ML20246L127

Provides Advance Changes to Be Included in Future FSAR Amend Re Organizational Changes Impacting FSAR Section 14.2,as Discussed During 890717 Meeting Between Util & NRC

ML20246L127
Person / Time
Site:	Comanche Peak
Issue date:	08/31/1989
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-89557, NUDOCS 8909060250
Download: ML20246L127 (96)

Text

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1EIELECTRIC ] l August 31, 1989 'l

.WEumm J. CaWE, k. j

' -l Lurcutive Vice nesulent p

O.,S.' Nuclear Regulatory Commission

. Attn: Document Control Desk -

Washington, D.'C. '20555- .

.1

SUBJECT:

- COMANCHE PEAK STEAN ELECTRIC STATION (CPSES)

-DOCKET NOS.:50-445 AND 50-446 ORGANIZATIONAL CHANGES INPACTING FSAR 1 CHAPTERi14- L!

Gentlemen:

This letter provides an advance copy of changes to be included in a future '

FSAR. amendment regarding CPSES Nuclear Operations organizational changes  ;

2 impacting FSAR'Section 14.2 INITIAL. TEST PROGRAM. These changes were  ;

' discussed during a meeting between TV Electric and the NRC on July 17, 1989. 1 In order to.facilitaie NRC staff review of these changes, the enclosure is -l organized as f0110ws:

1. Oraf t revised FSAR pages, with. changed portions . indicated by a bar in the margin,.as they are to appear in a future amendment

'(additional pages immediately preceding and/or following'the revised pages are provided if needed to understand the change). . _j

-2. Line-by .line description / justification of each item revised.

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3. A copy of related SER/SSER sections. j L4. An index page.containing the title of a " bullet" which consolidates l and categorizes the changes by subject and related SER section. 1 4

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8909060250 890831 h- PDR ADOCK 05000445 g PDC

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f TXX-89557 Page 2 of 2 August 31. 1989

5. The hand marked-up version of the existing FSAR pages denoting the actual changes.

Sincerely, tF -

William J. Cahill, Jr.

By: M '

4 RogeV D. Walker' Manager, Nuclear Licensing RSB/vid Enclosure c - Mr. R. D. Martin, Region IV Resident Inspectors CPSES (3)

Mr. J. H. Wilson, OSP-NRC

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Enclosure to TXX-89557.

!. August. 31, 1989 .,

' l Advance FSAR Change Regarding CPSES p  : Nuclear Operations Organizational' Changes L Impacting FSAR Section 14.2 ItemL1' . Draft Revised FSAR Pages' pg'2 thru 41 Item 2 Description / Justifications for all pg 42.thru 44-FSAR changes Item 3~ -Related SER/SSER Pages pg 45 thru 48 Item 4 -Index Page Containing the. Title pg 49 of the " Bullet"

. Item 5- ' Markup of Existing FSAR Pages pg 50 thru 94 1:

pg 1 of 94

Enclosura to TXX-89557 Paga 2 of 94 CPSES/FSAR 14.2 INITIAL TEST PROGRAM 14.2.1

SUMMARY

OF TEST PROGRAM AND OBJECTIVES The purpose of the test program for Comanche Peak Steam Electric DRAFT Station (CPSES) is to assure that the installed station structures, systems and components will be subjected to tests as required to verify that the plant has been properly designed and constructed and is ready to operate in a manner that wi11 not endanger the health and safety of the public, and to provide assurance of total plant reliability for opera' ion. The test program will also ensure that the procedures for opei ating the plant safely have been evaluated and demonstrated, and that he operating organization is knowledgeable about the plant and procedures and is prepared to safely operate the facility.

The necessary procedures to control, implement, and document the test DRAFT program are established by plant procedures and summarized in the following sections. TU Electric, as the applicant, has responsibility for overall direction and management of the test program.

The testing activities to be performed on safety-related cystems at 11 the CPSES are divided into three stjor phases: prerequisite testing, preoperational testing and initial startup testing. Prerequisite testing will be conducted in order to verify the integrity, proper installation, cleanliness, and functional . operability of the system components.

O Preoperational testing will be performed in order to demonstrate the capability of systems, structures, and components to meet safety-related performance requirements. These tests will be performed on plant systems, structures, and components that are designed to perform i

14.2-1 Draft Version ,

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Enclosure to TXX-89557-Page 3 of 94 CPSES/FSAR ,

57 a nuclear safety-related function. These include those systems and components which are identified as quality related items in Table 17A-1 of FSAR Section 17A. In addition, systems and components which have applicable testing requirements specified in Regulatory Guide 1.68 and discussed in Appendix 1A(B) will be subjected to 11 preoperational tests. Summaries of individual preoperational tests are provided in Section 14.2.12.

54 Preoperational testing will be completed prior to fuel load with

, certain limited exceptions where tests or parts of tests will be daferred to the Initial Startup Test Program. Such an exception is the complete testing of the control rod drive mechanisms with the rods attached. In such cases sufficient tests will be performed prior to fuel loading to. provide reasonable assurance that the post-loading tests will be successful.

54 Initial startup tests will be performed beginning with activities leading to fuel loading and ending with full power operation. The intent of these tests is to assure that tests deferred from the preoperational test program are performed: tMt fuel loading is effected in a safe manner: that the plant is st'ely brought to rated capacity: that plant performance is satisfactory in terms of established design criteria: and to demonstrate, where practical, thct the plant is capable of withstanding anticipated transients and postula nd accidents. Testing activities related to fuel load and i ni ti a~a criticality are described in Section 14.2.10. Initial startup tests including lower power physics testing and power ascension testing are deteribed in the test summaries provided in Section 14.2.12.

For systems and components which have no naclear safety-related requirements, acceptance testing will be performed to verify proper system performance and to ensure reliable and efficient operation of DRAFT the plant.

Draft Version 14.2-2

Enclosure to TXX-89557 Page 4 of 94 CPSES/FSAR Preoperational and initial startup tests will be conducted in accordance with approved test procedures. Review, approval, and DRAFT revision of test procedures and the evaluation and disposition of test

. results will be accomplished by methcds specified in the appropriate administrative procedures and summarized in Section 14.2.3.

The startup program will utilize, to the extent practical, operations personnel and operating procedures to provids familiarization with the plant installation and demonstrate the adequacy of operating procedures.

Preoperational testing activities will be coordinated through a Joint DRAFT Test Group (JTG), as descr'hed in Section 14.2.2.6. Initial startup testing detivities will be coordinated through a Test Review Group (TRG), as described in Section 14.2.2.7.

14.2.2 ORGANIZATION AND STAFFING 14.2.2.1 General Description TV Electric is responsible for the overall administration and DRAFT technical direction of the CPSES test program. The Performance and Test Kanager is responsible for the coordination of the initial startup test program. The Nanager, Startup is respons'ble for the coordination, direction, and implementation of the pres equisite and preoperational test program.

The Performance and Test and Startup organizations are shown in DRAFT Figures 13.1-2 and 13.1-3. The TRG and JT3 organizations are shown in Figures 14.2-1 and 14.2-2. The 50RC membership is described in Section 13.4.1.1.1. 37 I

14.2-3 Draft Version

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.DRAF7, 14.2.2.2 Performance and Test Organizational Responsibilities DRAFT- The duties and responsibilities of the Performance and Test organization under the direction of the Performance and Test Manager are as follows:

-38 1. Preparation of testing schedules; DRAFT 38 2. Coordination with the appropriate engineering organizations to resolve component / system design and operating problems:

38 3. Preparation of test procedures:

DRAFT 4. Conduct tests to demonstrate safe plant operation.

68 5. Perform the initial startup test sequence to ensure a safe and orderly power ascension program.

Support personnel including craft labor and technicians who will be engaged in testing activities may be supplied by TV Electric or DRAFT contractors. -Such support will vary according to test program requirements.

DRAFT 14.2.2.2.1 Performance and Test Manager DRAFT The responsibilities of the Performance and Test Manager include:

DRAFT-DRAFT 1. Development and implementation of the Performance and Test surveillance tests; Draft Version 14.2-4

Enclosure to TXX-89557 Page 6~of 94 CPSES/FSAR

' 2. : Development and implementation of the Initial Startup Test 76-Program: and

3. Coordination. of testing with the activities of. operations. DRAFT maintenance, engineering, and construction organizations.

4. Administration'of the development of plans and schedules to- DRAFT sut. port the assigned testing activities; r

5. Administration of the development of individual test procedures: DRAFT-

6. Review test procedures and results or assure that such reviews DRAFT are conducted by qualified personnel within the Performance and Test organization:

7. Assure proper and timely notifications and reports pertaining to DRAFT assigned testing activities are submitted to the Nuclear Regulatory Commission and other regulatory agencies.

14.2.2.2.2 Performance and Test Engineers l DRAFT' The duties and responsibilities of the Performance and Test engineers DRAFT include:

1. Preparation of assigned test procedures to direct and guide specific tests in accordance with a 3tandard format:

2. Direction to support personnel and others during performance of tests including appropriate _ interface with station operators:

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3. Ensuring the safety of personnel and plant equipment during testing:

14.2-5 Draft Version

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4. Familiarization of support personnel with specific tests:

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5. Identification of deficiencies that could adversely affect test performance:

6. Assembly of test data and preparation of test reports for I

evaluation of test results by others; and

7. Responsibility to disallow or terminate testing due to conditions which could endanger personnel or equipment.

DRAFT. 14.2.2.3 Startuo Department Organizational Resnonsibilitiel DRAFT' The duties and responsibilities.of the Startup Department under the i direction of the Manager, Startup are as follows:

38- 1. Preparation of testing schedules: i 38 2. Coordination with appropriate construction organizations for release of completed components /systeps to facilitate testing:

38 3. Coordination with the appropriate engineering organizations to resolve component / system design and operating problems:

38 4. Preparation of test procedures:

5. Conduct tests to demonstrate adequate and safe component and system performance.

l c 68 Support personnel including craft labor and technicians who will be engaged in testing activities may be supplied by TU Electric or DRAFT contractor:. Such support will vary according to test program requi remen ts .

Draft Version 14.2-6 l

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' Enclosure to TXX-89557 PagQ 8 of 94: CPSES/FSAR 14.2.2.3.1 Manager, Startup DRAFT i

The responsibilities of the fanager, Startup include: DRAFT

1. Administration of the development of plans and schedules 68 regarding the status of the startup program; i

2. Administration of the development of individual test procedures: 38 l

3. Continuing analysis of construction and equipment installation 38 er.hedules for compatibility with testing schedules and )

implementation of corrective actions to minimize conflicts:-

4. Review test procedures'and results or assure that such revieu DRAFT l are conducted by qualified personnel within the Startup -l Department; j 4

l l S. Assure proper and timely notifications and reports pertaining to 68 testing activities are submitted to the Nuclear Regulatory )

commission and other regulatory agencies. l 14.2.2.3.2 Assistant Startup Manager DRAFT I The Assistant Startup Manager is responsible for the startup program DRAFT

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and will have the following duties and responsibilities:

1. Provide technical direction to system test engineers and others 76 l

l assigned to the preoperational test group: l 1

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DRAFT 2. Review of Startup Department administrative and prerequisite test 1 i

procedures and ensure that the procedures and test results have l I

been approved at the appropriate level:

. DRAFT 3. Review and submittal of design change requests originated by the Startup Department in accordance with the appropriate Startup I Department administrative procedures:

76 4. Assure testing activities are conducted in accordance with the Quality Assurance Program and applicable procedures:

76 5. Coordination of testing with the activities of the engineering, construction and operations organizations: and 76 6. Implementation of the Unit 1 Prestart Test Program.

DRAFT 14.2.2.3.3 Startup Engineers ,

DRAFT The duties and responsibilities of the Startup engineers include:

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DRAFT 1. Preparation of assigned test procedures to direct and guide specific tests:

2. Direction to support personnel and others during performance of tests including appropriate interface with station operators:

3. Ensuring the safety of personnel and plant equipment during testing:

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4. Familiarization of support personnel with specific test:

5. Identification of deficiencies that could adversely affect test

./ performance; Draft Version 14.2-8

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6. Assembly of test data and preparation of test reports for evaluation of test results by others:

1 7 .. Implementation of tagging procedures: and

8. Responsibility to disallow or terminate testing due to conditions which could endanger personnel or equipment. )

14.2.2.4 Operatina Staff DRAFT The CPSES operating staff will be involved in the test program in DRAFT several capacities throughout preoperational and initial startup I I'

testing. This involvement will include review of test procedures and results and the direct participation of operating personnel in test activities. TU Electric maintenance personnel will assume the responsibility for performing routine preventative and corrective 38 maintenance activities on station components when they are released from construction to the preoperational testing group. Operating DRAFT staff technicians will be assigned to assist test engineers in performing tests. Station operators will assist test engineers in performing tests and will take over the routine operations of systems for which prerequisite-type testing has been completed. The operating staff will direct the fuel loading and will be responsible or the operation of the plant during initial startup testing.

DRAFT The duties and responsibilities of the operating staff during plant 15 operation are described in Chapter 13. The duties of key operating personnel with regard to the startup program are summarized below.

I 14.2.2.4.1 Vice President, Nuclear Operations l DRAFT The Vice President, Nuclear Operations has overall responsibility for DRAFT station operatic 1s and the test program.

14.2-9 Draft Version

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Pa'ge 11 of 94 CPSES/FSAR DRAFT 14.2.2.4.2 Plant Manager DRAFT The Plant Manager will provide a continual analysis of testing schedules, operator training schedules, and plant operating staff workloads in order to minimize conflicts with the test program, and he also will provide coordination between the operating staff and the Startup Department.

DRAFT Operations Department l14.2.2.4.3 DRAFT The Manager, Operations will be responsible for the proper operation of all equipment in the custody of the operations department and for l

encuring that the conduct of the test program does not place the plant in an unsafe condition. He will provide personnel from the operating 33 staff as required to support the conduct of testing activities. In addition, he will direct the development of station operating procedures.

