NSD-NRC-96-4800, Forwards Responses to RAI & Open Items Contained in Nov 1994 Draft SER on AP600

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Forwards Responses to RAI & Open Items Contained in Nov 1994 Draft SER on AP600
ML20116M024
Person / Time
Site: 05200003
Issue date: 08/13/1996
From: Mcintyre B
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Quay T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NSD-NRC-96-4800, NUDOCS 9608190262
Download: ML20116M024 (92)


Text

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Westingh0use Energy Systems Bei355 j

deCtricC0rporall00 Pmsbu@ Pennsylvania 15230-0355 NSD-NRC-%-4800 t

DCP/NRC0580 Docket No.: STN-52-003 1

I August 13,1996 Document Control Desk i

U.S. Nuclear Regulatory Commission

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Washington, D.C. 20555 t

ATTENTION:

T.R. QUAY i

SUBJECT:

SSAR CHAPTER 14 -INITIAL TEST PROGRAM, RESPONSES TO RAIS

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AND OPEN ITEMS

Dear Mr. Quay:

l The enclosure to this letter provides responses to requests for additional information and open items contained in the November 1994 Draft Safety Evaluation Report on the AP600. These responses I

reflect the recent revision to Chapter 14 of the AP600 SSAR (Revision 9). Attachment 1 identifies the open items and RAls addressed by this transmittal. We request that these responses be included in the ongoing icview of the Chapter 14 revision.

Please contact John C. Butler on (412) 374-5268 if you have any questions concerning this transmittal.

A[

Brian A. McIntyre, Manager Advanced Plant Safety and Licensing l

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Enclosures Attachment L

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cc:

T. Kenyon, NRC (w/o Enclosures / Attachments) g J. Sebrosky, NRC (I A, IE)

J. Peralta, NRC (I A, IE)

R. Gruel, PNL (I A, IE)

N. J. Liparulo, Westinghouse (w/o Enclosures / Attachments) 19004S 2mr p

9608190262 960813

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Attachment I AP600 Init8al Test Program Open items and RAls Addressed via Encie:are to Westinghouse Letter NSD-NRC-96-4800 OITS Number Open item 780 DSER 3.9.2.1-1 1124 DSER 9.5.1.4-7 1162 DSER 10.4.7-1 1234 DSER 14.2.1-1 123f DSER 14.2.2-1 1236 DSER 14.2.2-2 1237 DSER 14.2.2.1-1 1238 DSER 14.2.2.2-1 1239 DSER 14.2.8-1 1240 DSER 14.2.8-2 1241 DSER 14.2.8-3 1242 DSER 14.2.8-4 1243 DSER 14.2.8-5 1

1244 DSER 14.2.8-6 1245 DSER 14.2.8-7 1246 DSER 14.2.8-8 1247 DSER 14.2.8-9 1248 DSER 14.2.8-10 1249 DSER 14.2.8-11 1250 DSER 14.2.8-12 1251 DSER 14.2.8-13 1252 DSER 14 2.8-14 l

1253 DSER 14.2.8-15 1254 DSER 14.2.8-16 1255 DSER 14.2.8.3-1 1256 DSER 14.2.8.4-1 1257 DSER 14.2.9-1 i

1258 DSER 14.2.9-2 n94A

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h OITS Number Open Item 1792 DSER 3.9.2.1-4 1828 DSER 14.2.7-1 1829 DSER 14.2.8-1 1963 DSER 14.2.2-1 1964 DSER 14.2.2-2 1965 DSER 14.2.2-3 1966 DSER 14.2.2-4 1967 DSER 14.2.2.2-1 1968 DSER 14.2.8-1 t

2035 DSER " top 50" item 2271 Meeting Open item 2543 RAI 260.35 2544 RAI 260.36 2545 RAI 260.37 2546 RAI 260.38 2547 RAI 260.39 i

