ML20213D579
| ML20213D579 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/13/1981 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0339, CON-WNP-339 NUDOCS 8103270239 | |
| Download: ML20213D579 (12) | |
Text
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s DISTRIBUTION Docket No. 50-397 QorL PTRB Reading JJKramer ER1s 'O JAZwolinski DLZiemann MEMORANDUM FOR:
B. J. Youngblood, Chief DCFischer Licensing Branch No.1 Division of Licensing HBClayton WApley (PNL)
FROM:
Dennis L. Ziemann, Chief Procedures and Test Review Branch Division of Human Factors Safety
SUBJECT:
SECOND ROUND QUESTIONS:
WASHINGTON PUBLIC POWER SUPPLY SYSTEM, UNIT NO. 2 INITIAL TEST PROGRAM Contractor personnel from Battelle Pacific Northwest Laboratories have reviewed the applicant's initial test program as described in FSAR Chapter 14 and the responses to first round questions of the Procedures and Test Review Branch. Second round questions on the initial test program are enclosed for transmittal to the applicant.
By copy of this memo, we are also forwarding the enclosure to the DSI branches who have secondary review responsibility for Section 14.2.
Any consnents from the assigned reviewers in these branches should be dddressed to Brent Clayton of the PTRB.
The enclosed questions were prepared by Walt Apley of Battelle (consultant) and Brent Clayton.
._..,_gg DennisL[Ziemann, Chief Procedures and Test Review Branch Division of Human Factors Safety
Enclosure:
WNP Second Round Questions S
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n SECOND ROUND QUESTIONS WASHINGTON PUBLIC POWER SUPPLY SYSTEM UNIT NO. 2 423.30 Dur review disclosed that several of your startup test descriptions are not acceptable. Modify the individual test abstracts as indicated i
below.
i 1.
The following test descriptions are missing Level 1 or Level 2 critieria.
l Add missing criteria or if not applicable, so state.
Missing Level 1 Missino Level 2 S/U Test #11 S/U Test #1-#3 S/U Test #18 S/U Test #6 S/U Test #28 S/U Test #10 S/U Test #72 S/U Test #19-!20
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2.
Full Core Shutdown Margin Startup Test #4 -
Expand the Level 1 criteria to specify temperature conditions for the shutdown margin calculation and state how the exposure depend-ent correction factor will be used to correct the shutdown margin if the determination is made at some other time during the cycle than the most reactive time.
3.
Control Rod Drive System Startup Test #5 -
a.
Expand the test procedure description to either stipulate that at reactor pressures below the design.value, scram times must not exceed those at the design value or provide the bases for the less conservative acceptance criteria.
b.
Provide justification for why the friction test.is only being per-formed for the four slowest CRDs at rated reactor pressure, or revise the table to indicate that all CRDs will'be included in the friction test.
4.
Rod Sequence Exchange Startup Test #8 -
i In your response to item 423.21, D.2.o, you state that the rod I
pattern exchange demonstration will not be conducted since it does not involve the approach of any safety margin or operating limit.
Modify Subsection 14.2.7.2 (Exceptions to Regulatory Guide 1.68) to incorporate and justify this exception, or include such a startup test.
The test, if included, should demonstrate that core limits will not be exceeded during or following exchange of con-trol rod patterns that will be permitted during operation (the demonstration test should be conducted at the highest power level at which control rod pattern exchanges will be allowed during plant operation). This includes fuel conditioning thermal limits.
5.
Water Level Reference Leg Temperature Measurement Startup Test #9 -
a.
Modify the description section to explain why a fifth level instru-ment (upset range) is included in a list of "four" such systems.
b.
Rewrite the Level 2 criteria to combine and clarify the repetitive tolerances on narrow and wide range level system indicator readings.
6.
RCIC System Startup Test #14 -
a.
Item 423.23b requested that the applicant modify the RCIC test abstract to provide for five cold,. quick starts of the system.
The revised description section does not clearly indicate that five such cold, qu'ick starts will be conducted.
Rewrite the description section to include a sumary of the cold starts as provided in the response to item 423.23b.
7.
Feedwater System Startup Test #23 -
a.