I DRAFT The Shift Supervisors report to the Manager, Operations and are responsible for the safe operation of the plant during assigned shifts. They also are responsible for the implementation of appropriate safety and custody tagging procedures and have responsibility to disallow or terminate testing due to conditions which could endanger 3ersonnel or equipment or violate Technical Specifications.

l DRAFT 14.2.2.4.4 Maintenance Department 1

DRAFT The Manager, Maintenance will be responsible for performing preventive and corrective maintenance when required or components and systems that have been turned over from construction to TV Electric. He will 33 provide personnel from the maintenance department to support testing activities as required.

Draft Version 14.2-10

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'Page 12 of 94' CPSES/FSAR 14.2.2.4.5- Nuclear Operations Support ,

DRAFT The Manager of Nu' clear Operations Support will provide personnel from DRAFT the Nuclear Operations Support organization as required to support.

testing activities. The Performance and Test Manager reports to the Manager of Nuclear Operations Support and is responsible for the implementation of the Initial Startup program.

14.2.2.4.6 Director. Quality Assurance

_l DRAFT The Director. Quality Assurance.is responsible for approving and 68 verifying implementation of the TU Electric CPSES QA Program.

14.2.2.5 Major Participating Organizations l DRAFT 14.2.2.5.1 Engineering and Construction DRAFT Engineering and Construction will be responsible for assisting to the 60' extent required in ensuring that tests sufficiently verify the adequacy of system design and in the formulation of changes required to correct detected design deficiencies. This responsibility includes:

1. Review of preoperational and initial startup test objectives and DRAFT acceptance criteria to verify implementation of operating license commitments and consistency with the station safety analyses;

2. Review and approval of design change requests originated during DRAFT the course of the test program.

3. Management of Contractors. DRAFT DRAFT l

l 14.2-11 Draft Version

Enclosure to TXX-89557 Paga.13 of'94 CPSES/FSAR DRAFT 14.2.2.5.2 Brown & Root, Inc. (B&R)

DRAFT B&R, as the constructor for CPSES, is responsible for the construction completion, performance of associated constructions tests, and orderly release of components and systems to TU Electric consistent with the test program schedules. This responsibility includes:

1. Completion of construction and construction testing activities:

DRAFT 2. Provision of craft technical manpower support as required for performance of the test program.

DRAFT 14.2.2.5.3 Westinghouse Elect,ric Corporation 60 Westinghouse, as the Nuclear Steam Supply System (NSSS) supplier, is responsible for-providing technical direction to TU Electric during preoperationti and initial startup testing performed on the NSSS and associated auxiliary equipment. Technical direction is defined as technical guidance, advice and counsel based on current engineering, installation, and testing practices. This responsibility includes:

1. Assignment of personnel to provide advice and assistance to TV Electric for test and operation of all equipment and systems in the Westinghouse area of responsibility.

DRAFT 2. Assignment of an operational physicist to the site organization during fuel loading and low power testing; and

3. Provision of test procedure outlines and technical assistance for tests of Westinghouse furnished components and systems.

Draft Version 14.2-12

e-Enclosurs to TXXL89557 LPaga:14:of;94' C'PSES/FSAR 14.2.2.5.4' Utility Power Corporation (UPC)

DRAFT UPC 'as' supplier of the main turbine generator set, is responsible for DRAFT 4

'providing technical support to TU Electric during preoperational and

= initial startup testing performed on'the turbine generator and related auxiliary equipment.

14.2.2.6  : Joint Test Group (JTG) ' DRAFT The Joint Test Group (JTG) is comprised of certain station supervisory DRAFT'

-and technical personnel.- The JTG is charged with reviewing Startup' activities and advising the Manager,' Startup on the disposition of those it.2ms-reviewed. ,

14.2.2.6.1 JTG Membership DRAFT As a minimum, the Joint Test Group (JTG) shall be composed of 68; managers, supervisors, or engineers from the organizations. listed below.

DRAFT Startup DRAFT Operations 68 Technical Support 68 Engineering and Construction' 68 Westinghouse (for all matters concerning preoperational testing 68 performed on the NSSS and associated auxiliary systems)

The members and their alternates, including the Chairman, shall be DRAFT g

designated in writing by their cognizant Vice President.

The primary function of the JTG is the review and approval of all DRAFT preoperational test procedures, procedure revisions, and test

'results.

In addition to the above, representatives of other organizations will DRAFT participate, as requested by the Chairman. 1 I

14.2-13 Draft Version  !

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DRAFT 14.2.2.7 Test Review Group (TRG)

DRAFT The Test Review Group (TRG) is comprised of certain station supervisory and technical personnel. The TRG functions as a rdSIommitteeoftheStationOperationsReviewCommittee(SORC)for initial startup testing matters. The TRG is. charged with reviewing initial startup testing activities and advising the 50RC on the disposition of those items reviewed. The SORC may act in lieu of the TRG for activities described below.

ORAFT 14.2.2.7.1 TRG Hembership DRAFT As a minimum, the Test review G,roup (TRG) shall be composed of managers, supervisors, or engineers from the organizations listed below.

DRAFT -

Performance and Test DRAFT -

Operations DRAFT -

Technical Support DRAFT -

Engineering and Construction DRAFT - Westinghouse (for all matters concerning initial startup testing performed on the NSSS and associated auxiliary systems)

DRAFT The members and their alternates, including the Chairman, shall be i designated in writing by the Vice President, Nuclear Operations.

1 DRAFT The primary function of the TRG is the review and approval of initial startup program test procedures, procedure revisions, and test results.

DRAFT In addition to the above, representatives of other organizations will participate, as requested by the Chairman, i

Draft Version 14.2-14

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' Pagg 16 of 94 CPSES/FSAR 14.2.2.8 Quality r3surance DRAFT The TU Electric Quality Assurance Department is responsible for 68 assuring the quality of construction, plant testing, and operations activities as described in Chapter 17.

DRAFT 14.2.2.9 Qualifications of Key Personnel DRAFT 0423.1 0423.7 0423.21 n The minimum qualifications of individuals -asponsible for review and 68 approval of.preoperational and initial startup test procedures and i results shall be; (1) Bachelor's degree in engineering or the physical sciences and four years of applicable power plant experience; or (2)  ;

high school diploma or equivalent and eight years of applicable power plant experience. iredit for up to two years for related technical training may be sub stituted on a one-for-one time basis. A minimum 40 of two years shall be applicable nuclear power plant experience. I 68 4

The minimum qualifications of individual that direct or supervise the 37 1 conduct of preoperational test at the time of performance of the duties, shall be; (1) Bachelor's degree in engineering or the physical sciences and one year of experience in power plant testing or operation.. Included in the one year shall be three months of DRAFT )

familiarization of system and component operation unique to the design of similar nuclear power plants or (2) a high school diploma or equivalent and four years of experience in power plant testing or j operation or credit for up to two years for related technical training may be substituted on a one-for- one time basis. Included in the  ;

four years shall be three months of familiarization of system and component operation unique to the design of similar nuclear power plants.

14.2-15 Draft Version

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i Enclosure'to TXX-89557 Page 17 of.94 CPSES/FSAR

'37 The minimum qualifications of individuals that direct or supervise:the conduct of initial startup test at the time of performance of the r duties, shall be: (1) Bachelor's degree in engineering or the physical sciences and two years of experience in power plant testing orfoperation. Included in the two years shall. be a minimum of one z year of nuclear power plant testing, operation or training on a nuclear facility, or (2) a high school diploma or equivalent and five u

years of experience in power plant testing of which two years will be nuclear power plant experience. Credit for up to two years for related technical training may be ' substituted on a one-for-one time basis.

DRAFT Test personnel will be indoctrinated in the use of applicable administrative procedures, test procedures and familiarized with applicable quality assurance requirements.

14.2.3 TEST PROCEDURES

~ 14.2.3.1 General DRAFT Preoperational and initial startup tests will be performed in accordance with written approved test procedures. The following sections describe the general methods employed to control procedure development and review, and they also describe the responsibilities of the various organizational units participating in this process.

37 The detailed controls and methods will be' prescribed in the startup administrative procedures and station administrative procedures, as applicable.

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14.2.3.2- Develonnent'of Procedures DRAFT

, _ DRAFT Technical information required for the preparation of_the test procedures will be provided by the appropriate engineering organizations. This information will consist of system descriptions, technical specifications, design drawings and other technical documents which define the functional requirements and performance objectives for the various systeme os;d components. Additional technical data may also be obtained from the various component vendors and other contractors as required.

The applicable functional requirements provided by the system DRAFT designers will be incorporated into the acceptance criteria for each test procedure. This information will also be used by the test engineer in developing the detailed test methods which ensure that the capability of systems and components to function; properly within design specifications is adequately demonstrated.

14.2.3.3 Review and Anoroval of Test Procedures Preoperational and initial test procedures will be reviewed by members of the plant operating staff and appropriate design organizations. 4 Preoperational test procedures will be forwarded to appropriate DRAFT mer.bers of the Joint Test Group for review and comment.

Initial startup test procedure will be forwarded to the appropriate . DRAFT i members of the Test Review Group for review and comment.

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s. The responsibility for final approval of all preoperational and test DRAFT procedu es rests with the Manager, Startup. The responsibility for i final approval of initial startup test procedures rests with the Plant

Manager, i i

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- 11! 14.2.3'4 Format of Test Procedu.tgi _

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I - DRAFT Preoperational and initial startup tests will be prepared based on l s formats specified by administrative procedures. These standard U fcreats will help ensure that each procedure contains the information and instructions required to satisfactorily perform and document the test.

- 11 The procedures' format and content will reflect the guidance provided

, in Regulatory Guide 1.68 as discussed in Appendix 1A(B). The

. standard format will include,' as a minimum. the-following:

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1. Test Objectives:

. DRAFT- A detailed statement of the test objectives and method 9f system or plant operation to be demonstrated.

2.

References:

References to technical specifications, supporting procedures, ,

vendor's manual, or other technical documents will be included as  !

required. ,

1 DRAFT 3. Prerequisites: )

i DRAFT Prerequisites and initial conditions are satisfied and the i necessary prerequisite tests and construction activities have f been satisfactorily completed.

4. Precautions and Limitations:  !

Precautions and limitations relating to personnel safety, equipment integrity, and overall plant safety will be specified.

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/ 5. Instructions: _

DRAFT DRAFT Jhelinstruction'sectionwillcontaindetailedstepbystep instructions for operating t'he system in the test configuration, performing actual-test manipulations, and for use of off-normal procedures such as jumper cables:or mechanical bypasses and restoration of the system to normal status ~following test. The detailed test instructions will utilize normal and emergency

- station operating procedures to the extent practical.

6. Acceptance Criteria:

The performance objectives and functional requirements f9r system operations will be specified. The criteria used to judge the success or failure of the test may be qualitative or quantitative.

7. Data Collection:

Provisions will.be made for recording all pertinent test data regards:'g system conditions and performance. Records will DRAFT

-identify the observer, type of test instrumented 1on used, acceptability of results, and any deficiencies, and will become a part of the permanent station records.-

14.2.3.5 Revisions to Procedures-Revisions to preoperational test procedures will be reviewed by DRAFT appropriate members of the JTG and approved by the Manager, Startup.

Revisions to initial startup test procedures will be reviewed by the appropriate members of the TRG and approved by the Plant Manager.

Ou Preoperational and Initial Startup Test procedure modifications 38 required during conduct of test will be approved as follows:

14.2-19 Draft Version

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38 1. Preoperational Test Procedures ,

p 38 a. Test procedure modifications that do not change the intent i f

of the test will be approved by the system test engineer.

1 DRAFT b. Test procedure modifications that change the intent of the test will be approved by the test engineer and another member of the startup organization qualified to review preoperational test procedures.

38 c. All procedure modifications will be included with the completed procedure and be subject to review and approval with the test result.s as described by paragraph 14.2.5.

l 38  ?. . Initial Startup Test Procedures 38 a. Modifications to initial startup tests that do not change .)

the intent of the test will have the Shift Supervisor's  ;

concurrence and approval of the person in charge of the test.

DRAFT b. Modifications to initial startup tests that change the intent of the test will be reviewed and approved by the l Plant Manager.

14.2.4 CONDUCT OF TEST PROGRAM 14.2.4.1 Administrative Procedure 1 ,

DRAFT- The conduct of the test program will be controlled by administrative procedures. These procedures will prescriba controls for testing l activities such as the following:

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1. Preparation, review and approval, of test procedures

2. . Turnover of systems 37

3. Forniat and content of test procedures

4. Safety and custody tagging procedures 11

5. Temporary system modifications 11

6. Design change processing 11

7. Test' deficiency processing 11

8. Review of Reactor Operating /Startup experiences. l11 14.2.4.2 Prerequisite Testina 40 Startup administrative procedures will be established to ensure that 40 applicable prerequisites are met before testing is initiated. Upon completion of construction phase activities, custody of the component / system will be transferred to TU Electric for conduct of prerequisite testing and preoperational testing. During the turnover

! process, systems and components will be reviewed for completeness, installation damage and conformance with appropriate installation and/or design documents. Outstanding construction, document and test deficiencies will be identified and controlled prior to fuel load.

, 14.2.4.3 Preooerational Testinc DRAFT Technical direction and administration, including test procedure DRAFT preparation, test execution, and data recording, of the preoperational testing is the responsibility of the Startup Depcrtment, with the operating staff retaining responsibility for performing actual equipment operations and maintenance.

14.2-21 Draft Version

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The' Manager, Startup is responsible for the administration and

[ DRAFT.

implementation o'f all preoperational testing activities during the l-startup program.

l l DRAFT The tes* engineers will direct support personnel in the performance of tests and will provide appropriate interface with station operators.

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The Shift Supervisors will be responsible for insuring that the conduct of testing does not place the plant in an unsafe condition at DRAFT any time. Additionally, the shift supervisors and test engineers have l

the authority to terminate or disallow testing at any time.

I DRAFT 14.2.4.4 Initial Startup Testing DRAFT Technical direction and administration, including test procedure preparation, test executica, and data recording, of initial startup testing is the responsibility of the Performance and Test organization, with the operating staff retaining responsibility for performing actual equipment operations and maintenance.

DRAFT The Performar e and Test Manager is responsible for the administration and implementation of all initial startup testing activities during y the test program.

DRAFT Tht test engineers will direct support personnel in the performance of tests and will provide appropriate interface with station operators.

The Shift Supervisors will be responsible for insuring that the conduct of testing does not place the plant in an unsafe condition at any time. Additionally, the Shift Supervisors and test engineers g

have the authority to terminate or disallow testing at any time.