2548 RAI 260.40

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2549 RAI 260.41 2550 RAI 260.42 2551 RAI 260.43 2552 RAI 260.44 2553 RAI 260.45 2554 RAI 260.46 2555 RAI 260.47 2556 RAI 260.48 2557 RAI 260.49 2558 RAI 260.50 2559 RAI 260.51 2560 RAI 260.52 2561 RAI 260.53 2562 RAI 260.54 2394A

y OITS Number Open item 2563 RAI 260.55 2564 RAI 260.56 2565 RAI 260.57 2566 RAI 260.58 t

i 2567 RAI 260.59 2568 RAI 260.60 2569 RAI 260.61 2570 RAI 260.62 2571 RAI 260.63 i

2572 RAI 260.64 2639 RAI 260.65 2640 RAI 260.66 2641 RAI 260.67 2642 RAI 260.68 2643 RAI 260.69 2644 RAI 260.70 2645 RAI 260.71 2646 RAI 260.72 2647 RAI 260.73 2648 RAI 260.74 2931 RAI 260.75 2932 RAI 260.76 2933 RAI 260.77 2934 RAI 260.78 2935 RAI 260.79 2936 RAI 260.80 1

2937 RAI 260.81 2938 RAI 260.82 2844

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RESPONSE TO DSER OPEN ITEMS g --r vn -

OITS 780 DSER 3.9.2.1-1 Re:

SSAR Chapter 14, Section 14.2.9.1.7 Westinghouse should revise the SSAR to state that the identified piping systems will be included in the AP600 preoperational piping vibration, thermal expansion, and dynamic test programs.

Response

Subsection 14.2.9.l.7, has been revised to state that the AP600 preoperational piping vibration, thermal expansion, and dynamic testing will include ASME Code Class I,2, and 3; i.e., safety related high energy piping system components, piping, and piping support and restraint devices.

Westinghouse Status: Closed e

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RESPONSE TO DSER OPEN ITEMS OITS 1124 DSER 9.5.1.4-7 Re: SSAR Chapter 14, Section 14.2.9.2.8 The staff has not yet determined the acceptability of the preoperational acceptance test for all active components of the entire fire-protection system (s).

Response

Subsection 14.2.9.2.8, fire protection system testing, has been revised to state that the system operates as specified in subsection 9.5.1 and in appropriate design specifications. These documents identify the applicable NFPA standards for the testing of individual components in the fire protection system. Subsections 14.2.9.2.19 and 14.2.9.4.13 describe testing of the plant lighting and communication systems, respectively. The breathing apparatus provided at the plant and the use of this equipment will be identified by the COL applicant, as part of the fire protection personnel training.

Westinghouse Status: Closed W westinghouse

i RESPONSE TO DSER OPEN ITEMS im:sstm.:

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OITS 1162 DSER 10.4.7-1 Re:

SSAR Chapter 14. Section 14.2.9.1.7 Question 410.263 Westinghouse should provide procedures for testing feedwater hammer occurrence.

, Response:

Subsection 14.2.9.l.7 on dynamic effects on piping. has been revised to include testing to start /stop startup feedwater to the steam generators to verify that unacceptable feedwater hammer does not occur. Additional testing is also performed during the plant startup testing which includes both startup and main feedwater to the steam generators, as decribed in subsections 14.2.10.4.13,14.2.10.4.18, and 14.2.10.1.20.

Westinghouse Status: Closed e

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RESPONSE TO DSER OPEN ITEMS

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n-OITS 1234 DSER 14.2.1 1 Re:

SSAR Chapter 14, Section 14.2.1 Question 260.23 Westinghouse should acceptably address the issues identified in Q260.23 and identify items (discussed in Section 14.2.1 of this report) that are not addressed by the initial test program, and justify their exclusions.

Response

Subsection 14.2.1, has been revised to include the test objectives identified in the August 8,1994 response to RAI 260.23. In addition, test abstracts for applicable systems identified in Regulatory Guide 1.68, Revision 2, Appendix A have been includra.

Westinghouse Status: Closed 4

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RESPONSE TO DSER OPEN ITEMS j---1 i

w-OITS 1235 DSER 14.2.2-1 Re: SSAR Chapter 14, Section 14.2.2 In Section 14.2.2 of the SSAR, Westinghouse should replace the phrase "NRC staff personnel from the Office of Inspection and Enforcement" with "NRC inspection personnel."