Expand the test description to note what simulations, if any, will be done before the test to verify the runback capability of the recirculation system.
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b.
The response to item 423.23h is not totally acceptable.
Expand the test description to describe how the heater loss will be effected.
Verify that this is the limiting heater loss that could result from a single equipment failure or single operator error.
Verify that the Level 2 acceptance criteria for system response to setpoint changes are based on expected per.formance for the actual test con-ditions.
c.
Expand the test description to demonstrate that the maximum feedwater runout capability does not exceed the assumed value in the FSAR.
d.
Expand the acceptance criteria to specify the required dynamic flow response of each feedwater actuator (turbine or valve) to small and large step disturbances.
e.
Expand the acceptance criteria to provide the allowable water level margin to scram for a feedwater pump trip initiated at 100% power conditions.
8.
Turbine Valve Surveillance Startup Test f24 -
Modify the test description and acceptance criteria to measure bypass valve capacity and ensure that it is within the assumed value in the accident analysis for bypass failure.
9.
Main Steam Isolation Valves Startup Test #25 -
The presen't method for determining MSIV closure times is inaccurate.
a.
Modify the test method to measure the full travel of the valves or provide technical justification for extrapolating the full closure time when only measuring 90 percent.
If the measurement is to be based on 90 percent travel, calculate MSIV closure time as equal to the interval from deenergizing solenoids until the valve reaches 90 percent closed, plus the period from 10 percent closed to 90 percent closed times 1/8, or provide technical justification for the current method which " double-counts" delay time.
. b.
Since the stated purpose of this test is to functionally check th.e main steam line isolation valves (MSIVs) for proper operation, i
provide a description of a test which demonstrates that the PSIV-LCS components operate properly when handling steam and that the system can handle the amount of leakage that is present when the main steam system is at operating temperature.
10.
Relief Valves Startup Test #26 -
The Level 1 acceptance criteria (which states that the sum of capacity measurements from all relief valves shall be equal to or greater than rated, + 2% corrected for inlet pressure of 1112 psig) is very rigorous considering the expected individual tolerances noted in the Level 2 criteria (90-135%).
Clarify this apparent discrepancy or provide further information about actions to be taken if this particular Level l criteria is not met.
Turbine Trip and Generator Load Rejection Startup Test #27 -
11.
a.
The response to item 423.23k is not totally acceptable. Modify the test description to require that both turbine throttle valves and main generator breaker trips are conducted at full rated power, or provide technical justification that shows how the test purpose can be met without accomplishing both full power trips.
A s'ufficient technical justification would be if the turbine trip is initiated directly by all remote-manual openings or automatic trips of the generator main breaker, i.e., a direct electrical signal, not a secondary effect such as turbine overspeed. The method used for opening of the main generator breakers (by simu-lating an automatic or manual trip) should be selected such that the turbine-generator will be subjected to.the maximum credible overspeed condition.
b.
Modify Tables 14.2-2 and 14.2-4 to more clearly indicate the status of the turbine trip and generator load rejection tests per your response to part a.
12.
Shutdown from Outside the Main Control Room Startup Test #28 -
l l
The test description implies that the reactor scram and MSIV isola-tion will be performed from inside the control room.
It is our position that all actions be initiated from outside the control room. Modify the test description to comply with this position.
Also modify the test ~ description to clearly state that you will initiate the shutdown cooling mode of RHR from outside the control room and use it to partially cool down the plant (also from outside the control room).
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13.
Recirculation System Startup Test f30 -
Your response to item 423.21, D.2.r, indicates that a simultaneous trip of both recirculation pumps is not performed at 100 percent of rated power.
You state that your analysis of the event (FSAR 15.3.1) indicates there is not decrease in the Minimum Critical Power Ratio (MCPR), and therefore it does not involve the approach of any safety margin or operating limit.
In the startup test description, however, you state that a simul-taneous trip of both recirculation pumps without transfer to LFMG
~
set power supply will be made at near rated flow and power level conditions. In fact' Table 14.2-4 indicates the two pump trip is scheduled for TC-3 (50-75% Power /80-100% Flow).
Modify section 14.2.7.2 (Exceptions to Regulatory Guide 1.68) to
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incorporate and justify this exception, or include a simultaneous trip of both recirculation pumps test at TC-6.
