ML20213C881
| ML20213C881 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/13/1979 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Kniel K, Novak T, Rosztoczy Z Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0259, CON-WNP-259 NUDOCS 7903120463 | |
| Download: ML20213C881 (1) | |
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.MS E F?;.w@F F ( b $iN Y Ed]Ah k Q Y TAT cket File FEB 131979 QAB Projects QAB Chron. File NRR Reading File i DJSkovholt, DPM DBeckham, QAB Docket flo.: 50-397 RficDemott, QAB DLynch, DPM SVarga, DPM l llEMORANDUM FOR: Z. R. Rosztoczy, Chief, Analysis Branch, DSS K. Kniel, Chief, Core Performance Branch, DSS T. Novak, Chief, Reactor Systems Branch, DSS R. Satterfield, Chief, Instrumentation and Control Systems Branch, DSS 'FROM: Walter P. Haass, Chief, Quality Assurance Branch, Division of Project Management
SUBJECT:
IllITIAL TEST PROGRAft: WASHIllGTON NUCLEAR PROJECT NO. 2 The Quality Assurance Branch has submitted the enclosed Request for Additional Information to Light Water Reactors Branch No. 4. Some of the questions relate to testing of structures, systems, or components within your area of review responsibility. In accordance with recent revisions to Standard Review Plan Saction 14.2, you are requested to review the enclosure to determine if additional information is needed from the applicant concerning the initial test program for these items and others within your area of review responsi-bility. Please contact Don Beckham on extension 27741 by February 23, 1979 regarding the results of your review. Original signed by Walter P.Haass . Walter P. Haass, Chief Quality Assurance Branch Division of Project Management
Enclosure:
Memo for S. A. Varga from W. P. Haass - Request for Additional Information, Washington Nuclear Project tio. 2 790312 0 Y63 XN l DP;.g.. ... DPJ,1g, ,,,,p,,$f),, . ~.. ..Q NEAh.. . Rf,1,qQ ..,,t}{, dLS.,., .50 .l.S.. ......SQ ..E YS... - eas. > NtcPoaN 318 (9 74) NRCM 0240
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i / DISTRIBUTI0t': Docket file ~ 9 1979 OAS Projects J ~ ': C.E Chr ~n. Fil e siRR F.eading File C'5kochait, DP:4 Dt.ynch, DPii Daccet 6.o. ou-397 D'!assallo, DPM DBe ham, QAB %cDennott, QAB !!E 3Pt.L"2: FC.': S. A. V:rga, Chief, Light 1.'ater Reactors Brar.ch !!c. 4 Division of Project Managcment FRO::: l alter P. liaass, Chief, Quclity Assurar.ce Branch, Division of Project Management
SUBJECT:
llASHI'iGT0!! iUCLEAR PROJECT t!0. 2, FIRST ROUf;D QUESTIONS FOR CliAPTER 14, IHITIAL TEST PROGRAFI A:plicant: 1:ashingtcn Public Power Service System Lic:ncin; Stag:.: C, Responsible Dranca: L!!R #4 P:cjc::t licn:ger: D. Lynch Requested Completion Date: January 8,1979 .( Review Status: First Round Questions Complete through Amendment 1 {,,l The Quality Assurance Branch has reviewed FSAR Chapter 14 describing the, \\t .e A initial test program submitted in support of the Operating License .\\v. Application for !!ashington fiaclear Project lio. 2. Our Request for Additional Infomation is enclosed. Origir.:1 signed by Waher P. Haass Walter P. Haass, Chief 'J ' Quality Assurance Branch Division of Project Management
Enclosure:
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~ REQUEST FOR ADDITIONAL INFORMATION WASHINGTON NUCLEAR PROJECT NO. 2 423.11 Your replies to questions 423.2, 423.6, and 423.7 do not clearly identify the level of particioation of GE, Burns & i Roe, and WPPSS personnel, other than members of the Test Working Group and Plant Operating Committee, in the prepara-i tion, conduct, and review of preoperational and startup tests and do not provide for qualification of all personnel involved in preparation, conduct or review of tests. Your response should clearly establish minimum qualification requirements for supervisory and review positions. Our position in this respect is that, in general, the minimum qualification requirements listed below are appropriate for typical organizations. l The minimum qualifications of individuals that direct or supervise the conduct of individual preoperational tests are (at the time that the individual is assigned to the task): 1. A bachelor's degree in engineering or the physical sciences or the equivalent and one year of applicable power plant experience. Included in the one year of experience should be at least three months of indoc-trination/ training in nuclear power plant systems and component operation of a nuclear power plant that is substantially similar in design to the type at which the individual will perform the function or, 2. A high school diploma or the equivalent and four years of power plant experience. Credit for up to two years of this four year experience may be given for related I technical training on a one-for-one time basis. Included in the four years of experience should be at least three months of indoctrination / training in nuclear power plant systems and componen' operation of a nuclear power