Response

Subsection 14.2.2, has been revised deleting the phrase "NRC staff personnel from the Office of Inspection and Enforcement."

Westinghouse Status: Closed O

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OITS 1236 DSER 14.2.2-2 Re:

SSAR Chapter 14 h

Westinghouse should add to the SSAR the identified COL Action Items.

R'esponse:

Infonnation to be provided by the COL, related to the plant initial testing program, has been added to the SSAR in Section 14.4.

Westinghouse Status: Closed I

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RESPONSE TO DSER OPEN ITEMS JH OITS 1237 DSER 14.2.2.1-1 Re: SSAR Chapter 14, Section 14.4 Westinghouse should include in the SSAR a description of the organizational units and any augmented organizations or other personnet that will manage, supervise, or execute any phase of the ITP in a manner consistent with the guidance in Section 14.2.2 of RG 1.70.

Response

A description of the organizational units and any augmented organizations or other persormel that will manage, supervise, or execute any phase of the initial test program is the responsibility of the combined license applicant.

Section 14.4, states that the COL is to provide this information.

Westinghouse Status: Closed

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OITS 1238 DSER 14.2.2.2-1 Re: SSAR Chapw 14. Section 14.4 Westinghouse should add COL Action Item 14.2.2.2 i to the SSAR.

Response

COL Action Items related to the plant initial testing program have been added to the SSAR in Section 14.4.

Westinghouse Status: Closed 4

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RESPONSE TO DSER OPEN ITEMS w_

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OITS 1239 DSER 14.2.8-1 Re: SSAR Chapter 14. Section 14.2.9.3 Westinghouse should modify preoperational test abstract 14.2.8.1.80 in Appendix 1A of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to RG 1.68, Appendix A Items 1.a.(2)(d) and 1.h.(2).

Response

Subsection 14.2.9.3, specifies that testing to demonstrate the flowpath resistances of each automatic depressurization system flowpath is to be performed for each AP600 plant. A blowdown test of the heated and pressurized reactor coolant system through the stage I,2, and 3 depressurization flowpaths into the inw:pntainment refueling water storage tank is performed on only the first AP600 plant. This first-plant-only blowdown test is perfonned to verify that the response of in-containment refueling water storage tank and plant stuctures to the hydrodynamic loads resulting from the blowdown are consistent with design basis loading developed from the extensive blowdown testing, done as part of the certification test program. Once this blowdown test is perfornwd and proper structural response is verified, this test need not be repeated on subsequent plants since the IRWST and spargers are identical and the flowpath resistance will be verified. Therefore, the blowdown flowrates and hydrodynamic loads will be the same, The above first-plant-only blowdown test meets the following criteria used to establish which testing is to be performed only on the first AP600 plant:

The perfonnance parameter (s) to be measured is not provided by previous certification, qualification, or prototype testing.

and Construction / installation inspections and other preoperational tests, performed on every plant, demonstrate that the performance parameter (s) does not change from plant to plant.

Examples of previous tests which are done only for the first plant, with NRC concurrance, have been reactor internals vibration and reactor coolant system natural circulation testing.

Westinghouse Status: Closed

RESPONSE TO DSER OPEN ITEMS r.=manne :

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OITS 1240 DSER 14.2.8-2 Re: SSAR Chapter 14, Section 14.2.9.1.3 Westinghouse should modify preoperational test abstract 14.2.8.1.85 in Appendix 1A of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to.

.RG 1.79 and RG 1.68, Appendix A. Item 1.h.(l).

Response

Subsection 14.2.9.1.3 on passive core cooling system testing, has been revised to specify verification of core makeup tank and accumulator performance for each AP600 plant.

Westinghouse Status: Closed I

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OITS 1241 DSER 14.2.8-3 Re: SSAR Chapter 14, Section 14.2.9.1.3 Westinghouse should modify preoperational test abstract 14.2.8.1.87 in Appe.ndix I A of the SSAR to include the applicability of this testing te subsequent AP600 plants, or to provide appropriate justification for this exception to RG l.139 and RG 1.68, Appendix A Items 1.d.(5), l.d.(8), and 1.h.