14.
Loss of Turbine-Generator and Offsite Power Sta.rtup Tes.t #31 -
Modify the test description to:
a) Provide assurance that the loss of offsite power condition will be maintained for at least 30 minutes to demonstrate that necessary equipment, controls, and indication are available following station blackout to remove decay heat from the core using only emergency power suppl.ies and distribution systems; b) Verify that the acceptance criteria include proper start and load times for the diesel generators; and c) Verify that the reactor pressure acceptance criterion is. based on a realistic prediction for the test condition.
15.
Residual Heat Removal System Startup Test #71 -
Modify the test description to specify the minimum power level the test will be conducted at and how power history and test scheduling will be coordinated to more adequately demonstrate the heat exchanger capacity.
. 16.
Cooling Water Systems Startup Test #73 -
a) Modify the acceptance criteria to state whether they are Level 1 or Level 2.
Ensure that not applicable criteria are so labelled.
b)
Include the standby service water (SSW) system in an expanded test description, or provide technical justification for not testing that. system.
17 Off-gas System Startup Test #74 -
Your test description states that provided measurable and sufficient fission gases and fission gas daughter products are'present in the off-gas, decontamination factors across several charcoal beds are determined. Modify your test description to state how the decon-tamination factors will be detemined if sufficient levels are not attained.
423.31 Provide or modify test descriptions 1) that will verify that the plant's ventilation systems are adequate to maintain all ESF equipment within its design temperature range during normal operations; and 2) that will verify that the emergency ventilation systems are capable of maintaining all ESF equipment within their design temperature range with the equipment operat-ing in a manner that will produce the maximum heat load in the compartment.
If.it is not practical to produce maximum heat loads in a compartment, describe the methods that will be used to verify design heat removal capabil-ity of the emergency ventilation systems.
Note that it is not apparent that post-accident design heat loads will be produced in ESF equipment rooms during the power ascension test phase; therefore, simply assuring that area temperatures remain within design limits during this period will probably not demonstrate the design heat removal capability of these systems.
It will be necessary to include measurement of air and cooling water temperatures and flows and the extrapolations used to verify that the ventilation systems can remove the postulated post-accident heat loads.
423.32 Modify Figure 14.2-4 or Section 14.2.12 to correct items noted below:
1.
The CRD Installation Equipment System Preoperational Test listed in this figure is not described in Section 14.2.12.1, while several test descriptions listed in that section are not contained in this figure (14.2.12.1.2,
.3,.15,.17, and.30).
2.
The test phase of the 480 V Distribution System Preoperational Test is not shown to be accomplished concurrent to the testing phases of the 230/115 KV, 6.9 KV, and 4.16 KV distribution system although they all are tested under the same test, Loss of Power and Safety Testing Preoperational Test (37).
. 423.33 Reference the test conditions of Table 14.2-2 and Table 14.2-3 to the regions defined in Figure 14.2-3.
The test titles 'in Table 14.2-3 do not correspond to those listed in Subsection 14.2.10.3(12).
Correct the title listing inconsistencies.
423.34 Provide preoperational test descriptions (or modify existing descriptions) to verify that each engineered safety feature pump operates in accordance with the manufacturer's head-flow curve.
Include in the description the bases for the acceptance criteria.
(The bases provided should consider both flow requirements for ESF functions and pump NPSH requirements.)
423.35 The response to item 423.8c is not acceptable.
Regulatory Guide 1.68 C.8 states in part, that " hold points should be establishedn.to ensure that relevant test results are evaluated and approved... prior to p'rogres-sing with the power-ascension test phase." Modify Subsection 14.2.5.3 to i
reflect this position.
423.36 The response to item 423.11 states that both preoperatio.nal and startup tests are under the direction of a Test. Engineer.
Modify the minimum qualifications for a Test Engineer stated in Subsection 14.2.2.10 to meet those of individuals who direct or supervise the conduct of individual startup tests as outlined in item 423.11.