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y .Page 24'of 94, CPSES/FSAR 14.2.4.5 Test Prerequisites DRAFT 'I l

Each test procedure will contain a set of prerequisites or initial DRAFT ,

conditions as' prescribed by administrative procedures. The test  ;

engineer will ensure that all specified prerequisites _are met prior to_ j performing the test. The format for test procedures is described in Section 14.2.3.4. j l

t 14.2.4.6 Phase Evaluation l DRAFT .l l

Between each major phase of the preoperational test program the test' ' DRAFT results for all tests that have been performed will be reviewed by the j l

JTG. '

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Between each major phase of the initial startup test program the test DRAFT l

1 results for all tests that'have been performed will be reviewed by the TRG. 'j This review ensures that all required systems have been tested 11

.l satisfactorily and that test results are approved before proceeding to 1

the next stage of testing. This review is described in Section  !

l' 14.2.5.-

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14.2.4.7 Desian Modifications 0 RAFT l

Modifications to the design of safety-related equipment during the test program may be initiated in order to correct deficiencies discovered as a result of testing. Any such modification will be j referred to the appropriate engineering organization for approval.

Modifications made to safety-related components or systems after completion of preoperational or initial startup testing will be I reviewed for retesting requirements on affected portions of the system.

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l' Enciosure to'TXX-89557' Page 25 of 94 CPSES/FSAR 11 14.2.5 REVIEW, EVALUATION, AND APPROVAL OF TEST RESULTS DRAFT Following completion of 6 particular test, the responsible test engineer will assemble the test data package for evaluation. ,

Prerequisite and preoperational tests will be reviewed by appropriate members of the JTG. Initial startup test results will be reviewed by y appropriate members ol' the TRG.

m 11 Each test data package will be reviewed to ensure that the test has been performed in accordance with the written approved procedure and that all required data, checks, and signatures have been properly recorded and that system performance meets the approved acceptance criteria. ,

DRAFT. Deficiencies identified in the review process will be resolved to the satisfaction of the appropriate review group. If the evaluation 11 indicates that deficiencies in'the test method are responsible for .

unsatisfactory test results, the test procedure will be revised accordingly before retesting is initiated. Whenever an evaluation of test results indicates deficiencies in system performance, the problem will be referred to the appropriate engineering organization for evaluation.

DRAFT The responsibility for_ final approval of preoperational test results rests with the Manager, Startup. The responsibility for final approval of initial startup test results rests with the Plant Manager.

0423.3 11 Following each major phase of 'che test program, test results and/or test status will be reviewed to ensure that all required tests have been performed and that the test results have been approved. This review will ensure that all required systems are operating properly and that testing for the next major phase will be conducted in a safe

' Draft Version 14.2-24

I Enclosure.to TXX-89557 PagG.26.of 94 CPSES/FSAR and efficient manner. >This type of review will be performed to the 40 l

extent required before major test phases such as fuel load, initial n

criticality, and power escalation. During the power escalation 76 l

phase, review and approval of initial startup test procedure results will be completed for each major power plateau prior to proceeding with power ascension testing to the next plateau.

14.2.6 TEST RECORDS Test procedures and test data relating to preoperational and initial startup testing will be retained in accordance with the measure described in Section 17.2.17. " Quality Assurance Records."

- i 14.2.7 CONFORMANCE OF TEST PROGRAMS WITH REGULATORY GUIDES I I

1 The test program will be conducted in accordance with guidance given in the applicable Nuclear Regulatory Commission Regulatory Guides which are listed below. j I

1. Regulatory Guide 1.41, "Preoperational Testing of Redundant On- ' 11 Site Electric Power System to Verify Proper Load Group Assign '4ts* I

2. Regulatory Guide 1.52, " Design. Testing, and Maintenance Criteria 11 q for Atmosphere Cleanup System Air Filtration and Absorption Units of Light-Water-Cooled Nuclear Power Plants"

3. Regulatory Guide 1.68, " Initial Test Programs for Water-Cooled DRAFT I 3

Nuclear Power Plants"

4. Regulatory Guide 1.68.2, " Initial Startup Test Program to 37 Demonstrate D. emote Shutdown Capability for Water Cooled Nuclear Power Plants." l j

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14.2-25 Draft Version

Enclosuro to TXX-89557 Paga 27 of 94- CPSES/FSAR 37- 5, Regulatory Guide 1,69, " Concrete Rad,iation Shields for Nuclear h Power Plants."

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6. Regulatory Guide 1.20. " Comprehensive Vibration Assessment ]

Program for Reactor Internals During Preoperational and Initial Startup Testing."

7. Regulatory Guide 1.79, "Preoperational Testing of Emergency Core i Cooling Systems for Pressurized Water Reactors." i Exception has been taken to certain provisions of the above Regulatory Guides and are discussed in Appendix 1A(B) i 14.2.8 UTILIZATION OF REACTOR OPERATING AND. TESTING EXPERIENCE IN DEVELOPMENT OF TEST PROGRAM DP. AFT The CPSES test program will utilize information gained from operating and testing experience in other similar nuclear plants. This information will be used to provide guidance in developing test procedures and schedules and to alert personnel to potential pr Olem areas in the testing program.

DRAFT The development of this program for utilizing testing and operating l experience is the responsibility of the Vice President, Nuclear Operations with the direct implementation of the program being the responsibility of the Manager, Startup and the Performance and Test Manager,

, DRAFT Significant event information received from NSAC and INPO will be l reviewed by the test organization to identify special testing which should be included in the test program.

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The operating experience program'will consist of an initial review.to be. administered prior to conducting preoperational tests and an ongoing review during the remainder of the-test program. The initial

! review will examine all pertinent operating data and' abnormal events on similar plants which occurred during a period of two years prior to the review. The review will be conducted so as to allow sufficient time for data to be analyzed and incorporated in test procedures. Any new information will be reviewed on a regular basis during the test p -

program so as to address current testing problems.

Additionally, testing and operating experience gained from Unit I will be incorporated into the Unit 2 test program.

14.2.9 TRIAL USE OF PLANT OPERATING AND EMERGENCY PROCEDURES The plant operating, emergency, and surveillance procedures will be use-tested during the test program and will also be used in the development of preoperetional arid initial startup prncedures to the extent practical. The trial use of operating procedures serves to familiarize operating personnel with systems and plant operation during the testing phase and also serves to assure the adequacy of the procedures under actual or simulated operating conditions before plant operation begins.

Prior to fuel load, draft operating procedures may be utilized for equipment operation and may be informally altered to meet special test considerations.

In general the development of plant operating procedures will take place in approximately the same time frame as the preparation of preoperational and initial startup test procedures. The operating procedures will be revised as necessary to reflect experience gained during the actual testing.

14.2-27 Draft Version

Enclosuro to TXX-89557 'l'

.Paga 29 of 94 CPSES/FSAR DRAFT .During the test program, operating procedures employed for periodic tests and inspections may be used directly for certain preoperational and initial-startup tests. Operating procedures used directly for 44 preoperational or initial startup tests to obtt.in quantitative data to be used for evaluation of syster, performance will be performed in accordance with the CPSES Station Administrative Manual.

14.2.10 INITIAL FUEL LOADING, CRITICALITY, AND POWER OPERATION Fuel loading will begin after the required preoperational tests are satisfactorily completed. At the completion of fuel loading, the reactor upper internals and pressure vessel head will be installed and additional mechanical and electrical tests will be performed to prepare the plant for nuclear operation. After final precriticci tests, nuclear operation of the reactor will.begin. This phase of testing includes initial criticality, low power testing and power level escalation. The purpose of these tests is to establish the

< operational characteristics of the unit and core, to acquire data for the proper calibration of setpoints, and to ensure that operation is within license requirements. Section 14.2.12.2 summarizes the tests which will be performed from initial criticality to rated power. The core loading and post loading tests are described below.

14.2.10.1 Fuel Loadina 0423.5 DRAFT The overall responsibility for coordination of initial core loading activities will be exercised Ly the Plant Manager, or his designated representative with technical assistance provided by Westinghouse.

2 The overall process of initial core loading will be directed from the operating floor of the containment structure by a licensed Senior Reactor Operator.

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The core ' configuration will be specified as part of the core design L studies conducted well in advance of fuel loading. In the event mechanical damage is sustained during core loading operations to a fuel-assembly of a type for which no spare is available onsite, an-alternate core loading scheme will'be determined. Any such changes will be approved by the appropriate Westinghouse personnel. ,

Core loading procedures will specify the condition of fluid systems to  !

prevent inadvertent cha iges in bcron concentration of the reactor coolant; the movement of fuel to preclude the possibility of '

mechanical damage: the conditions under which loading can proceed; and the responsibility and authority for continuous and complete fuel and ]

core componerit accountability. ,

The following conditions will be met prior to core loading:

1

-1. The reactor Containment structure will be complete and Containment integrity established and maintained during fuel loading.  ;

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2. Fuel handling tools and equipment will have been checked out and operators familiarized in the use and operation of equipment.

Inspections of fuel assemblies, rod cluster control. assemblies, and reactor vessel will be satisfactorily completed. i

3. 'The re ator vessel and associated components will be in a state j of readiness to receive fuel. Water level will be maintained above the bottom of the nozzles and recirculation maintained to g

assure the required boron concentration. Boron concentration can be increased via the recirculation path or directly to the open vessel, j j

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14.2-29 Draft Version

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Page 31'of 94 CPSES/FSAR  !

!' < -Criteria for safe loading require that loading operations stop.

immediately if any of the following conditions occur.

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1. An unanticipated' increase'in the neutron count rates by a factor l of.two occurs on all responding nuclear channels'during any l single loading step after the initial nucleus of eight fuel f

' assemblies is loaded.

2. .An unanticipated increase in the count rate by a factor of five' jl on.any indivtdual responding nuclear channel during any single l loading step after the initial nucleus of eight fuel assemblies l 1s-loaded.  !

l 76 3. An unanticipated decrease in boron concentration greater than 20 ppm is determined from two successive samples of the reactor coolant.  ;

i Loading operations may not be re-started until the situation is j evaluated. An alarm in the Containment and main Control Room will be

. coupled to the source range channels with a setpoint equal to or less than five times the current. count rate. This alarm will automatically 1

alert the loading operation personnel of high count rate and an 1

immediate stop of all operations'will be required until the situation is evaluated. In the event the evacuation alare is actuated during core loading and after it- has been determined that no hazards to personnel exist, preselected personnel will be permitted to reerter )

the Containment to evaluate the cause and determine future action, j

p A The core will be assembled in the reactor vessel, submerged in reactor l l.

grade water containing sufficient dissolved boric acid to maintain a calculated core effective multiplication factor of 0.95 or lower. The i

refueling cavity will be dry during initial core loading. Core  !

l moderator chemistry conditions (particularly boron concentration) will be prescribed in the core loading procedure document and verified by chemical analysis of moderator samples taken prior to and during core i loading operations.

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Enclosure to TXX-89557 Page 32 of:94' CPSES/FSAR At.least two artificial. neutron sources will be introduced into the core at specified points in the core during the loading program to ensure a detector response of.at least 2 counts pc? second

[ attributable ,to neutrons.

L LCore loading instrumentation consists of two permanently installed source range (pulse type) nuclear channels and two temporary incore source range channels. A third temporary channel may also be.used as a spare. .The permanent channels, when responding, will be monitored in the main Control Room and the temporary channels will be installed and monitored in the Containment. At least one. permanent channel will be equipped with an audible count rate indicator. 'Both plant channels will have the capability.of displaying the neutron flux level on a strip chart recorder. The temporary channels will indicate on scalers and a minimum of one channel will be recorded on a strip chart recorder Minimum count rates of two counts per second, attributable to core neutrons will be required on at least two of the four (i.e.

two temporary and two permanent source range detectors) available nuclear source channels at all times following installation of the initial nucleus of eight fuel assemblies. A response check of nuclear instruments to a neutron source will be performed within eight hours prior to loading of the core, or upon resumption of loading if delay is for more than eight hours.

Fuel assemblies together with inserted components (control rod assemblies, burnable poison inserts, source spider, or thimble plugging devices) will be placed in the reactor vessel one at a time

- according1to a previously established an'd approved sequence developed to provide reliable core monitoring with minimum possibility of core O.

mechanical damage. The core loading procedure documents prest. ribe the successive movements of each fuel assembly and its specified inserts from its initial position in the storage racks to its final position in the core. Checks will be made of component serial numbers and types at successive transfer points to guard against possible l ..

14.2-31 Draft Version

[ Enclosure to TXX-89557 PagG.33 of 94 - CPSES/FSAR

' inadvertent exchanges or substitutions of componcats. Fuel assembly.

status boards will be maintained throughout the core loading operation.

An initial nucleus of eight fuel assemblies,'one containing a neutron source, is the minimum source fuel nucleus which will permit subsequent meaningful inverse count rate monitoring. This initial nucleus is determined by calculation to be markedly subcritical (Keff10.95) under the required conditions of loading.

Each subsequent fuel addition will be accompanied by detailed neutron count rate monitoring to determine that the just-loaded fuel assembly does not excessively increase t,he count rate and that the extrapolated inverse count rate ratio is behaving as expected. These results for each loading step will be evaluated before the next fuel assembly is loaded. The final, as loaded, core configuration will be subcritical (Keff10.95) under the required loading conditions.

14.2.10.2- Initial Criticality Prior to initial criticality, the following tests will tw performed I and the results evaluated.

1. At the completion of core loading, tee reactor upper internals and pressure vessel head will be installed. A pressure test will be conducted after filling and venting is completed to check the leak tightness of the vessel head installation.

2. Mechanical and electrical tests will be performed on the control rod drive mechanisms. These tests include a complete operational checkout of the mechanisms and calibration of the individual rod position indicators.

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3. Test will-be performed on the reactor trip circuits:to test ~

manual trip-operation, and actual control rod assembly drop times ,

will be measured for each control rod assembly. ' At all times

! that the control rod drive mechanisms are being tested, the boron i concentration in the coolant will be maintained such that the shutdown margin requirements.specified in the Technical l

Specifications are met. During individual RCCA or RCC bank motion, source range instrumentation will be monitored for unexpected changes in core reactivity.