Response

Subsection 14.2.9.l.3 on passive core cooling system testing, has been revised to specify verification of passive residual heat removal heat exchanger performance for each AP600. Observation of the accompanying heatup characteristics of the in-containment refueling water storage tank water is specified only for the first AP600 plant.

Westinghouse Status: Closed i

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RESPONSE TO DSER OPEN ITEMS i

OITS 1242 DSER 14.2.8 4 Re: SSAR Chapter 14. Section 14.2.9.l.12 1

Westinghouse should modify preoperational test abstract 14.2.8.1.94 in Appendix IA of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to RG 1.68.2 as well as RP C.3 and C.4.

Response

Subsection 14.2.9.1.12. has been revised to include verification of the ability to initiate actuation signals to the systems / components required for safe-shutdown from the remote shutdown workstation for each AP600 plant.

Westinghouse Status: Closed 1

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RESPONSE TO DSER OPEN ITEMS

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,RO 1.68, Appendix A, item 1.h.(3).

Response

Subsection 14.2.9.1.4, has been revised to include verification of the pn>per operation of the functions required for passive containment cooling for each AP600 plant.

Westinghouse Status: Closed 1

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OITS 1244 DSER 14.2.8-6 Re: SSAR Chapter 14, Section 14.2.9.1.6 Westinghouse should modify preoperational test abstract 14.2.8.1.100 in Appendix 1 A of the SSAR to include the applicability of this testing to subsequent AP600 plants, or provide appropriate justification for this exception to RG l.68, Appendix A, Item 1.n.(14)(f).

Response

Subsection 14.2.9.l.6, has been revised to include verification of the proper. operation of the main contml room habitability system and components for each AP600 plant. A long-term demonstration test of this system is specified only for the first plant in order to demonstrate the ability of the structural heat sinks to. maintain proper component temperatures and demonstrate the proper sizing of the stored air supply.

The above first-plant-only test meets the following criteria used to establish which testing is to be performed only, on the first AP600 plant:

The performance parameter (s) to be measured is not provided by previous certification, qualification, or prototype testing.

and Construction / installation inspections and other preoperational tests, performed on every plant, der'nonstrate that a

the performance parameter does not change from plant to plant.

Westinghouse Status: Closed 1

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RESPONSE TO DSER OPEN ITEMS

.r-OITS 1245 DSER 14.2.8-7 i

Re: SSAR Chapter 14, Section 14.4 COL Action Item 14.2.8 7 Westinghouse should add additional criteria to stanup test abstract 14.2.8.2.34 in Appendix I A of the SSAR.

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. Response:

Section 14.3, provides reference to Cenified Design Material which commits the COL to conduct the Initial Test Program. As part of that Initial Test Program, the COL will verify the physical layout and configuration of the components, and component parameters important to the natural circulation of fluid in the reactor coolant system.

Dese verifications will establish that AP600 plants subsequent to the first plant, will achieve natural circulation flow similar to the flow demonstrated by testing in the first plant.

Westinghouse Status: Closed I

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RESPONSE TO DSER OPEN ITEMS

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OITS 1246 DSER 14.2.8-8 Re: SSAR Chapter 14, Section 14.2.10.4.9 Westinghouse should modify startup test abstract 14.2.8.2.38 in Appendix 1A of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to.

RG 1.68. Appendix A. Items 5.b and 5.y.

Response

Subsection 14.2.10.4.9, has been revised to include verification of the proper operation of the reactor external core flux meters for each AP600 plant.

Westinghouse Status: Closed O e 4

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RESPONSE TO DSER OPEN ITEMS s..

OITS 1247 DSER 14.2.8-9 Re: SSAR Chapter 14 Section 14.2.9.2.17 Westinghouse should modify startup test abstract 14.2.8.2.41 in Appendix IA of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate jusufication for this exception to RG 1.68, Appendix A, item 5.J.J.

Response

Chapter 14 has been revised to delete testing which simulates a loss of off-site electrical power with the reactor core at power; however, each spect of a loss of offsite power transient is tested separately. These tests include the RCP flow coastdown test (14.2.10.1.18), the diesel generator start, and load testing (14.2.9.2.17), the rod control system test (14.2.10.1.1I), and the rod drop time measurement test (14.2.10.l.14).