plant t that is substantially similar in design to the type at which the individual will be employed. Minimum qualifications of individuals that direct or supervise the conduct of individual startup tests are (at the time of assignment to the task): 1. A bachelor's degree in engineering or the physical sciences or the equivalent and two years of applicable power plant experience of which at least one year shall be applicable nuclear power plant experience or, 2. A high school diploma or the equivalent and five years of applicable power plant experience of which at least two years shall be applicable nuclear power plant experience. Credit for up to two years of non-nuclear experience may , be given for r, elated te:hnical training on a one-for-one time basis. ....,,..i
Minimum qualifications of individuals assigned to groups responsible for review and approval of preoperational and startup test procedures and/or review and approval of test results are (at the time the activity is being performed. ) 1. Eight years of applicable power plant experience with a minimun of two years of applicable nuclear power I plant experience. A maximum of four years of the non-nuclear experience may be fulfilled by satisfactory completion of academic training at the college level. 423.12 Several sections including 14.2.4.4,14.2.5.2, and 14.2.6.1 reference the WPPSS Test and Startup Program Manual..To allow review of the material, the appropriate information should be incorporated into the FSAR. _l [2333 Describe the approximate numbers by job position and approximate schedule, relative to fuel loading, for providing test personnel. 423.14 In reply to our question 423.4, you modified Section 14.2.4.1.5 to address significant modifications or repairs to safety-related systems. Define significant modifications and repairs and designate the group or individuals authorized to determine the significance of a modification or repair and to detemine retest requirements. Also, specify how modifications and repairs that are not considered significant are to be controlled. 423.15 Revise Section 14.2.11 to ensure that test procedures will be available not less than 60 days prior to fuel. loading. i 423.16 Section 14.2.7 ddresses conformance of test programs with Regulatory Guides. This section should also address conformance with Regulatory Guides 1.52,1.56,1.68.1.1.68.2, ions to reflect 1.80, and 1.108. Also, modify the appropriate test descript the information in the Regulatory Guides. 423.17 Section 14.2.10.l.4, Master Startup Checklist, refers to preoperational testing listed in Table 14.2-4. Table 14.2-4 is a list of startup tests. Correct the reference.
s, 423.18 Several preoperational test prerequisites include the requirement that support systems must have readiness verification. Provide a description of readiness verification and specify which individuals or groups are authorized to make this determination. 423.19 Our review of your preoperational test phase disclosed that several systems and design features may not be scheduled to be preoperationally tested. The staff's evaluation of your preoperational test program was based on a comparison of your proposed test program with the structures, systems, components, and design features included in your facility design that: 1. Will be relied upon for safe shutdown and cooldown of the reactor under normal plant conditions; 2. Will be relied upon for safe shutdown and cooldown of the reactor under faulted, upset, or emergency conditions; 3. Will be relied upon for establishing confomance with safety limits or limiting conditions for operation that will be included in the facility's technical specifications; 4. Are classified as engineered safety features or I will be relied upon to support or assure the operation of engineered safety features within design limits; 5. Are assumed to function or for which credit is taken in the accident analysis for the facility; and 6. Will be utilized to process, store, control, or limit the release of radioactivity. i The description of your preoperational test phase should be expanded or modified to address your plans relative to preoperational testing of the following: 1. Logic, controls, valves, and components used in the condensate and feedwater heating systems. 2. Auto Depressurization Valves, including demonstrations i of operability using all alternate pneumatic supplies and demonstration of operability of pneumatic air supply systems (reference Regulatory Guide 1.80). I e i
4 3. ATWS logic, controls, and final control elements. 4. Leak tightness of Control Room. 5. Diesel Generator Air Starting System. 6. " Keep-full" systens for HPCS, LPCS, and RHR pumps. 7. Automatic transfer of suction from the CST to the suppression pool for the HPCS System. 8. Temperature control of the Condensate Storage Ta'nk'. 9. Manual isolation capability between the main condenser and the off-gas systen.