423.37 Provide a referenceable source for Fiqure 14.2-6, and indicate the units applicable to the horizontal axis.
423.38 Figure 14.2-2 shows the test and startup organization, which includes the test group supervisor position. Modify Subsection 14.2.2.3.3 (Test and Startup Department Position Responsibilities) to include a description of the test group supervisor's responsibilities.
423.39 Your response to item 423.13g is not acceptable.
Modify the Reactor Protec-t
~
tion System preoperational Test to account for the delay time of process-to-i sensor hardware (e.g., instrument lines, valves, flow limiters) in your response time testing.
Modify the test description to state how you will account for this delay time.
Also, modify Test Procedure item c of the l
test description to make it clear that your preoperational test will l
include all channels of each trip function for which response time tests are required by the Technical Specifications.
423.40 Figure 14.2-3, Test Condition Region Definition, requires modification to improve its readability and use in conjunction with the startup test descriptions.
1 1.
Modify the description for TC-1 to indicate the percent power boundaries, shown in the figure as approximately 5 to 20%.
.- 2.
Label the following:
(a) 50% Rod Line (b) Analytical Lower Limit of Master Power Flow Control (E)
(c) Analytical Upper Limit of Master Power Flow Control (F) 3.
Label and provide definitions for maximum allowable core flow lines.
4.
Your operating license will not allow operation at a power level greater than rated thermal power. Therefore, modify your definition of Test Condition 7 and locate this test condition on the map.
423.41 The response to certain sub-items of 423.16, 423.19' and 423.20, regarding compliance with certain items o'f Regulatory Guides 1. 41, 1. 68, 1. 80,. a nd 1.108, is' not acceptable.
Provide the iniorcation requested below or provide test descriptions of the equivalent alternative testing that is being performed.
1.
Regulatory Guide 1.41 (a) Verify that all sources of power supply to vital buses are full-load tested.
(b). Verify triat testing is conducted with only one power source at a time.
(c) Verify that buses not under test are monitored to verify absence of voltage.
2.
Regulatory Guide 1.68 (a) Provido a test description for the Chemical Control System [1.b(2)].
(b) Provide testing to verify that containment spray nozzles, headers, and piping are free of debris by air testing, and verify that this air testing overlaps tests for obstruction done with water [1.h(3)].
(c) Provide a preoperational test description for the containment combustible gas control system [1.h(4)] which will serve:
(i) To demonstrate the capability of the combustible gas control system to operate in response to post-LOCA requirements.
(ii) To demonstrate that post-LOCA hydrogen monitors function properly.
(iii) To demonstrate the operability of the vacuum breakers.
(d) Provide a preoperational test description to test containment penetration coolers. On those penetrations where coolers are not used, provide a startup test description that will demonstrate that concrete temperatures surrounding hot penetrations do not exceed design limits [1.i('21)].
.. (e) Provide a test description for seismic instrumentation [1.j(10)].
(f) Modify the Reactor Building Crane Preoperational Test (53) to include static testing at 125% rated load and full operational testing at 100% rated load [1.m(4), l.o(l)].
(g) Modify the Standby Service Water System Preoperational Test to demonstrate adequate NPSH and the absence of vortexing over range of basin level from maximum to the minimum calculated 30 days following LOCA.
Verify that overflow lines are unobstructed [1.n(1)].
('h) Modify the Radwaste Building HVAC System Preoperational Test (30) to verify that the Radwaste Building is maintained at a slightly negative pressure and that air-flow patterns are such that air flows from relatively clean areas to areas of progressively greater' contamination potential [1.n(14)(e)].
(i) Verify operability of the solid liquid radwaste system by testing with representative chemical waste streams. The acceptance criterion for the solid radwaste system should require that there be no free liquid in the solidification sample (5.c.c).
3.
Regulatory Guide 1.80, Positions c.(8), (9) and (10)
Modify the Primary Containment Instrument Air Preoperational Test (34) or describe other tests to show conformance with the loss-of-air testing requirements of this guide.
4.
Regulatory Guide 1.108, Positions c.2.a(3), (5), (9), c.2.b Modify the Standby AC Power System Preoperational Test (43) to address the full-load carrying capacity, the capacity at full-load temperature, the consecutive valid starts, and the redundant starting requirements of this guide.
423.42 The startup test program described in Table 14.2-4 is not acceptable as written. Modify Table 14.2-4 as follows:
1.