Westinghouse Status: Closed e

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RESPONSE TO DSER OPEN ITEMS

-- E n-OITS 1248 DSER 14.2.8-10 4

Re: SSAR Chapter 14, Section 14.2.10.4.6 Westinghouse should modify startup test abstract 14.2.8.2.47 to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to RG l.68, Appendix A, item 5.i.

Response

3 Subsection 14.2.10.4.6, which desenbes rod cluster control assembly out of bank measurements, has been revised to be performed for each AP600 piant.

Westinghouse Status: Closed e

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. ni FAE OITS 1249 DSER 14.2.8-11 Re: SSAR Chapter 14 Section 14.2.10.4.21 Westinghouse should modify startup test abstract 14.2.8.2.51 in Appendix 1A of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to RO l.68, Appendix A. Item 5.n.n.

Response

Subsection 14.2.10.4.21 specifies that the 100% load rejection test is to be performed only on the first AP600 plant.

Thi.s testing provides measurements of the plant parameters including reactor power and primary and secondary pressures and temperatures that xcur following this transient. Subsequent plants hav9 similar equipment, control systems, and setpoints. The above first. plant-only test meets the following criteria used to establish which testing is to be performed only on the first AP600 plant:

The performance parameter (s) to be measured is not provided by previous certification, qualification, or prototype testirg.

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Construction / installation inspections and other preoperational tests, performed on every plant, demonstrate that a

the performance parameter (s) does not change from plant to plant.

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Westinghouse Status: Closed d

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RESPONSE TO DSER OPEN ITEMS pnummmn:

rau-OITS 1250 DSER 14.2.812 Re: SSAR Chapter 14, Section 14.2.10.4.22 Westinghouse should modify startup test abstract 14.2.8.2.52 in Appendix IA of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to

,RG 1.68, Appendix A, Item 5.h.h.

Response

Subsection 14.2.10.4.22 specifies that the capability of the plant to properly perform load follow maneuvers is demonstrated only on the first AP600 plant. This testing provides measurements of the core power distributions that

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occur during load follow maneuvers. Subsequent plants have similar equipment, control systems, and setpoints. The above first-plant-only test meets the following criteria used to establish which testing is to be performed only on the first AP600 plant:

The performance parameter (s) to be measured is not provided by previous certification, qualification, or prototype testing.

l and Construction / installation inspections and other preoperational tests, performed on every plant, demonstrate that the performance parameter (s) does not change from plant to plant.

Westinghouse Status: Closed.

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RESPONSE TO DSER OPEN ITEMS

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OITS 1251 DSER 14.2.8-13 Re: SSAR Chapter 14, Section 14.2.10.4.24 Westinghouse should modify startup test abstract 14.2.8.2.55 in Appendix IA of the SSAR to include the applicability of this testing to subsequent AP600 plants, or to provide appropriate justification for this exception to RG 1.68 Appendix A Item 5.1.1.

Response

Subsection 14.2.10.4.24, has been revised to specify that a plant trip test is to be performed on each AP600 plant.

Westinghouse Status: Closed e

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OITS 1252 DSER 14.2.814 Re: SSAR Chapter 14, Section 14.4 Questions 260.24 & 260.28 Westinghouse should revise Section 14.2.8 of the SSAR to reconcile its contents with that of Section 14.2.2 of the SSAR, as discussed above in relation to Q260.24.

Response

Responses to RAls 260.24 and 260.28 have been provided. Section 14.4, has been revised to specify the COL provide appropriate initial test program documents for review by the staff.

Westinghouse Status: Closed O

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RESPONSE TO DSER OPEN ITEMS W."M rau --

DSER 14.2.8-15 OITS 1253 Re: SSAR Chapter 14, Section 14.2.9 Westinghouse should revise Section 14.2.8 of the SSAR, as well as the individual test m criteria, to provide specific references to the basis for determining acceptable system and co

Response

Subsection 14.2.9, has been revised to specify specific references that should be used to determi and component performance.