4. The Reactor Control and Reactor Protection Systems will be- ,

checked with simulated inputs to produce trip signals for various trip conditions. ,

5. A functional electrical and mechanical check will be made of the incore nuclear flux mapping system near norms 1 operating temperature and pressure. j Initial' criticality will be achieved by a combination of shutdown and  !

control bank withdrawal and reactor coolant fystem boron concentration j dilution. The plant conditions, precautions and specific instructions for the approach to criticality will be specified by approved procedures. l 4

Initially, the shutdown and control banks of control rods will be t

withdrawn incrementally in the normal withdrawal sequence leaving the 1 last withdrawn control bank partially inserted in the core to provide .

J' effective control when criticality is achieved. The boron concentration in the Reactor Coolant System will then be reduced and criticaljtyachievedbyborondilutionorbysubsequentrodwithdrawal ,

following boron dilution. Throughout this period, samples of the primary coolant will be obtained and analyzed for boron concentration.

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14.2-33 Draft Version i

i - Enclosura to TXX-89557 Paga 35 of.94 CPSES/FSAR Inverse count rate ratio monitoring, usin,g data from the normal plant source range instrumentation, will be used as an indication of the proximity and rate of approach to criticality. Inverse count rate ratio data will be plotted as a function of rod bank position during rod motion and as a function of reactor makeup water addition during reactor coolant system boron concentration reduction.

14.2.10.3 Low Power Testino Following initial criticality, a program of reactor physics measurements will be undertaken to verify that the basic static and kinetic characteristics of the core are as expected and that the values of the kinetic coefficients assumed in the safeguards anLlysis are conservative.

Procedures will specify the sequence of tests and measurements to be conducted and the conditions under which each is to be performed in order to ensure both safety of operation end the validity and consistency of the results obtained. If test results deviate significantly from design predictions, if unacceptable behavior is revealed, or if unexplained anomalies develop, the plant will be brought to a safe stable condition and the situation reviewed to determine the course of subsequent plant operation.

These measurements will be made at low power and primarily at or near 76 normal operating temperature and pressure. Measurements will be made in order to verify the calculated values of control rod bank reactivity worths, the isothermal temperature coefficient, f

j differential boron concentration reactivity worth, and critical boron DRAFT} concentrations.[In addition, measurements of the relative cower ]

distributions will be made, and tests wil! be conducted on the gg g (kn3c., instrumentation inc1cding power and intermediate range nuclear l channels.

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Draft Version 14.2-34

h . Enclosure'to TXX-89557 Page'36fof 94' CPSES/FSAR I" 14.2.10.4 fower Level Escalation ,

' After_'the operating characteristics of the reactor have been verified g by -low power testing, a program of power level escalation will bring the unit to its full rated power level in successive stages. The minimum test requirements for each successive stage of power escalation will be specified in the initial startup test procedures.

Measurements will be made to determine the relative power distribution in the core as functions of power level and control assembly bank.

position.

Secondary system heat balance measurements will ensure that the indications of power level are consistent and provide bases for 3 calibration of the power range nuclear channels. The ability of the Reactor Coolant System to respond effectively to signals from primary and secondary instrumentation undsr a variety of conditions encountered in normal operations will be verified.

(

At prescribed power levels the dynamic response characteristics of the primary and secondary systems will be evaluated. System response characteristics will be measured for design step load changes, rapid load reduction, and plant trips.

Adequacy nf radiation shielding will be verified by gamma ano neutron radiation surveys at selected points inside the Containment Building and throughout the station site et various power levels. Periodic sampling will be performed to verify tne chemical and radio-chemical analysis of the reactor coolant.

14.2.11 TEST FROGRAM SCHEDULE The sequential schedule for the preoperational testing of individual systems and components is shown in Figure 14.2-3. The sequential.

M 14.2-35 Draft Version

Enclosure'to TXX-89557 9

CPSES/FSAR schedule for initial startup performed following fuel loading is shown in Figure 14.2-4. These schedules show certain milestones at which time the tests, or portions of tests, will be completed and the overall time , frame in which the tests will be conducted. The detailed schedules for testing will be prepared, reviewed and revised on a continuing basis as station construction r. ogresses.

Preoperational testing of the various systems and components, which will continue up to fuel loading is scheduled to commence at a time 10 to 15 months prior to fuel load. Initial startup tests are scheduled to be conducted over a period of approximately five months subsequent to fuel load. Fuel load, initial criticality, and power ascension tests are scheduled to be accomplished durir.; this time period.

DRAFT Station structures, systems, and components which are relied upon to prevent or mitigate consequences of postulated accidents will be fully tested to the extent practical prior to exceeding the 50 percent power level. Certain systems will have part of the preoperational testing performed after fuel load due to system configuration (e.g. control rod drive mechanism require fuel in the vessel to be fully tested).

Such systems will be sufficiently tested prior to fuel load to provide reasonable essurance of successful testing after fuel load.

The development cf test procedures will be en ongoing process, which will consist of preparation, review, and revision. The preparation of preoperational test procedures is scheduled to start no later than 15 months prior to feel loading.

'O Preparation of initial startup procedures is scheduled to commence l 76 approximately five months prior to fuel 1cading. Preoperational and initial startup test procedures will be available for exaninetion by the NRC regional personne'l approximately 60 days prior to the scheduled performance of the test, and, approximately 60 days prior to the scheduled fuel loadine date.

Draft Version 14.2-36

Enclosure to TXX-89557 Page 38 of 94 CPSES/FSAR 38 Testing efforts on CPSES Unit I will not be diluted by activities on Unit 2.

14.2.12 INDIVIDUAL TEST DESCRIPTION; 14.2.12.1 Precoerational Testi The test summaries for each of the preoperational tests to be performed, along with an index to these summaries, are provided in Table 14.2-2. These summaries describe the various tests which are 11 specified as preoperational tests in Regulatory Guide 1.68 as discussed in Appendix 1A(B). T,he scope and titles of these summaries ma'y not in all cases correspond directly to the actual test procedures which will be used during the Startup Program. Certain test procedures may include more than one test as described in these summaries, and in some cases tests described in one summary may be covered under more than one procedure. The overall scope and content of the tests described in these summaries will be addressed in final procedures.

There will be certain prerequisites which will apply in general to all preoperational tests. For convenience these general prerequisites are l

listed here rather than included in each summary.

l l

General Prerequisites:

1. Construction activities have been completed on the system and on the necessary portions of supporting systems and any defit.iencies 3

l have been properly dispositioned.

2. Functional operability of individual components or subsysterns has been demonstrated for items stch n valves, pumps, motors, instrumentation, and controls.

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7 3. Test equipment necessary for test performance is available and l

]$ 0 calibrated.

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4. Electrical power and air supplies are'available as-required for':

test. performance.

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. , 14.2.12.2 Initial Startuo Testi, 54 Thefinitial startup phase of the test program consists of preoperational tests deferred to the Initial Startup Program, Initial Startup Tests prior to and including fuel loading, precritical tests.

initial criticality, low power physics ~ tests, and power ascension tests. Fuel load and initial criticality procedures and tests are described in Section 14.2.10. Test summaries providing descriptions of all other major initial startup tests 'are provided in Table 14.2-3

.along with an.index for these test summaries.

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Pago 40 of 94 j l

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l CHAIRMAN OPERATIONS TECHNICAL ENGBEEROFJ WESTMMOUSE PERFORMANCE SUPPOAT AfD TEST i

COMANCHE PEAK S.E.S.

FINAL SAFETY ANALYSIS REPORT UNITS 1 and 2 TEST REVIEW GROUP FIGURE 14.2-1

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' Enclosure to TXX-89557.

Page 41 of 94 I CHAIRMAN OPERATIONS TECHNICAL ENGINEERING WESTINGHOUSE STARTUP SUPPORT I

i COMANCHE PEAK S.E.S.

FINAL SAFETY ANALYSIS REPORT UNITS 1 and 2 JOINT TEST GROUP FIGURE 14.2 2 f

Enclosura to TXX-89557- CPSES FSAR AMENDMENT )

Pag 2.42 of 94 ' DETAILED DESCRIPTION i

FSAR Page (as amended) fr_92R Description

i. 14.2-1, 2 2 See Page No(s):03 thru 38, F14.2-1 and F14.2-2 Reorganization of Nuclear Operations Update:

As a result of the reorganization of the Nuclear Operations function, specifically the division of responsibilities between Startup ans Performance and Test, certain operational' functions described in Section 14.2 have been reassigned to provide better centralized management direction and control.

Significant portions of the text for Section 14.2 have been reorganized and rewtitten to provide editorial corrections, improve clarity of meaning and provide consistency with other sections of the FSAR.

FSAR Change Request Number: 89-517.1 Related SER Section: 14 SER/SSER Impatt: No 14.2-1, 2 4 See Page No(s):03, 09 - 13, 15, 16, 20 - 24 Provides editorial changes to Sections 14.2.1, 14.2.2.1, 14.2.2.4, 14.2.2.5, 14.2.2.9 and-14.2.4 to update job titles and to reflect the separation of responsibilities between Startup and Performance and Test.

Editorial:

See Description for the update of Section 14.2.

FSAR Change Request Number: 89-517.2 Related SER Section: 14 SER/SSER Impact: No 14.2-4, 5 2 See Page No(s):06 Provides update to Section 14.2.2.2 which defines the Performance and Test organizational responsibilities.

Update:

See Description for the update of Section 14.2.

FSAR Change Request Number: 89-517.3 Related SER Section: 14 SER/SSER Impact: No 14.2-6, 7 2 See Page No(s):08 and 09 Provides update to Section 14.2.2.3 which defines the Startup Department responsibilities.

L' Update:

See Description for the update of Section 14.2.

FSAR Change Request Number: 89-517.4 Related SER Section: 14 SER/SSER Impact: No

7 Enclosure to TXX-89557. CPSES FSAR AMENDMENT ',

Page 43 of 94 DETAILED. DESCRIPTION j FSAR Page.

(as

• W ) Gr0UD DeScr1Dtion 14.2-13 2 Provides update to Section 14.2.2.6 to reflect tF1 modified JTG responsibilities and memberships. The JTG L is now charged with specifically reviewing Startup in lieu of Test activites with a member from the Startup organization.

Update:

See Description for the update of Section 14.2.

FSAR Change Request Number: 89-517.5 Related SER Section: 14 SER/SSER Impact: No 14.2-14 2 Provides update to Section 14.2.2.7 to define the Test' Review Group (TRG) responsibilities and memberships.

he TRG is charged with specifically reviewing Initial Startup testing activites with a member from the Performance and Test organization.

Update:

See Description for the update of Section 14.2.

FSAR Change Request Number: 89-517.6 Related SER Section: 14 SER/SSER Impact: No 14.2-15 4 Provides clarification to Section 14.2.2.9 on minimum qualification of individuals that direct or supervise the conduct of preoperational tests.

Clarification:

Clarifies wording carried over from 0423.7 to remove confusion of meaning and to provide consistency with FSAR Chapter 13. These changes do not change the intent of the specified qualification requirements.

FSAR Change Request Number: 89-517.9 Related SER Section: 14 SER/SSER Impact: No 14.2-16. 17 2 See Page No(s):18 thru 20 Provides update to Section 14.2.3 to establish review responsibilities for the TRG and JTG: defines the Plant Mangager as approval authority for ISU test procedures:

and Manager. Startup as approval authority for preop test procedures.

Update:

See Description for the update of Section 14.2.

FSAR Change Request Number: 89-517.7&8 Related SER Section: 14 SER/SSER Impact: No 14.2-24, 25 2 Provides update to Section 14.2.5 to define the Plant Manager as approval authority for ISU test results and

5 FSAR AMENDMENT

'Encicsuro to'TXX-89557 DETAILED DESCRIPTION Pageg44 of 94 FSAR Page-

p. (as amended) Group Description the Manager, Startup as approval authority for preop i test results.

. Update:

See Description for the update of Section 14.2.

FSAR Change Request Number: 89-517.7&B Related SER Section: 14 F

SER/SSER Impact: No Figure 14.2-1 2 Updates F14.2-1 to reflect the new Test Review Group (TRG) organization.

L Update:

See Description for the update of Section 14.2 and

p. 14.2-14.

FSAR Change Request Number: 89-517.1 Related SER Section: 14 SER/SSER Impact: No Figure 14.2-2 2 Updates F14.2-2 to reflect the modified Joint Test Group (JTG) organization.

Update:

See Description for the update of Section 14.2 and

p. 14.2-13.

FSAR Change Request Number: 89-517.1 Related SER Section: 14 SER/SSER Impact: No c-

, H Enclosure ~to TXX-89557

-Page 45 of 94

-14' INITIAL TEST PROGRAN The' testing activit'fes to be performed on safety-related systems at Comanche Peak are divided into three major phases: prerequisite testing, preoperational testing, and initial startup testing. .

-Prerequisite testing will be conducted to verify the integrity, proper installa- i tion, cleanliness, and functional operability of the system components.

Preoperational testing will be performed to demonstrate the capability of systems, structures. and components to meet safety-related performance require-ments. These tests will be performed on plant systems, structures, and compo-nents that are designed to perform a nuclear safety-related function. Preopera-tional testing will be completed before fuel loading with certain limited exceptions where tests or parts of tests will be deferred until the core has been loaded. In such cases, sufficient testing will be performed before fuel loading to provide reasonable assurance that the postloading tests will be successful.

Initial startup tests will be performed beginning with fuel loading and ending with commercial operation. The intent of these tests is to ensure that fuel loading is effected in a safe manner; that the plant is safely brought to rated capacity; that plant performance is satisfactory in tems of established design criteria; and to demonstrate, where practical, that the plant is capable of withstanding anticipated transients and postulated accidents. The staff review concentrated on the administration of the test program and the complete-ness of.the prerequisite, preoperational, and startup tests. For example, the staff's Safety Evaluction Report issued at completion of the Construction Permit review (CP SER) was re examined to determine 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 w'th the facility design and nomenclature. Chapters 13 and 17 were reviewed for familiarization with the applicant's organizational structure, qualifications, administrative controls, and quality assurance program as they apply to or impact the initial test program. Chapter 15 was reviewed to identify assumptions pertaining to perform-

'ance characteristics that should be verified by testing and to identify all structures, systems, components, and design features that were assumed to function (either explicitly or implicitly) in the accident analysis. Licensee Event Reports for operating reactors of similar design were reviewed to identify potentially serious eventa and chronic or generic problems that might warrant special test consideration. Stanatard Technical Specifications for Westinghouse PWRs were reviewed to identify all structures, systems, and components that d

would be relied upon for establishing conformance with safety limits or limiting

, conditions for operations. Finally, the Startup Test Reports for other PWR plants were reviewed to identify problem areas that should be emphasized in the Comanche Peak initial test program.