Incorporate lines bracketing tests to aid in determining which symbols l
refer to which test conditions.
2.
The marked test conditions for STI #5 reference note 2, which states that test 5 should be done at test conditions 5 (STI #27) and 2 (STI #31),
neither of which are given in STI #5.
Modify these notations to remove this discrepancy.
l 3.
Label STI-7, STI-8, and STI-32 "Not Applicable," as is STI #15.
l l
4.
Modify STI-16 such that measurement is made at 100% core flow as is j
stated in the test description.
(Also " Temperatures" not "Emperatures".)
, 5.
Modify STI-17 to reference pre-heatup condition when initial measurements are made, and TC #6 which would represent the extreme steady-state condition.
6.
7.
STI-25 states that a simultaneous full closure of all MSIVs will be conducted at approximately 100%.
Remove note 10 which indicates the test may be performed at > 75% power. Also, "0" should be "8".
8.
STI - 27 "BP" should probably be "SP".
9.
STI-30 on Table 14.2-4 references TC-1 (See defn. Figure 14.2-3).
TC-2 should be substituted for TC-1.
10.
STI-35. states that flow calibration is made at TC-2, between TC-2 and TC-3, at TC-3, at TC-5, between TC-5 and 6, and at TC-6.. Modify STI-35 if this is not the intended calibration schedule.
11.
STI-36 through STI-69 should be labelled "Not Applicable" if that is the intention.
~
12.
Consideration should be given to performing STI-71 at TC-6, in light of decay heat load problem (see p. 14.2-145).
13.
The test description for STI-73 states that data will be taken follow-ing initial heatup (add TC-1) and at selected power levels (add TC-3).
14.
Modify T.able 14.2-4 to include or delete the following unassigned notes.
- 1, #9, #11, SE.
15.
Note 1 "14.2-1" should be "14.2-3".
ERRATA WNp #2 - Nuclear. Station
- p. 14-1 14.2.2.1 General "14.2-7" should be "14.2-5"
- p. 14-xx The titles for Figures 14.2-1 through 14.2-4 don't match the titles used on the figures
- p. 14.2-2 "chemcial" should be " chemical"
' p. 14.2-11
" Operational Assurance" should be "Cperational' Quality Assurance"
- p. 14. 2-18
" condition" should be ' conditions"
- p. 14.2-26, 49 "Precperation" should be "preoperational"
- p. 14.2-33 On this and subsequent pages, whenever a regulatory guide is referenced, the appropriate revision number should be included.
Section 14.2.7.3.b is written. backwards. The FSAR must be in compliance with Regulatory Guide 1.33, not vice versa.
- p. 14.2-38 "14.2.10.1.5" should be "(14.2.10.1.5"
- p. 14.2-42
" test anticipated" should be "tes'ts anticipated"
- p. 14.2-54 "preparational" should be "preoperational"
- p. 14.2-54a
" tasks" should be " tanks"
- p. 14.2-60 "initiaton" should be " initiation"
- p. 14.2-74 "with" should be "within"
- p. 14.2-77 "Sperintendent" should be " Superintendent"
- p. 14.2-91, 92 "0.38% K/K" should be "0.38% AK/K"
" strongest" should be " highest worth" or "most reactive" 2
p. 14. 2-95,97, Kg/cm is not an approved pressure unit; use
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109a, 110, 122, "Pa" if metric units are to be used.
123, 129, & 130 e
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- p. 14.2-98
" count-range" should be " count-rate"
- p. 14.2-102 The prior use of alternative metric units whenever inches are used is not given here
- p. 14.2-107, 108 The abbreviations used in startup test #13 (MLHGR, MCPR, and MAPLHGR) are not defined until startup test #19.
Where abbreviations have not been previously defided or contained in a central glossary, provide appropriate definitions.
- p. 14.2-109 "is from" should be "is for" "controlers" should be " controllers" 1
n
- p. 14.2-110 "consensor" should be " condenser" d
- p. 14.2-112 "reciruclation" should be " recirculation" "restarets" should be " restarts" "dermined" should be " determine"
- p. 14.2-ll2a "38" should be "56"
- p. 14.2-116 "Preoperatonal" should be "Preoperational"
- p. 14.2-117 Add subsection heading'(14.2.12.3.18.4 Criteria)
- p. 14.2-118 Add "'iCPR" to parameters list.