- 10. Manual operations (local-manual) of all valves or dampers (that are provided with manual operators) for systems classified as engineered safety features. Your response should indicate whether this will be done as a part of each individual preoperational test, as a test pre-requisite, or as a construction acceptance test.
- 11. Timing tests for Recirculation System flow control valves.
- 12. Leak tightness tests for ECCS Systems.
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- 13. Test firing of squib explosive devices in the TIP System j
and SLC System. i
- 14. Response time testing of Engineered Safety Features including initiating logic.
- 15. ADS logic and power supplies including tests for redundancy.
- 16. Heating, Air Conditioning and Ventilating Systems in the following areas: Main Control Room / Cable' Spreading Room / Critical Switchgear Area, Emergency Diesel Generator Butiding, Diesel-Generator Cable Area Corridor, Radwaste Building, Reactor Building Emergency Cooling and Critical Electrical Equipment Area Cooling System.
- 17. Standby Gas Treatment System.
- 18. MSIV Leakage Control System.
- 19. Oriented Spray Cooling System.
423.20 We could not conclude from our review of the preoperational test phase and the test abstracts provided in Table 14.2 that compre-hensive testing is scheduled for several of the described tests. Therefore, clarify or expand the description of the preoperational test phase to address the following: 1 1 1. Modify the individual AC and DC distribution system test descriptions or provide an integrated test description to i i verify er load group assignments. (Reference Regulatory Guide 1 ~ '~ State your plans to verify that DC loads are in accordance 2. with battery sizing assumptions and to verify the supplied loads remain operable at the minimum battery tenninal voltage equivalent to the initial and periodic load discharge tests. Modify the 250 VDC,125 VDC, and 24 VDC system test descrip-tions to include this testing and provide acceptance criteria for the tests. ~ 3. State how operability of emergency loads using offsite power will be demonstrated during AC and DC system tests. 4. Modify the Primary Containment Leak' Rate test description to address the progression of test pressures and the method of closure of the containment isolation valves. Also, clarify whether local type B&C leak tests will be conducted as a part of construction testing or preoperational testing. ~ 5. Identify testing that will be accmplished to verify drywell floor bypass leakage and provide quantitative acceptance criteria. 6. State your plans for testing the Primary Containment Isolation System, including response times of the containment isolation valves. 7. State your plans for assuring I that the effects of inter-facing hardware (e.g., snubbers, pulse dampers) located between measured variables and the input to the sensors for the Reactor Protection System do not compromise the channel response time requirements. Modify the Reactor Protection System test descr1ption and provide acceptance criteria that reflect the effect of these interactions. 8. Modify the Reactor Recirculation System and Control test description to demonstrate correct operation of Recir-culation Flow Control Valve rate limiters on flow controllers and demonstrate that individual control valve stroke rates do not exceed safety analysis assumptions. Provide quantitative acceptance criteria for the above.