The object of the staff rev4ew 4f.FSAR Chapter 14 is to determine whether the acceptance criteria stated ir. the Standard Review Plan are met. The staff review covered several aspects of the initial test program including the following major considerations:

14-1

En' closure to TXX-89557 j

Page 46 of 94 i

(1) The appliqant's organization and staff for performing the initial test i program were reviewed. The staff concludes that an adequate number of appropriately qualified personnel are assigned to develop test procedures, '

conduct the tests, and review the results of the tests. Plant staff personnel are utilized to maximize the training benefits of the test program.

(2) The applicant stated that_ the test procedures were developed using input-from the NSSS vendor the architect engineer, the applicant's en staff,andotherequipmentsuppliersandcontractorsasneeded.gineering The applicant also stated that a review of operating experiences at similar p bnts was factored into the development of the test procedures.

(3) The applicant-stated that the tests are being conducted using approved test procedures and that 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 stated that administrative procedures also cover implementation of modifications or repair requirements identified as being required by the tests and any necessary retesting.

(4) The applicant stated that the results of each test are reviewed for-technical adequacy and completeness by qualified personnel, including NSSS vendor and architect engineer personnel as appropriate. Preopera-tional test results are reviewed before fuel loading, and the startup .

test results from each activity or power level will be reviewed before the next activity or power level.

(5) The applicant stated that normal plant operating and emergency procedures are used in performing the initial test program, thereb correctness of the procedures to the extent practical. y verifying the (6) The appifcant's schedule for conducting the initial test program allowed adequate time to conduct all preoperat'onal~ tests and startup tests. The sequential schedule for performing the startup tests established (a) that systems required to prevent, limit, or mitigate the consequences of postulated accidents will be tested before 255 of rated power is exceeded and (b) that the safety of the plant will not be dependent on the perfor-mance of untested systems, structures, and components. Preoperational test procedures.will be available for IE review at least 30 days before the expected performance of the test, and startu available at least 90 days before fuel loading. p test procedures will be (7) The abstract of each test procedure presented in Chapter 14 of the FSAR was reviewed. The staff verified that there are test abstracts for those structures, systeen, components, and design features that: (a) will be used for shutdown and cooldown of the reactor under norsal plant condi-tions and for maintaining the reactor in a safe condition for an extended shutdown period; under transient ((6) will infrequent be used frequent or moderately for shutdown events) conditions and cooldown and of postulated accident conditions and for maintain 19g the reactor in a safe condition for an extended shutdown period follow ng such conditions; (c) will be used for establishing conformance with safety ifnits of 14-2

U Enclosure to TXX-89557 Page 47 of 94 1

limiting conditions for o technical specifications;peration that will be included in the facility (d) arI or will be relied on to support or ensure the operations of engineered safety features within desiga limits; (e) are assumed to function er for

[- which credit is taken in the accident analysis of the facility, a.s described in the FSAR; and (f) will be used to process, store, control, or limit  !

the release of radioactive materials.

(8) The test objective, prerequisites, test methods, and acceptance criteria for each test abstract were reviewed in sufficient detail to estsblish that the functioral adequacy of the structures, systems, components, and design features will be demonstrated.

' (9) The test program's conformance with applicable Regulatory Guides was reviewed. he review included: Regulatory Guides 1.20, 1.41, 1.52, 1.68, 1.68.2, 1.7S, 1.80, and 1.108.

The applicant made a number of changes to the initial test program because of the staff's comments. Examples of these changes include (1) Administrative controls were added to ensure that all test procedure modifications that alter the acceptance criteria or test intent would be appropriately reviewed.

(2) Additional (five consecutive, cold quick starts) testing of the staas-driven auxiliary foodwater pumps was added to further demonstrate system reliability.

(3) Testing to verify that the reactor cooled pipe penetration cooling system will maintain the pipe tunnel concrete temperature within design Ifmits was added.

(4) The acceptance criteria for certain preoperational and startup tests involving reactor protection system hardware instrumentation delay time, remote p ant shutdown validation, diesel generator starting requirements, snubber inspection, battery charghr capac' ty, contairrtent spray flowpath verification, sampling system flowpath and holdup, and power-operated relief valve capacities were modified. Modified acceptance criteria were required to more accurately reflect the actual test conditions and to provide assurance that system performance will be in conformance with design predictions.

(5) The minimum qualifications for personnel who direct or supervise the conduct of testing were upgraded to conform with acceptable industry standards. .

t (6) Certain system tests were expanded to ensure that comprehensive system and component testing was scheduled. Example systes included station service water, component cooling water, vent and drain, spent fuel pool cooling, residual heat Tomoval, chemical and volume control, safety inject'on, containment ventilation, diesel generator com tion, ac and de power distribution, reactor protection, rod partment control,ventila-staan generator safety and relief valves, main steam and feedwater isolat' on valves, auxiliary feedwater, pressurizer safety and relief valves, and engineered safety features.

, 14-3

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L ,.. Enc 1csura to TXX-89557 P:ga 48 of 94 Based on its review, including the items discussed above, the staff concludes that the initial test program described in the application meets the accest-ance criteria of SRP Sect' on 14.2 and that the successful completion of tie program will demonstrate the functional adequacy of slant structures, systems, and components. The staff also has concluded that t)e initial test program described meets the test requirements of GDC 1 and Section XI of 10:CFR 50 Appendix 8..

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i:.- , Enclosure to TXXa89557.

. Page 49 of 94 Bullet Section 14 - INITI AL-TEST. PROGRAM POE8 .18. .The FSAR has been revised to reflect;. changes in the-Test Department to define and separate responsibilities of the organizations associated with startup and performance testing (includes Figures 14.2-1 and 14.2-2).

Enclosure to TXX-89557 Paga 50 of 94

, 14.2 INITIAL TEST PROGRAM 14.2.1

SUMMARY

OF TEST PROGRAM AND OBJECTIVES The purpose of the program for Comanche Ped Steam Electric Station (CPSES) is to assure that the installed station structures, systems and components will be subjected to tests as required to verify that the plant has been properly designed and constructed and is ready to operate in a manner that will not endang2r the health and safety of the public, and to provide assurance of total plant reliability for operation. The :te.st.rt ; program will also ensure that the procedures for operating the plant safely have been evaluated and demonstrated, and that the operating organization is knowledgeable about the plant and procedures and is prepared to safely operate the plant fMCal0M.5 test

= Lf The necessary procedures to control, implement, and document the 4eet-4lN program are established by th: T::t ^ ; r'n .t .'.iini;tr:ti- ":: d l

d th: St:ti:n "tiai;tr:ti n "r re!, and summarized in the following l sections. TU Electric, as .ne applicant, has responsibility for l overall direction and management of the :Y$f*3; program.

The testing activities to be perfonned on s'afety-related systems at l11 the CPSES are divided into three major phases: prerequisite testing, l preoperational testing and initial startup testing. Prerequisite l testing will be conducted in order to verify the integrity, proper l 3 installation, cleanliness, and functional operability of the system l components. l e

Enclosura to TXX-89557 Page 51 of 9 CPSES/FSAR pre:perational testing will be performed in order to demonstrate e th capability of systems, structures, and components to meet safet related performance requirements.

These tests will be performed on 57 plant systems, structures, and components that are designed to p l a neclear safety-related function.

These include those systems and l components which are identified as quality related items in Table l 17A-1 of FSAR Section 17A.

In addition, systems and components which have applicable testing requirements specified 'n Regulatory Guide 11 1.68 and discussed in Appendix 1A(B) will be subjected to l preoperational tests.

Summaries of individual preoperational tests lareprovidedinSection14.2.12.

54 l Preoperational testing will be completed prior to fuel load with lcertainlimitedexceptionswheretestsorpartsoftestswillbe l deferred to the Initial Startup Test Program. Such an exception is the complete testing of the control rod drive mechanisms attached.

with the rods In such cases sufficient tests will be performed prior to fuel loading to provide reasonable assurance that the post-loadi tests will be successful.

54 l Initial startup tests will be performed beginning with activities l leading to fuel loading and ending with full power operation. The 1 intent of these tests is to assure that tests deferred from l preoperational test program are performed; that fuel loading is l effected in a safe manner; that the plant is safely brought to rated l capacity; that plant performance is satisfactory in terms of I established design criteria; and to demonstrate, where practical, that l the plant is capable of withstanding anticipated transients and lpostulatedaccidents.

Testing activities related to fuel load and initial criticality are described in Section 14.2.10.

Initial startup tests including lower power physics testing and power ascension testing are described in the test summaries provided in Section l 14.2.12. I

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fcbruary 15, 1988 -

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3- . Enclosure to TXX-89557 Pago 52 of 94 CPSES/fSAR For. systems and components which have no nuclear safety-related requirements, acceptance testing will be performed to verify proper I system performance and to ensure reliable and efficient operation of the plant. [There are no unique y "first M = W " 2; iga fegu d f require special testing provisions.

i. Preoperational and initial startup tests will be conducted in accordance with approved test / procedures. Review, approval, and l68 revision of test procedures and the evaluation and disposition of test l results will be accomplished by methods specified in the 4est approjonMte 0:p r ;at / administrative procedures and summarized in Section 14.2.3. l The startup program will utilize, to the extent practical., operations personnel and operating procedures to provide familiarization with the plant installation and demonstrate the adequacy of operating procedures.

Preoperational A/esting activities will be coordinated through a Joint Test Group l68 (JTG), as described in Section 14.2.2.f.' /dtid startup test /og l astivities will be c,edelinsted tbromb n Test Review l68 Grevy (TR G) , $S denef bed in SCCtIM 'N' 2* L 7'

'Enclosur5 to TXX-89557 Paga 53 of 94:

14.2.2 ORGANIZATION AND STAFFING 14.2.2.1 General Description l

TU Electric is responsible for the overall administration and techn' cal direction of the e i

CPSES test program. The Performance'and Test Manager is responsible for the coordination of the initial startup test program. The Manager, Startup ic responsible for the coordination, direction, and l implementation of the prerequisite and preoperational test program. l The Performance and Test and Startup organizations are shown in Figures 13.1-2 and 13.1-3. The TRG and JTG organizations are shown in Figures 14.2-1 and 14.2-2. The SORC membership is described in Section 13.4.1.1.1.

N c4e.: Sa614.2.2. has been si abd4 3 teoised heke., a tetspeJ osa aka and pose'uesdn ,

k has been used +o more, eteel3 EsFccde +he requikel chnges dohbt.h uerston also mcludes adchfionol harel mocked 9 @NeMi"S .

j' Enclosure to TXX-89557 P

' Page 54 of 94 14.2.2.2 Performance and Test,Orannirational Responsibilities l

Ar#orneam:eard d/yAltatioA l 68 l The duties and responsibilities of theATest 0 p:rt=;tAunder the l direction of the ":=; r., St:rtupvand Testrare as follows:

Adamnue s*kyer 38 l1. Preparation of testing schedules;

2. Coordination with the appropriate engineering' organizations to resolve component / system design and operating problems; 3 Preparation of test procedures; sde phe a

4. Conduct tests to demonstrate de; rite :r.d .gostion.f; :::_i:=nt :,-d y;t: p:rf: =:= :.

5. Perform the initial startup test sequence to ensm. a safe and orderly power ascension program.

e WP

Enclosure to TXX-89557 Page.55 of 94 i

Support personnel including craft labor and technicians who will be engaged i testing activities may be supplied by TU Electric or contractors. .... .. ... . gpuch support will vary according to test program requirements.

14.2.2.2.1 Performance and Test Manager The responsibilities of the Performance and Test Manager include:

Pe d w m Development and implementation of the, Test ";;;;ctc ..;- 68 h.

surveillance tests; Relvaleelfrm

2. Developme.it and implementation of the Initial Startup Test 76 14.22.23 Program; and .

cptruflooi, (b8AiE%4CE 76 3 # coordination of testing with the activities of fengineering, construction-1 e=4 organizations.

q A

4. Administration of the development of plans and schedules l68 z:;;c O ,; t,',e stet.; :' t h C ;t ; ; n ; r . g{g ,*g-

5. Administration of the development of individual test procedures; l38

(.. . Review test procedures and results or assure that suc l68 v{

are conducted by qualified personnel within the3Test  ; [

A b newnee 4 2 Assure proper and timely notifications and repod.s pertaining to a31 testing activities are submitted to the Nuclear Regulatory Cassission and other regulatory agencies.

1

Enclosure to. TXX-89557 PagG 56 of 94 14.2.2.2.2 Performance and Test Engineers (Ted rdocM Irtm 14 ,7. 2. 7 4 )

Tha duties and responsibilities of the Performance and Test engineers include:

1. Preparation of assigned test procedures to direct and guide specific tests in accordance with a standard format;

2. Direction to support personnel and others during performance of tests including appropriate interface with station operators;

3. Ensuring the safety of personnel and plant equipment during testing;

4. Familiarization of support personnel with specific tests;

t. Identification of deficiencies that could adversely affect test perfo mance;

6. Assembly of test data and preparation of test reports for evaluation of test results by others; and 0

J.  !;;k ;t:thn cf teggh; i;.ecek n; ::d ~

~7 4 Responsibility to disallow or terminate testing due to conditions which could endanger personnel or equipment.

1 l

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Enclosure to TXX-89557 Page 57 of 94 14.2.2.3 Starton Denartment Organizational Resoonsib!ities (Text relocchc! ftcM Id'2 *h 3far&f

-68 l The dutits and responsibilities of the 4est Department under the l direction of the Manager, Startup d int are as follows:

38 l1. Preparation of testing schedules; 38 l2. Coordination with appropriate construction organizations for l release of completed components / systems to facilitate testing; 38 l 3. Coordination with the appropriate. engineering organizations to l resolve component / system design and operating problems; 38 l 4. Preparation of test procedures;

5. Conduct tests to demonstrate adequate and safe component and system performance.

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i Enclosure to TXX-89557 l Paga 58 of 94 Support personnel including craft labor and technicians who will be engaged in, testing activities may be supplied by TU Electric or contractors. The .mT.M. ei fuch support will vary according to test program requirements.

