sufficient detail to establish that the functional adequacy of the structures, systems, components, and design features will be demonstrated.

8. The test program confoms with Regulatory Guide 1.68, "Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors," Revision

2. Exceptions have been identified, and technical justification provided.

i The applicant made a number of charges to the initial test program because of the staff's cmments. Examples of theses changes are:

1. Testing was added to more accurately determine the Reactor Protection and Engineered Safety Feature System trip response times, j 2. Testing was added to verify steam generatnr safety relie'f valve operability.

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3. Testing was modified to verify that no blockages exist in the containment spray nozzle flow path.

4. Natural circulation tests were expanded and will be repeated for training purposes to comply with TMI-2 Action Plan Item I.G.1 for low power training and testing.

5. Testing was added to provide improved assurance of proper auxiliary

. feedwater system performance.

6. Testing was added to verify the heat removal capacity of ECCS coolers during post-accident conditions.

7. Testing was added to verify the capabilities of the emergency lighting system.

8. Testing was added for the loose parts monitoring system.

9. Testing was added to demonstrate operability and perform leak tests of sectionalizing devices in the spent fuel storage pool.

10. Testing was added to demonstrate that, for het containment penetratiens ,

where coolers are not used, concrete temperatures do not exceed design limits.

The following items remain unresolved:

Question Number Request for Additicnal Information (RAI)

Question l

640.01 Tests which may be waived or rescheduled, conditional on the l results of earlier tests, should be identified.

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, . . . 7 f 640.03 FSAR Section 14.2.11 should state that fuel loading and startup test procedures should be available at least 60 days prior to fuel loading.

640.04 Individual test descriptions should be expanded to indicate the sources of acceptance criteria.

640.08 FSAR Subsection 14.2.12.2.23 (ECCS Area Ventilation) should state that data will be extrapolated to verify design heat removal capability as stated in response to this item.

640.09 (1) FSAR Subsection 14.2.7 should state the level of conformance with the testing requirements of Regulatory Guide 1.95, " Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release."

(2) FSAR Subsection 14.2.12.2.48 (Control Room Leak Rate Test) should state conformance with Regulatory Guide 1.95 acceptance criteria, or the testing described in this test abstract should be referenced by, or incorporated into, FSAR Subsection 14.2c12.16 (Control Room HVAC).

640.11 (1) FSAR Subsection 14.2.12.2.8(DieselGeneratorsand Auxiliary Systems) should be modified to demonstrate that testing is conducted in accordance with Regulatory Guide 1.108. Positions C.2.a (1-9) and C.2.b.  :

640.12 (1) The Essential 125V DC Presperational Test description should be clarified to ensure that testing will verify l

the ability of equipment to start and operate with batteries at minimum voltage.

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(2) The Standby Transformers Preoperational Test description should be revised to demonstrate proper operation of transformer cooling under rated load, or how part-load test data will be used to verify full-load capability.

640.14 (1) Provide the following test abstracts, modify existing test abstracts, or provide justification for exception -

with the following positions of Regulatory Guide 1.68, Appendix A:

1.b (1) Service Water System 1.n (16) Heating systems for the refueling water storage tank 5.n Obtain baseline data for the loose parts monitoring system 14A FSAR Subsection 14.2.7 (Conformance of Test Programs with Regulatory Guides) states that the WNP-3 test program ,

" generally conforms to the requirements of" the listed regulatory guides. Either sthte that the WNP-3 test program conforms to the applicable guides, or provide justification for any exceptions taken.

j 14B FSAR Subsections 14.2.12.5 and 14.2.12.8 state that additional tests will be provided at a later date. Either provide these additional tests, or modify these sections

accordingly.

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-9 Based on our review of the FSAR section 14.2 as . emended through Amendment 5, we have concluded that (with the exception of the items described above) the initial plant test program is acceptable and meets the requirements of 10 CFR Part 50, 650.34(b)(6)(iii) that requires inclusico of plans for preoperational testing and initial operations in the FSAR and 10 CFR Part 50, '

Appendix B,Section XI that requires a test program to assure that all testing required to demonstrate that structures, systems, and temponents will perform satisfactorily in service is identified and performed in

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accordance with written ~ test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. We have further concluded that if acceptable responses to the above itens are made, ,

then the initial test program described in the application will meet the acceptance criteria of Section 14.2 of the Standard Review Plan, NUREG-0800, and the successful completion of the test program will demonstrate the functional adequacy of plant structures, systems, and components.

This review and evaluation was performed with the assistance of Battelle Pacific Northwest Laboratories' personnel.

Future changes to this approved test program should be submitted to the staff with justification for the changes for review by the staff. If a change relates to incividual test descriptions, the justification should consider the safety-related categories enumerated above pertaining to the criteria of -

Standard Review Plan 14.2.

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