~ 423.21 Our review of your proposed startup testing phase disclosed that some tests may not fully conform to regulatory positions described in Regulatory Guide 1.68. Describe your plans relative to positions C.2.f and 1, D.2.a (for your high pressure core spray system), 0.2.k (operation of a bypass valve), 0.2.0, D.2.s (trip-of two recirc pumps at 100%), and D.2.v of Appendix A. 423.22 Clarify the information in Section 14.2 to specifically identify ' each startup test listed in Table 14.2 that is not considered " essential" to demonstrate the operability of structures, systems, and components that meet any of the criteria listed below. a. Those that will be used for safe shutdown and cooldown of the reactor under normal plant conditions and for maia-taining the reactor is a safe condition for an extended shutdown period; or b. Those that will be used for safe shutdown and cooldown of the reactor under transient (infrequent or moderately frequent events) conditions and postulated accident conditions and for maintaining the reactor in a safe condition for an extended shutdown period following such conditions; or c. Those that will be used for establishing conformance with safety limits or limiting conditions for operation that will be included in the facility technical specifications; or d. Those that are classified as engineered safety features or will be used to support or ensure the operations of engineered safety features within desgin limits; or e. Those that are assumed to function or for which credit is taken in the accident analysis for the facility, as described in the FSAR; or f. Those that will be used to process, store, control, or limit the release of radioactive materials. 423.23 The status or mode of operations of plant control systems (automatic or manual) should be specified for all transient tests. Acceptance criteria relating to the performance of control systems should also be provided.
2 7-423.24 Our review of the test abstracts provided in your FSAR disclosed that they are not sufficie'ntly descriptive to conclude that comprehensive testing is planned or that satisfactory test acceptance criteria have been established. The individual test abstracts should be modified as indicated below: 1. Provide technical justification for the Average Power Range Monitor Calibration Test Level 2 acceptance criterion of i 7% of rated power. 2. Modify the test abstract for the Reactor Core Isolation Cooling System to provide for five cold quick starts of the system. Also, pecify system conditions for cold quick S start. the Level 1 acceptance criteria refer to operating restriction on Figure 14.2-3 if the criteria are not met. Figure 14.2-3 does not indicate this restriction. Provide adequate restrictions on operation if Level I criteria are not met. 3. Expand the description of controls to ensure TIP reproducibility in the Core Power Distribution test for both random noise and geometric components. Also, provide assurance that the process computer properly. calculates core power distribution for both symmetric and non-symmetric rod patterns. Provide technical justification for the Level II acceptance criteria. 4. The description of the test methods in the Selected Process Temperatures Test should be expanded. The acceptance criteria should be made consistent with the stated test purpose. 5. Modify or clarify the acceptance criteria for the System Expansion test to provide assurance that design stress levels or fatigue limits will not be exceeded. ~ 6. In the Core Power-Void Mode Test description specify the mode of control (auto or manual) of each of the prir.cipal control systems at each test condition. Provide technical justification or the bases for the Level 2 acceptance criterion to assure that if the acceptance criterion is just satisfied, that stable performance can be expected throughout core life. 7. In the Pressure Regulator Startup Test specify the mode of control (auto or manual) of each of the other principal control systems at each test condition. Provide technical justification or the bases for the Level 2 acceptance criterion (paragraph 1) to assure that if the acceptance criterion is just satisfied, that stable performance can be expected throughout core life. 4
~ (., 8. Modify the Feedwater System Startup Test to specify the mode of control (auto or manual) of each of the other principal control systems at each test condition for the feedwater control setpoint changes. Provide technical justification or the bases for the Level 2 acceptance criterion (paragraph 1) to assure that if the acceptance criterion is just satisfied, that stable performance can be expected throughout core life. Also, the test description should be modified to include a feedwater heater trip and to specifically identify: (1) the type of trip to be initiated; (2) the feedwater heater (s) involved; and, (3) a discussion of how the planned trip relates to the worst case limiting event for your design that could result from a single equipinent failure or operator error. Acceptance criteria for this later transient should be modified to: (1) identify the parameters or variables to be monitored; (2) provide assurance that the transient results will be compared with predicted results for the actual test case; and (3) provide quantitative acceptance criteria and their bases for the required degree of convergence of actual test results with predicted results for the monitored variables and parameters. 9. Modify the description of the Turbine Valve Surveillance Test to ensure that the rate of valve stroking and timing of the close-open sequence is consistent with the conditions which will be experienced during surveillance tests. l 10. In the MSIV Tests modify the acceptance criteria for full MSIV closure at 100% power to: (1) identify the par meters and variables that will be monitored; (2) provide assurance that the transient results will be compared with predicted results for the actual test case; and (3) provide quantita-tive acceptance criteria and their bases for the required degree of convergence of actual test results with predicted results forthe monitored variables and parameters. Also provide clear acceptance criteria for relief valves and RCIC performance during this transient. Also provide acceptance criteria for minimum values of individual valve closure times.