14.2.2.3.1 Manager, Startup (tem rdMck fecm 14.7 7..'2_.\)

The Yene;er, 9teMup ?>"' rep ~!!e e!! tect'a; p=meaae! a~';nM te the 9teMup Ocped .crt The responsibilities of the Manager, Startup include:

l. Administration of the development'of plans and schedules l68 regarding the status of the startup progras; l 2, Administration of the development of individual test procedures; l38 3, Continuing analysis of construction and equipment installation l38 schedules for compatibility with testing schedules and l implementation of corrective actions to minimize confilets; l tj, Review test procedures and results or assure that such reviews l68 are conducted by qualified personnel within the -Test Department; l Swtop 5, Assure proper and timely notifications and reports pertaining to @

testing activities are submitted to the Nuclear Regulatory Commission and other regulatory agencies.

Enclosure to TXX-89557 Paga 59 of 94 14.2.2.3.2 Assistant Startup Manager Ued MMm M'LN

.1& reg The Assistant Startup Manager is respon ble for the test program '  ; , t:1.; :'!!: in L

.-the jud:dcr. v. u .. .... ..,y .r.. . ... . nd will have the following duties and responsibilities:

76 1. Provide technical direction to system test engineers and others assigned to the preoperational test group; Stadv 76 2. - Review of h Department administrative and prerequisite test procedures and ensure that the procedures and test results have been approved at the appropriate level; 76 3. Review and submittal of design change requests originated by the M Department in accordance with the appropriate Jee4-Swy Department / administrative /rocedures; 76 4. Assure tes. ting activities are conducted in accordance with the Quality Assurance Program and applicable procedures..

76 5. Coordination of testing with the activities of the engineering, construction and operations organizations.

76 6. Implementation of the Unit 1 Prestart Test Program.

Enclosure to TXX-89557-Paga 60 of 94 U

14.2.2.3.3- Startup Engineers (Ted redoCcbc1 Itcth ((L'2. 2. AI The duties and responsibilities of the Startup engineers include:

l 1. Preparation of assigned test procedures to direct and guide

. specific tests; 5 :::O d er H th a st r e rd f: = t;

2. Direction to scpport personnel and others during performance of tests including appropriate interface with station operators;

3. Ensuring the safety of personnel and plant equipment during testing;

4. Familiarization of support personnel with specific tests;

5. Identification of deficiencies that could adversely affect test perfonnance;

6. Assembly of test data and preparation of test reports for evaluation of test results by others;

7. Implementation of tagging procedures; and

8. Responsibility to disallow or terminate testing due to conditions which could endanger per'sonnel or equipment.

p-

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Enclosure to TXX-89557-Page 61 of 94 i: .14.2.2.4 Operating Staff (Texire.loCrMQcdhe,NNil.7.N eest The CPSES operating staff will be involved in the +4ec4mp program in several capacities throughout preoperational and' initial'startup testing.. This involvement will include review of test procedures and results and the direct' participation of operating personnel in test 38 -l activities. TU. Electric maintenance personnel will assume the l responsibility for performing routine preventative and corrective l.maintenanceactivitiesonstationcomponentswhentheyarereleased~

l from construction to the preoperational testing group. Operating l staff technicians will be assigned to assist ;y;t= test engineers in l performing' tests. Station operators will assist zy:t= test engineers in performing tests and will take over the routine operations of systems for which prerequisite-type testing has been completed.- The operating staff will direct the fue'l loading and will be responsible for the operation of the plant during initial startup testing.

68 l 'he t W ice! :; r eti ; ettf' it d hif:f Ste fr r f:;:--*- t: hrdid l ty the 4;r; tis; "x:;x; "cutrrr "r:;r; ";n;r.. St:rt;; a l !;;;;. xd tx;r, inhaini L;;;-t; rz;rth:1. 3 Th; ^;r;ti=;

15 l rd ";btrrr in;r; .g:-t :f ';ht=th;l; rd txt;inity t; l the "r:; r, '"rt Cert!r :- 'The duties and responsibilities of l the operating staff during plant operation are described in Chapter l13, The duties of key operating personnel with regard to the startup program are summarized below.

a '

Enclosura to TXX-89557 J Page-62 of 94 i

j 14.2.2.4.1 ' Vice President, Nuclear Operations j 60 j.TheVicePresident,NuclearOperationshasoverallresponsibilityfor l station operationsf and 4 test pregm.

t.he 14.2.2.4.2 Plant Manager.

l The "r N, $$ h :r:t'::: will provide a contin ing4nalysis of l68 testing schedules, operator training schedules, and plant operating l staff workloads in order to minimize conflicts with the :t:rtup esse l program, and he also will provide coordination between the operating l staff and the N Department.

14.2.2.4.3 Operations Department Manager, operafpas 7Le ^- M ' - % g will be l68 responsible for the proper operation of all equipment in the custody l of the operations department and for ensuring that the conduct of the l

$9!;;; program does not place the plant in an unsafe condition. He l will provide personnel from the operating staff as required to support l 33 the conduct of testing activities. In addition, he will direct the l development of station operating procedures.

Mnnnger, oecmhcid ThefhiftfupervisorsreporttotheMr:t'^m":::;;fandare l62 responsible for the safe operation of the plant during assigned l shifts. They also are responsible for the implementation of l appropriate safety and custody tagging procedures and have 4he.

responsibility to disallow or terminate testing due to conditions which could endanger personnel or equipment or violate [echnical specifications.

t EnclosurG to TXX-89557

-Page 63 of 94 14.2.2.4.4 Maintenance Department Snocoer, Knanteet,nte 62 lThe C -tr = ce " r;:r"will be responsible for performing preventive landcorrectivemaintenancewhenrequiredoncomponentsandsystems l that have been turned over from construction to TU Electric. He will 33 l provide personnel from the maintenance department to support testing l activities as required.

14.2.2.4.5 Nuclear Operations Support (peu) Tal.)

The Manager of Nuclear Operations Support will provide personnel from the Nuclear Operations Support organization as required to support testing activities. h Pc.rformanct onct Test Manager repc>rts to fk r4c nceer c>F Mudw ope.mbs Sappor,t and is tc.sponsible fo.- +h e impicmentedien oF 4he. In;Hcd Skrbp Prog rc,m ,

14.2.2.4.6 Director, Quality Assurance 68 lTheDirector,QualityAssuranceisresponsibleforapprovingand lverifyingimplementationoftheTVElectricCPSESQAProgras

i . Enclosure to TXX-89557 _

W PagG 64 of 94-

-14.2.2.5 Mahr Participating Organizations hqf ggQ Q 4 M}

14.2.2.5.1 Engineering and Construction 60- l Engineering and Construction will.be responsible for. assisting to the l extent' required in ensuring that tests. sufficiently verify the l adequacy of system design and in the fonsulation of changes required ltocorrectdetecteddesigndeficiencies. This responsibility includes:

std. $ni$5A { b $Afi Wf 46 l1. Review of preoperationalatest objectives and acceptance criteria l to verify implementation of operating license commitments and

-l consistency with the station safety analyses;

2. Review and approval of design change requests originated during the course of the 0t:r0.; program.

tess

3. ManagementofContractors.(:.;_Citt: !"'!,Orn-- !"xt, l15 "x tirf x x}. l

t. In t:i ni rni = xd :_ 1_r.0; Of L' it 2 prn;;r tin:1 t0;t l'S prn i rn Ob',n t h s M n n;t z r ;rit:ri pri:7 t: ;;rn:1. l 14.2.2.5.2 Brown & Root,Inc. (B&R)

B&R, as the constructor for CPSES, is responsible for the construction completion, performance of associated constructions tests, and orderly I release of components and systems to TU Electric consistent with the Mb program schedules. This responsibility includes:

1. Completion of construction and construction testing activities;

2. Provisi,on of craft technical ranpower support as required for l11 performance of the :t: $ 4 program. l test

_ _ _ _ _ _ _ _ _ _ ._ _ . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ ________._.m.._. ____ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ -

Enclosure to TXX-89557 Page 65'of 94 14.2.2.5.3 Westinghouse Electric Corporation Westinghouse, as the Nuclear Steam Supply System (NSSS) supplier, is l60 responsible for providing technical direction to TU Electric during l preoperational and initial startup testing performed on the NSSS and l associated auxiliary equipment. Technical direction is defined as l technical guidance, advice and counsel based on current engineering, l installation, and testing practices. This responsibility includes: l

1. Assignment of personnel to provide advice and assistance to TU Electric for test and operation of all equipment and systems in the Westinghouse area of responsibility.

2. Assignment of an operational physicist to the site organization during fuel loading andypower testing; and few

3. Provision of test procedure outlines and technical assistance for tests of Westinghouse furnished components and systems.

14.2.2.5.4 Utibly Power Corporation (UPC)

' UMc 4GIEh as supplier of the main turbine generator set, is responsible f'or providing technical NI$ to'TU Electric. during preoperational and initial startup testing performed on the turbine generator and related auxiliary equipment.

.Enclosuro to-TXX-89557 )

Pega 66 of 94 i

'14.2.2.6 MMLfamun (JTG)- { ferh t b Ch PM Ite m 14:L1' 68- l The Joint Test Grot,. (JTG) is comprised of certain station supervisory-l and technical personnel.:: f::;rik t i 0;;;i;r. 14.2.2.0.'. Th; . !;

l 5;:ti::: :: : : & r-ftt:: Of th: St'ti;. Og r:ti;;; 0;.;e., C itt;;

71 l (;0'C) 6 I;it H; d it:r:. The JTG is char ed with reviewing w

se,eter l 0;; tin; actitities and advising the Me aon he disposition of those l items reviewed.

14.2.2.6.1 JTG Membership As a minimum, the Joint Test Group (JTG) shall be composed of l68 managers, supervisors, or engineers from the organizations listed l below. "h: ":::;:r, St: rte; : ' T::t ::. :: :: tu &!  : :f th: l

• - l 4ed StartvP j68 Operations l68 Technical Support l68 Engineering and Construction l68 Westinghouse (for all matters concerning preoperational testing l68 performed on the MSSS and associated auxiliary systems) .l CMeus.eed-The members and their alternates, including the%!! itt fer th: l68

.ebe& amen, shall be designated in writing by their cognizant Vice l President. l The primary function of the JTG is the review and approval of all l68 preoperational : d '-it!;l :t:rt ; ; ?; r test procedures, procedure l revisions, and test results. l l68 In addition to the above, representatives of other organizations will participate,asrequested'bythe-gaoupMairman.

i: Enclosuro to TXX-89557 Page 67 of 94 14.2.2.7 Test Review Groun (TRG) ( NRW TGXh Te*st Aav.es (TR6)

The 1:! '^Tm Group W is comprised of certain station supervisory  !

TE G- '

1 and . technical personnel. :: d::: rib:d in ::th: 10.2.2 St The dWr functions,hitial s 64.eMaf'as a subcgemitte of the tation Operations Review Committee fa(50RC) is charged with reviewing nt u4ngforAtesting matters. The f Atesting activities and advising the 50RC on the disposition of those "

iten reviewed, ne SOM may act m Neu ef efe TAG for activities desertb ed b e lo w. l 14.2.2.7.1 TRG Membership Test Re k w (TG(r)

As a minimum, the J "t T::: Group 94GF shall be composed of managers, supervisors, or engineers from the organizations listed below. 'S: ":::; , St:rtu; :rd T:: ::r;;; ., J, J,.:r-:: ef th:

4%r:-

-Te64 Per4rmance am( Test Operations Technical Support Engineering and Construction ..

Westinghouse (for all matters concerning prer;:r:tM :1 testing initin{ s6etsf performed on the NSSS and associated auxiliary systems)

C M e u n.**d-The members and their alternates, including theh!!: :t- . Sr th:

Sti :r,shall be designated in writing by theie n gai;;at Vice president, Noelear CMistions

• TAG The primary function of the 4M is the review and approval of +4+ i pr;;;;r:th :1 ::d initial startup program test procedures, procedure revisions, and test results.

In addition to the above, representatives of other organizations will .

participate, as requested'by the M dainnan, d 1

i E______.._________ _ . _ _ _ _ . - - --

' Enclosure to TXX-89557

-PagQ 68 of 94~

14.2.2.8- Quality Assurance (fe2f IdOCChd h&m Yl2 *O The TU Electric Quality Assurance Department is responsible for l68' assuring the quality of construction, plant testing,'and operations l activities as described in Chapter 17. l a

l l

9

Enc 1csure to'TXX-89557 1 Pag 2'69.of 94' CPSES/FSAR

- 14.2.2.19 ' Qualifications of Key' Personnel 10423.1 'l Q423.7 l.

-Q423.21 l.

68 l~Theminimumqualificationsofindividualsresponsibleforreviewand lapprovalof.preoperationalandinitialstartuptestproceduresand

-l results shall be; .(1) Bachelor's degree in engineering or the physical

.l sciences and four years of applicable power plant experience; or (2)-

l high school diploma or. equivalent and eight years of applicable power.

lplantexperience.

Credit for up to two years for related technical 40

-ltrainingmaybesubstitutedonaone-for-onetimebasis. A minimum of two years shall be applicable nuclear power plant experience.

68 l 37 l The minimum qualifications of individual that direct or supervise the

.lconductofpreoperationaltestatthetimeofperformanceofthe i duties, shall be; (1) Bachelor's degree in engineering or the physical lsciencesandaneyearofexperienceinpowerplanttestingor l operation.

Included in the one year shall be three months of lfamiliarizationofsystemandcumponentoperationuniquetothedesign l of similar nuclear power plants et " !:S t h Sdivid..i "!- M L l ---'ayed?_or (2) a high school diploma or equivalent and four years of

-) experience in power plant testing or operation or credit for up to two lyearsforrelatedtechnicaltrainingmaybesubstitutedonaone-for-lonetimebasis. Included in the four years shall be three months of l familiarization of system and component operation unique to the design l of similar nuclear power plants -;t tid th bdhid=1 will M "-

_l , k, e d ."-

37 l The ninimum qualifications of individuals that direct or supervise the lconductofinitialstartuptestatthetimeofperformanceofthe l duties,shallbe:

(1) Rachelor's degree in engineering or the l physical sciences and two years of experience in power plant testing loroperation.