- p. 14.2-119
" Average Linear" should be " Average. Planar Linear" "mmeasured" should be " measured" "maintainned" should be " maintained" "reactro" shculd be " reactor"
- p. 14.2-122 "0.13.0 Hz" should be corrected
- p. 14.2-124 "12.5" should be "12.7" "15.3" should be "15.2"
.p. 14.1-128
" closures" should be " closure"
- p. 14.2-130 "17.5" should be "17.6"
- p. 14.2-132 "oening" should be " opening" "14.2.1.3.27" should be "14.2.12.3.27"
- p. 14.2-135
" flow to high" should be " low to high"
- p. 14.2-139 "alinged" should be " aligned" "conditionn" should be " condition"
- p. 14.2-142
" component deformed" should be " component is deformed"
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MAR 13 1961 Docket No@
MEMORANDUM FOR:
B. J. Youngblood, Chief, Licensing Branch No.1, DL FROM:
N. D. Lynch, Project Manager, Licensing Branch No. 1, DL
SUBJECT:
FORTHCOMING MEETING WITH WPPSS REGARDING THE GE0 LOGY AND SEISM 0 LOGY OF WNP-2 SITE DATE AND TIME:
Tuesday, March 31, 1981 8:30 am - 4:00 pm LOCATION:
Room P-110 Phfilips Building Bethesda, Maryland PURPOSE:
Discussion of staff concerns regarding geology and seismology at WNP-2 site.
PARTICIPANTS:
NRC Staff M. D. Lynch, R. Jackson, et al.
WPPSS Keener Earle, et al.
DriRinal signed by*-
EDeve Lynch M. D. Lynbh, Pmject Manager Licensing Branch No. 1 Division of Licensing cc: See next page bl000008 3 4
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.sc rosu sia no sci ~scu e:aa OFFICIAL RECORD COPY mo w-xu a
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Mr. R. L. Ferguson Managing Director Washington Public Power Supply System P. O. Box 968 3000 George Washington Way Richland, Washington 99352 ccs:
Nicholas Reynolds, Esq.
Debevoise & Liberman
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1200 Seventeenth Street, N. W.
Washington, D. C.
20036 Richard Q. Quigley, Esq.
Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 Nicholas Lewis, Chairman Energy Facility Site Evaluation Council 820 East Fifth Avenue Olympia, Washington 98504 Mr. O. K. Earle Licensing Engineer P. O. Box 968 Richland, Washington 99352 Mr. Albert D. Toth Resident Inspector /WPPSS-2 NPS c/o U. S. Nuclear Regulatory Commission P. O. Box 69 Richland, Washington 99352 a
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MEETING NOTICE DISTRIBUTION M
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T. Novak M. Ernst R. Baer
- ..,;I V S. Varga E. Adensam ef T. Ippolito R. A. Clark A. Thadani R. Reid ACRS (16)
R. Tedesco Attorney, OELD J. Youngblood OIE (3)
A. Schwencer OSD (7)
F. Miraglia Project Managerniunrh J. R. Miller Licensing Assistant MRushbrnnk G. Lainas Receptionist D. Crutchfield TERA W. Russell J. LeDoux, I&E J. Olshinki V. Moore 1
R. Vollmer I&E Headquarters R. Bosnak I&E Region I F. Schauer I&E Region 11 R. E. Jackson I&E Region III G. Lear I&E Region IV V. Noonan I&E Region V S. Pawlicki V. Benaroya
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Participants:
Z. Rosztoczy W. Haass M. D. Lynch, R. Jackson et al.
D. Muller R. Ballard W. Regan J. D. Saltzman D. Ross P. Check Chief, Power Systems Branch
- 0. Parr bcc: Applicant & Service List F. Rosa W. Butler W. Kreger R. W. Houston Chief. Radiological Assessment Branch W. Gammill L. Rubenstein T. Speis W. Johnston B. Grimes S. Schwartz F. Pagano S. Ramos J. Kramer