- 11. Modify the Turbine Trip and Generator Load Rejection Tests to (1) specify that both a turbine trip and a generator load rejection will be conducted from approximately full power; (2) correct the Level 1 acceptance criteria to be consistent with your design; (3) identify the variables or parameters to be monitored for each trip; (4) provide assurance that test results will be compared with predicted results for the actual tests to be run (for each trip), (5) provide quantitative acceptance criteria and their bases for the required degree of convergence of actual test results with 5
predicted results for the monitored variables and parameters [ t i
for each trio; and (6) provide acceptance criteria for grid stability, voltage and frequency following generator load rejection trips. _
- 12. Modify the Recirculation Flow Control Startup Test abstract to specify the mode of control (auto or manual) of each of the other principal control systems at each test condition where system stability checks will be conducted. Provide technical justification or bases to assure that if Level 2 acceptance criteria are just satisfied, that stable perfomance can be expected throughout core life.
- 13. Modify the Recirculation System Startup Test to define the types of trips, including two pump trips, to be conducted at each test condition and the manner by which the pumps will be tripped. Also modify the test description and provide acceptance criteria for flow coastdown and for APRM flow biased rod block and scram transient setpoints following the double a circ pump trip. Also provide stability criteria for plant performance following the trips.
- 14. Modify the loss of Turbine-Generator and Offsite Power Test abstract to:
- 1) describe the initial plant conditions for the test includ(ng the lineup of the plant's electrical i
system; (2) describe the type of trip to be conducted; (3) identify the variables, parameters and plant equipment to be monitored; (4) provide assurance that test results will be compared with predicted results for the actual test case; (5) provide quantitative acceptance criteria and their bases for the required degree of convergence of actual test results with predicted results for the monitored variables and parameters; and (6) provide functional acceptance criteria for plant equipment that should function during or following the test.
- 15. The Reactor Water Cleanup System Test states that it will be run in three modes as described in the System Process Diagram. The System Process Diagrams (Figures 5.4-17 a, b, c and 5.4-18) do not define the three modes. Modify the test description and Level 2 acceptance criteria to correspond to the information presented in Chapter 5.
16. The Residual Heat Removal System Test acceptance criteria are based on flow rates and temperatures in the process diagrams. The RHR system process diagrams do not contain this information. Modify the acceptance criteria to include the necessary information.
n 10 - 423.25 Chapter 5", Section'5.2.2.4.1 (page 5.2-12) of the FSAR specifies ~ that the preoperational and startup testing of the safety relief valves will include monitoring of the discharge line movement. Modify the startup test description to reflect this commitment. ~i 423.26 Chapter 5, Section 5.2.5.5.5 of the FSAR specifies that alarm l points for the Leak Detection System will be determined analytically or based on measurements of appropriate paraneters made during startup or preoperational tests. Modify the' test description to identify these parameters and the methods of determining the alann points. 42327 Chapter 6, Section 6.3.2.2.3 (page 6.3-15) of the FSAR states that during preoperational testing of the Low Pressure Core Spray System, the discharge flow orifice will be sized to limit system flow to acceptable values as described in the LPCS process diagram. Modify the test description to reflect this connitment. 423.28 Provide a preoperational test description for the various modes and systems of the Fire Protection System. 42329 Provide a schedule relative to fuel loading that specifies the scheduled time for performing low power and power ascension testing. 9 %}}