Included in the two years shall be a minimum of one l year of nuclear power plant testing, operation or training on a j nuclear facility, or (2) a high school diploma or equivalent and five l years of experience in power plant testing of which two years will Amendment 68 F'ebruary 15, 1988 14.2-14

Enclosure to TXX-89557.

Page 70'of 94 CPSES/FSAR

~ be nuclear power plart experience. Credit.for up to two years for l 37 related technical training may be substituted on a one-for-ons time l basis. - l~

44+/estpersonnelwillbeindoctrinatedintheuseofT::tS:;r'atl68 a d applicable statf = administrative e rt r! procedures, test l procedures and familiarized with 44 applicable quality assurance' l.

requirements. '

l 14.2.3 TEST PROCEDURES 14.2.3.1 General

-*HSfreoperational and initial startup tests will be performedl37 in accordance with written approved test procedures. The following l sections describe the general methods employed to control procedure development and review, and they also describe the responsibilities of the various organizational units participating in this process.

• The detailed controls and methods will be prescribed in the startup l37 administrative procedures and station administrative procedures, as l applicable. l

.14.2.3.2 Development of Jeo6 Procedures l37

1. rn :' ..ege , "; tert;;; =4 'es+ i= r**P<ible for the development of l68 all preoperational and initial startup procedures and maintenance of petestprocedureindexesandpreparationschedules. l l68 Technical information required for the preparation of the test procedures will be provided by the appropriate engineering e l- organizations. This information will consist of system descriptions, technical specifications, design drawings and other technical l

documents which define the functional requirements and performance objectives for the various systems and components. Additional technical deta may also be o'btained from the various component vendors and other contractors as required.

14.2-15 ~A*endment 68 February 15, 1988 i

E; sure to TXX-89557 Page 71 of 94 glicsk The4f unctional requirements provided by the system designers will be incorporated into the acceptance criteria for test procedures. This information will also be used by the Test engineers in developing the detailed test methods which ensure that the capability of systems and components to function properly within design specifications is adequately demonc! rated.

14.2.3.3 Review and Anoroval of Test Proceduras Preoperational and initial startup test procedures will be reviewed by membors of the plant operating staff and appropriate design organizations.

Preoperational test procedures will be forwarded to appropriate members of the Joint Test Group for review and comment.

Initial startop test procedures will be forwarded to appropriate members of the Test Review Group for review and comment.

The responsibility for final approval of d preoperational and L-? ' r O test procedures rests with the Manager d Mr$2- C;rr.:; .; 0 ;;; , Searcup.

The respsibility for find aAnd of hitial sf.ekp test goadotu restLs wick the Pkat Mager.

11 l14.2.3.4 Format of Test Procedores 68 l AM [reoperational and initial startup tests will be prepared based on l formats specified by ! = t h; r' :.! administrative procedures. hit 7Aese standard format will help ensure that each procedure contains +M cAe information and instructions required to sat'sfactorily perform and document time test.

e

Enclosuro to TXX-89557 CPSES/FSAR Page 72 of 94 The procedures format and content wi11' reflect the guidance provided l11 I in Regulatory Guide 1.68 as discussed in Appendix 1A(B). The j standard format will include, as a miniaum, the following: l

1. Test Objectives: ,

A detailed statement of the test objectives and method of system orqpla%7 operation to be demonstrated.

2.

References:

References to technical specifications, supporting procedures, vendor's manual, or other technical documents will be included as required.

3. Prerequisites::rf I 'ti:1 C.J.dit.';;;.

i: rectir- 4 :;;:ify/ferequisitest:  ::: r: th:t :lk re be t initial conditions are satisfied and h the necessary prerequisite tests and construction activities have been satisfactorily completed.

4. Precautions and Limitations:

Precautions and limitations relating to personnel safety, equipment integrity, and overall plant safety will be specified.

14.2-17 February 15, 1988

w i

Enclosure to TXX-89557 CPSES/FSAR PagG 73 of 94 #"5 '~b, # " A

5. Dete+1-d T::: L

";Q:f.,4,,,jg,7, Thei::t5:thedhillcontaindetailedstepby-stepinstructions for operating the system in the test configuration, perfonning actual test manipulations, and for use of off-normal procedures such as jumper cables or mechanical bypasses and restoration of the system to normal status following test.

The detailed test instructions will utilize normal and emergency station operating i

procedures to the extent practical.

6. Acceptance Criteria:

The performance objectives and functional requirements for system operatius will be specified. The criteria used to judge the success or failure of the test may be qualitative or quantitative.

7. Data Collection:

Provisions will be made for recording all pertinent test data regardingsystemconditionsandgerformance.Je identify the observer, type ofjinstrumentatlog, acceptability of gords wil results, and any deficiencies, and will become a part of the pennanent station records.

14.2.3.5 Revisions to Procedures 1

68 l Revisions to preoperational rd 'it'-? :trt ; test procedures will

{ be reviewed :-f ;; red by appropriate members of the JTG by tAs Pisanger, Scareof.f f and @ved 38 l Preoperational and Initial Startup Test procedure modifications l required during conduct of test will be approved as follows; 38 l1. Preoperationa! Test Procedures A'ensiers to intial startup test prmdWes will be rulewe')

by tAe approfriste osabers of sle 726 aed aym<ed sy

-tl,e Pla ,,e M a m g e r. .

Amendment 68 '

Febreary 15, 1988. 14.2 18

Enclosure to TXX-89557 CPSES/FSAR Page 74 of 94

a. Test proccdure modifications that do not change the intent l 38 of the test will be approved by the system test engineer. l

b. Test procedure modifications that change the intent of the l38 test will be approved by the4ptedtest engineer and l another member of the start.up organization qualified to l review preoperational test procedures.' l

c. All procedure modifications will be included with the l38 completed procedure and be subject to review and approval l with the test results as described by paragraph 14.2.5. l

2. Initial Startup Test Procedures l38

a. Modifications to initial startup tests that do not change l38 the intent of tne test will have the fhift [upervisor's l concurrence and approval of the person in charge of the l

~

4e64 ,

test. l

b. Modifications to initial startup tests that change the l68 intent of the test will be' reviewed and approved by the l

.ps,. t , f ^! . !: C;:-- ..a !;,% - . l Plet Mamger.

14.2.4 CONDUCT OF TEST PROGRAM 14.2.4.1 Administrative Procedures The conduct of the : test.rt; program will be controlled by th: C^5EF l68

'n! ?;;;^-- ydninistrative frocedures,Manua4. These procedurcs l

.. will prescribe controls for :trt; activities such as the following: l 37 fasW5 i

14.2-19 Amendment 68 February 15. 1988

Enclosure.to TXX-89557 i- Pag 2 75 of 94

1. Preparation, review and approval, of test procedures 37 l2. Turnover of systems

3. Format and content of test procedures 11 l4. _ Safety and custody tagging procedures 11 l5. Temporary system modifications 11 l6. Design change processing 11 l 7. Test deficiency processing 11 l8. Review of Reactor Operating /Startup experiences.

40 l-14.2.4.2 Prerequisite Testing 40 lStartup/dministrativeprocedureswillbeestablishedtoensurethat l applicable prerequisites are met before testing is initiated. Upon

!completionofconstructionphaseactivities,custodyofthe l component / system will be transferred to TU Electric for conduct of l prerequisite testing and preoperational testing. During the turnover l process, systems and components will be reviewed for completeness, l installation damage and conferiaance with appropriate installation jand/ordesigndocuments. Outstanding construction, document and test l deficiencies will be identified and controlled prior to fuel load.

Enclosure to TXk-89557 Pago 76 of 94 l

14.2.4.3 W Preonorational Testing 1

'68 l Technical direction and administration, including test procedure l preparation, test execution, and data recording, of the preoperational l : f -it':! :ti-t"- testing is the responsibility of the Seetf 4ee+ Department, with the operating staff retaining responsibility for l 68 performing actual' equipment operations and maintenance. l The Manager, Startup : d T::t is responsible for the administration l 68 and implementation of all preoperational : d '-iti:' :t:rt ; testing l activities during the startup program, l mm . yng l68 thed}if::"t::tengineerswilldirectsupportpersonnelinthe performance of tests and will provicie appropriate interface with station operators. Thefhiftfupervisorswillberesponsiblefor insuring that the conduct of testing does not place the plant in an unsafe condition at any time. Additionally, the shift supervisors and ty"F 2 T :testt engineers have the authority to terminate or disallow testing at any time.

Enclosure to TXX-89557 PagQ 77 of 94 14.2.4.4 Initia! Startun Testina 68 lTechnicaldirectionandadministration,includingtestprocedure l preparation, test execution, and data recording, of th: prr;: :t' nF I landinitialstartuptestingistheresponsibilityofthe a

fedemace^ Test 5;;;ts...:, with the operating staff retaining responsibility for l 68 m.a.esew performing actual equipment operations and maintenance.

l ArnGenum:e ud Test Adanner The ";c,;;;'., Sterty ;ad T::t is responsible for the administration l68 and implementation of 4114meooe~tia-9 rd initial startup testing l activities during the N $ k program. l d ,8 : r e d fear l68 The-4y-t= t;;,t engineers will direct support personnel in the ,

performance of tests and will provide approprSte interface with station operators. Thefhift[upervisorswillberesponsiblefor insuring that the conduct of testing does not place the lant in an unsafe condition at any time. Additionally,the[hift upervisors and

y:tr test engineers have the authority to terminate or disallow testing at any time.

Enclosura to TXX-89557 Paga 78 of 94 14.2.4.t5 Test Prerequisites or Each test procedure will contain a set of prerequisitesjand initial l68 conditior,s as prescribed by the 'er+ 9epartrtfdministrative l procedures. The -:y:t= test engineer will ensure that all specified l prerequisites are met prior to performing the test. The format for test procedures is described in Section 14.2.3.4.

14.2.4.g4 Phase Evaluation preoperetical Between each major phase of the^ test program the test results for all l68 tests that have been performed will be reviewed by the JTG. l i4ItialS M W Between each major phase of the a test program the test results for all tests that have been performed will be reviewed by the N 11 l This review ensures that all required systems have been tested l satisfactorily and that test results are approved before proceeding to lthenextstageoftesting. This review is described in Section l14.2.5.

1 14.2.4.g Design Modifications Modifications to the design of safety-related equipment during the test program may be initiated in order to correct deficiencies discovered as a result of testing. Any such modification will be referred to the appropriate engineering organization for approval.

Modifications made to safety-related components or systems after completion of preoperational or initial startup testing will be reviewed for retesting requirements on affected portions of the system.

. . - . _ _ . - . _ _ _ . - - - ..__.-.-._..-.___.____-J

- Enclosuro to TXX-89557 Page 79 of 94 14.2.5 REVIEW, EVALUATION, AND APPROVAL OF TEST RESULTS Following completion of a particular test, the responsibleefstemtest engineer will assemble the test data package for evaluation. Prerequisite and preoperational tests will be reviewed by appropriate members of the JTG. Initial startup test results will be reviewed by appropriate members of the TRG.

11 lEachtestdatapackagewillbereviewedtoensureth6tthetesthas l been performed in accordance with the written approved procedure and lthatallrequireddata, checks,andsignatureshavebeenproperly l recorded and that system performance meets the approved acceptance l criteria.

~

Ug w Q ~~U' Enclosura to-TXX-89557' CPSES/FSAR Pag 2 80.of 94 Deficiencies identificd in th2 review process will b2 rssolvcd to the 68 l satisfaction of the . If the evaluation indicates that deficiencies in the test method are responsible for unsatisfactory 11 test results, the test procedure will be revised accordingly before retesting is initiated. Whenever an evaluation of test results indicates deficiencies in system performance, the problem will be referred to the appropriate engineering organization for evaluation.

fNewnn % ni The responsibility for final approval ofAtest results rests with the 68 pk 9ar,9a%. -.  % n.

,; "': !: :startup C,"^: 1sest

=; S&^lts tw.su Mstk 71 7as mesiMity for fiut aphout ofr**itial witA tAs //ne Mauger. OA23'3 following each major phase of the test prograsj test results and/or 11 test status will be reviewed to ensure that all required tests have been performed and that the test results have been approved. This review will ensure that all required systems are operating properly and that testing for the next major phase will be conducted in a safe and efficient manner. This type of review will be performed to the _

40 extent required before major test phases such as fuel load, initial criticality, and power escalation. During the power escalation 75 phase, review and approval of initial startup test procedure results will be completed for each major power plateau prior to proceeding with power ascension t'esting to the next plateau.

14.2.6 TEST RECORDS Test procedures and test data relating to preoperational and initial startup testing will be retained in accordance with the measure described in Section 17.2.17. " Quality Assurance Records."

14.2-23 Amendment 76 ,

May 1, 1989

. Enclosure to TXX-89557 -CPSES/FSAR Page 81 of 94 14.2.8 UTILIZATION OF REACTOR OPERATING AF0 TESTING. EXPERIENCE IN DEVELOPMENT OF TEST PROGRAM TheCPSESd!$fr;programwillutilizeinformationgainedfrom operating and testing experience in other similar nuclear plants.

This information will be used to provide guidance in developing test y procedures and schedules and to alert personnel to potential problem areas in the testing program.

The development of this program for utilizing testing and operating l68 experience is the responsibility of the Vice President', Nuclear .l Operations with the direct implementation of the program being the l responsibility of the Manager, Startup and % t 4e M m mec l amt Test yea Significant event information received from NSAC and INP0 will be l 37 reviewed by the Mb; organization to identify special testing which l should be included in the test program. l The operating experience program will consist of an initial review to be administered prior to conducting preoperational tests and an ongoing review during the remainder of the test program. The initial rerfew will examine all pertinent operating data and abnonnel events

.on similar plants which occurred during a period of two years prior to the review. The review will be conducted so as to allow sufficient time for data to be analyzed and incorporated in test procedures. Any new information will be reviewed on a regular basis during the test program so as to address current testing problems.

Additionally, testing and operating experience gained from Unit I will be incorporated into the Unit 2 test program.

,14.2-25 Amendment 68 February 15, 1988

( .. Enclosure to TXX-89557 CPSES/FSAR

Pagn.82o{4}.9 1

TRIAL USE OF PLANT OPERATING AND EMERGENCY PROCEDURES The plant operating, emergency, and surveillance procedures will be use-tested during the test program and will also be used in the development o,f precperational and initial startup procedures to the extent practical.

The trial use of operating procedures serves to familiarize operating personnel with systems and plant operation during the testing phase and also serves to assure the adequacy of the procedures under actual or simulated operating conditions before plant operation begins.

Prior to fuel load, draft operating procedures may be utilized for equipment operation and may be informally altered to meet special test considerations.

In general the development of plant operating procedures will take place in approximately the same time frame as the preparation of precperational and initial startup test procedures. The operating procedures will be revised as necessary to reflect experience gained during the actual testing.

During the " test r'.,,

program, operating procedures employed for periodic tests and inspections may be used directly for certain preoperational 44 landinitialstartuptests. Operating procedures used directly for l preoperational or initial startup tests to obtain quantitative data to l be used for evaluation of system performance will be perfonned in

] accordance with the CPSES Station Administrative Manual.

14.2.10 INITIAL FUEL LOADING, CRITICALITY, AND POWER OPERATION Fuel leading will begin after the required preoperational tests are satisfactorily completed. At the completion of fuel loading, the reactor upper internals and pressure vessel head will be installed and February 15, 1988 '

14.2-26

Enclosure to TXX-83557 CPSES/FSAR Paga 83 of 94 additional mechanical and electrical tests will be performed to prepare the plant for nuclear operation. After final precritical tests, nuclear operation of.the reactor will begin. This phase of testing in'cludes initial criticality, low power testing and power level escalation. The purpose of these tests is to establish the operational characteristics of the unit and core, to acquire data for the proper calibration of setpoints, and to ensure that operation is within license requirements. Section 14.2.12.2 summarizes the tests which will be performed from initial criticality to rated power. The core loading and post loading tests are described below.

14.2.10.1 Fuel Loading j [5 h lQ423.5 The overall responsibility for coordination of initial coreyloading l62 activities will be exercised by the "r:;;: , Td.. kd S;;;rtAor his l designated representative with technical assistance provided by l Westinghouse. The overall process of ' initial core loading will be l directed from the operating floor of the containment structure by, a l2 licensed Senior Reactor Operator. l The core configuration will be specified as part of the core design studies conducted well in advance of fuel loading. In the event mechanical damage is sustained during core loading operations to a fuel assembly of a type for which no span is available onsite, an alternate core loading scheme will be determined. Any such changes will be approved by the appropriate Westinghouse personnel.

Core loading procedures will specify the condition of fluid systems to prevent inadvertent changes in boron concentration of the reactor coolant; the movement of fuel to preclude the possibility of mechanical damage; the conditions under which loading can proceed; and the responsibility and authority for continuous and complete fuel and core component accountability.

' i

.14.2-27 February 15, 1988

________________-__a

Enc 1osureito TXX-89557 CPSES/FSAR Pag 3 B4T of N following conditions will be met prior to core loading: .

1.

The reactor Containment structure will be complete and Containment integrity established and maintained during fuel-Ioading.

2.

Fuel handling tools and equipment will have been checked out'and operators familiarized in the use and operation.of equipment.

Inspections of fuel assemblies, rod cluster control assemblies, and reactor vessel will be satisfactorily completed.

3.

The reactor vessel and associated components will be in a' state of readiness to receive fuel. Water level will be maintained above the bottom of the nozzles and recirculation maintained to-assure the required boron concentration. Boron concentration can be increased via the recirculation path or directly to the open vessel.

Criteria for safe loading require that loading operations stop immediately if any of the following conditions occur.

1.

An unanticipated increase in the neutron count rates by a factor of two occurs on all responding nuclear channels during any single loading step after the initial nucleus of eight fuel assemblies is loaded.

2. An unanticipated increase in the count rate by a factor of five on any individual responding nuclear channel during any single loading step aft'er the initial nucleus of eight fuel assemblies is loaded.

76- 3.

An unanticipated decrease in boron concentration greater than 20 ppe is determined from two successive samples of the reactor coolant.

1 Amendment 76 14.2-28 May 1, 1989' l

, EnclosurG to TXX-89557 iCPSES/FSAR PagG 85 of 94 .

4 Loading operations may'not be re-started until the situation is-

~

evaluated. An: alarm in the Containment and main Contro11 Room will be coupled to the source range channels with a setpoint equal to'or less than five times the current count rate. This alarm will automatically

' alertthe loading operation' personnel.of high count rate'and an immediate stop of all operations will be required until the. situation is evaluated. .In the event the evacuation alarm is actuated during core loading and after it has been determined that no hazards to personnel exist, preselected personnel will be permitted to reenter the Containment to evaluate the cause and determine future action.-

The core will be assembled in the reactor vessel, submerged in reactor grade water containing sufficient dissolved boric acid to maintain a calculated core effective multiplication factor of 0.95 or lower.- The refueling cavity will be dry during initial core loading. Core moderator. chemistry conditions.(particularly boron concentration) will I

be prescribed'in the core loaeling procedure document and verified by chemical analysis of moderator samples taken prior to and during core '

loading operations.

At least two artificial neutron sources will be introduced into the l core at specified points in the core during the loading program to I

ensure a detector response of at least 2 counts per second attributable to neutrons, Core loading instrumentation consists of two permanently installed source range (pulse. type) nuclear channels and two tempor'ary incore source range channels. A third temporary channel may also be used as a spare. The permanent channels, when responding, will be monitored

.in the main Control Room and the temporary channels will be installed 14.2-29 February 15, 1988

L i

Enclosure to TXX-89557. CPSES/FSAR Page 86 of 94-and monitored in the Containment. At least one pemanent channel will be equipped with an audible count rate indicator. Both plant channels will have the capability of displaying the neutron flux level on a strip chart recorder.

The temporary channels will indicate on scalers and a minimum of one channel will be recorded on a strip chart recorder.

Minimum count rates of two counts per second, attributable to core neutrons will be required on at least two of the four (i.e.

two temporary and two pemanent source range detectors) available nuclear source channels at all times following installation of the initial nucleus of eight fuel assemblies. A response check of nuclear instruments to a neutron source will be performed within eight hours prior to loading of the core, or upon resumption of loading if delay is for more than eight hours.

Fuel assemblies together with inserted components (control rod '

assemblies, burnable poison inserts, source spider, or thimble plugging devices) will be placed in the reactor vessel one at a time according to a previously established and approved sequence developed to provide reliable core monitoring with minimum possibility of core mechanical damage. The core loading procedure documents prescribe the successive movements of each fuel assembly and its specified inserts from its initial position in the storage racks to its final position in the core. Checks will be made of component serial numbers and types at successive transfer points to guard against possible inadvertent exchanges or substituti e s of components. Fuel assembly status boards will be maintained throughout the core loading operation.

An initial nucleus of eight fuel assembifes, one containing a neutron source, is the minimum source-fuel nucleus which will permit subsequent meaningful inverse count rate monitoring. This initial nucleus is determined by calculation to be markedly subcritical (Keff50.95) under the required conditions of loading.

Amendment 68 February 15, 1988 14.2-30

EnclosurG to TXX-89557 Pago 87 of 94 CPSES/FSAR Each subsequent fuel addition will be accompanied by detailed neutron count rate monitoring to determine that the just-loaded fuel assembly does not excessively increase the count rate and that the extrapolated' inverse count rate ratio is behaving as expected. These results for each loading' step will be evaluated before the next fuel assembly is loaded. The final, as loaded, core configuration will be subtritical (Keff50.95) under the required loading conditions.

14.2.10.2 Initial Criticality Prior to initial criticality, the following tests will be performed and the results evaluated. .

1. At the completion of core loading, the reactor upper internals and pressure vessel head will be installed. A pressure test will be conducted after filling and venting is completed to check the leak tightness of the vessel head installation. ,

2. Mechanical and electrical tests will be performed on the control rod drive mechanisms. These tests include a complete operational checkout of the mechanisms and calibration of the individual rod position indicators.

3. Test will be performed on the reactor trip circuits to test manual trip operation, and actual control rod assembly drop times will be measured for each control rod assembly. At all times that the control rod drive mechanisms are being tested, the boron concentration in the coolant will be maintained such that the shutdown margin requirements specified in the Technical Specifications are met. During individual RCCA or RCC bank notion, source range instrumentation will be monitored for unexpected changes in core reactivity.

' 14.2-31 February 15, 1988

Enclosure to TXX-89557 CPSES/FSAR Pag 3 BB of 94 4.

The Reactor Control and Reactor Protection Systems will be checked with simulated inputs to produce trip signals for various trip conditions. '

S. l A functional electrical and mechanical check will be made of the incore nuclear flux mapping system near normal operating temperature and pressure.

Initial criticality will be achieved by a combination of shutdown and control bank withdrawal and reactor coolant system boron concentration dilution. The plant conditions, precautions and specific instructions

{ for the approach to criticality will be specified by approved procedures.

Initially, the shutdown and control banks of control rods will be withdrawn incrementally in the nomal withdrawal sequence leaving the last withdrawn control bank partially inserted in the core to provide effective control when criticality is achieved. The boron concentration in the Reactor Coolant System will then be reduced and criticality achieved by boron dilution or by subsequent rod withdrawal following boron dilution.

Throughout this period, samples of the primary coolant will be obtained and analyzed for boron concentration.

Inverse count rate ratio monitoring, using data from- the normal plant source range instrumentation, will be used as an indication of the proximity and rate of approach to criticality. Inverse count rate ratio data will be plotted as a function of rod bank position during rod motion and as a function of reactor makeup water addition during reactor coolant system boron concentration reduction.

Tebruary 15, 1988 "*'

_ _ _ _ _ _ _ _ _ _ _ - - _ . - - _ _ -- i

Enclosure to TXX-89557 CPSES/FSAR Paga 89 of 94 14.2.10.3 Low Power Testing Following initial criticality, a program of reactor physics measurements will be undertaken to verify that the basic static and l

kinetic characteristics of the core are as expected and that the values of the kinetic coefficients assumed in the safeguards analysis are conservative.

Procedures will specify the sequence of tests and measurement to be conducted and the conditions under which each is to be perfomed in order to ensure both safety of operation a J the validity and consistency of the results obtained. If test results deviate significantly from design predictions, if unacceptable behavior is revealed, or if unexplained anomalies develop, the plant will be brought to a safe stable condition and the situation reviewed to determine the course of subsequent plant operation.

These measurements will be made at low power and primarily at or near normal operating temperature and pressure. Measurements will be made 76 in order to verify the calculated values of control rod bank reactivity worths, the isothermal temperature coefficient ,

~

differential boron concentration reactivity worth, and critical boron concentrations . In addition, measurements of the relative power distributions will be made, and concurrent tests will be conducted on the instrumentation including power and intennediate range nuclear channels.

14.2.10.4 Power Level Escalation After the operating characteristics of the reactor have been verified by low power testing, a program of power level escalation will bring the unit to its full rated power level in successive stages. The minimum test requirements for each successive stage of power escalation will be specified in the initial startup test procedures.

14.2-33 Amendment 76 ,

May 1, 1989

c-L .: Enclosure to TXX-89557 CPSES/FSAR

~

'PagG 90 of-94 Measurements will be made to determine the relative power distribution in the core as functions of power level and control assembly bank L position.

Secondary system heat balance measurements will ensure that the-indications 1of power level are consistent and provide bases for calibration of the power range nuclear channels. The ability of the

. Reactor Coolant. System to respond effectively to signals from primary and secondary instrumentation under a variety of conditions-encountered in normal operations will be verified.

At prescribed power levels the dynamic response characteristics of ~the

-primary and secondary systems will be evaluated. System response characteristics'will be measured for design step load changes, rapid load reduction, and plant trips.

Adequacy of radiation shielding will be verified-by gamma and' neutron.

radiation surveys at selected points-inside the Containment Building and throughout the station site at various power levels. Periodic sampling will be performed to verify the chemical and radio-chemical analysis of the reactor coolant.

14.2.11 TEST PROGRAM SCHEDULE .

The sequential schedule for the preoperational testing of individual systems and components is shown in Figure 14.2-3. The sequential schedule for initial startup performed following fuel loading is shown in Figure 14.2-4.

These schedules show certain milestones at which time the tests, or portions of tests, will be completed and the overall time frame in which the tests will be conducted. The detailed schedules for testing will be prepared, reviewed and revised on a continuing basis as station construction progresses.

~ February 15,1988 *~

- _ _ _ _ -_ ______ - _ n

~

~l b .Enclosuro'to TXX-89557 Paga 91 of 94 .CPSES/FSAR

, Preoperational testing of the various systems and components, which will continue up to fuel loading, is scheduled to commence at a time 10 to 15 months prior to fuel load. Initial startup tests are scheduled to be conducted over a period of approximately five months subsequent to fuel load. Fuel load, initial criticality, and power ascension tests are scheduled to.be accomplished during this time period.

Station structures, systems, and components which are relied upon to prevent or mitigate consequences of postulated accidents will be fully tested to the extent practical prior to exceeding the N percent power level. Certain systems will have part of the preoperational testing perfonned after fuel load due to system configuration (e.g. control rod drive mechanism require fuel in the vessel to be fully tested).

Such systems will be sufficiently tested prior to fuel load to provide reasonable assurance of successful testing after fuel load.

The development of test procedures will be an ongoing process, which will consist of preparation, review, and revision. The preparation of preoperational test procedures is scheduled to start no later than 15 months prior to fuel loading.

Preparation of initial star' tup procedures is scheduled to commence approximately five months prior to fuel loading. Preoperational and 76

• initial startup test procedures will be available for examination by the NRC regional personnel approximately 60 days prior to the scheduled performance of the test, and, approximately 60 days prior to the scheduled fuel loading date.

38 Testing efforts on CPSES Unit 1 will not be diluted by activities on Unit 2.

14.2-35 Amendment 76 May 1, 1989

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