Westinghouse Status: Closed j

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RESPONSE TO DSER OPEN ITEMS I

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OITS 1254 DSER 14.2.8-16 Re: SSAR Chapter 14, Section 14.2.9 j

Westinghouse should either expand the test abstracts of Section 14.2.8 of the SSAR to address the issued identified in Appendix A to RG 1.68, or revise Appendix I A of the SSAR to provide technical justification for any exceptions taken.

Response

Subsection 14.2.9, has been revised to include test abstracts for all applicable AP600 systems and components as specified in Regulatory Guide 1.68. Revision 2, Appendix A.

Westinghouse Status: Closed i

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OITS 1255 DSER 14.2.8.31 Re: SSAR Chapter 14, Section 14.2.9 Westinghouse should acceptably address the issues identified in Q260.30.

Response

Subsection 14.2.9, has been revised to include test abstracts for appropriate AP600 systems and components as specified in Regulatory Guide 1.68. Revision 2, Appendix A.

Westinghouse Status: Closed e

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A OITS 1256 DSER 14.2.8.4-1 Re: SSAR Chapter 14 Section 14.2.9.1.12 Question 260.31 Westinghouse should acceptably address the issues identified in Q260.31.

Response

Subsection 14.2.9.l.12, has been revised to include testing ta,erify the ability to initiate actuation signals to the systems / components required for reactor shutdown from the remote shutdown workstation. Note that the AP600 remote shutdown workstation provides the operator with the same capability to maintain the plant at hot shutdown conditions, or to cool the plant down; as is provided from the main control room. 'Iherefore, the operator does not need to perform manual actions or operate equipment from local control panels. In addition, test abstracts for the instrument and compressed air system and appropriate HVAC systems have been revised.

Westinghouse Status: Closed J

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__z OITS 1257 DSER 14.2.9-1 Re: SSAR Chapter 14, Section 14.4 Question 260.32 Westinghouse should acceptably address the issues identified in Q260.32.

Response

Section 14.3, provides reference to COL information items to verify site specific aspects of the pla.nt that may require testing are within the certification envelope.

Westinghouse Status: Closed S

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OITS 1258 DSER 14.2.9-2 Re: SSAR Chapter 14, Section 14.4 Question Q260.25 & 260.27 Westinghouse should acceptably address the issues identified in Q260.25.

Response

Section 14.4, has been revised to include a COL information item to provide a startup administrative manual that will delineate specific permissions required for the approval of test msults and the pennission to proceed to the next testing phase.

Westinghouse Status: Closed l

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RESPONSE TO DSER OPEN ITEMS rau--

i DSER 3.9.2.1-4 OITS 1792 Re: SSAR Chapter 14. Section 14.2.9.1.7 Question 210.57 (Incorporate SSAR 3.9.2.1-4 Westinghouse should revise the SSAR as noted in Section 3.9.2.1 of this report.

revision from RAI 210.57, acceptance standard for attemating stress intensity.)

Response

14.2.9.1.7 on expansion vibration, and dynarnic effects testing, has been revised to include ref SSAR subsection 3.9.2, which delineates the acceptance criteria for attemating stress intensity due t Subsection Westinghouse Status: Closed e

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OITS 1828 DSER 14.2.71 i

Re: SSAR Chapter 14 Section 14.4 Question 260.27 Westinghouse will revise the SSAR to state that the startup administrative manual (procedures) will be the responsibility of the COL applicant, as will other documents that delineate the test program schedule for the initial fuel load and for each major test program.

Response

Section 14.4, has been revised to include a COL infomation item to provide a startup administrative manual that will l

delineate the test program schedule for staff review.

i Westinghouse Status: Closed b

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OITS 1829 DSER 14.2.8-1 Re: SSAR Chapter 14 Question 210.58 & 210.53 Westinghouse will make the appropriate changes to the pcwper4ional and startup test abstracts, pending satisfa resolution of Q210.53 and Q210.58.

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Response

Chapter 14 has been revised to require steady-state and dynamic vibration measurements of safety related, high energy piping during hot functional testing and during stanup testing; for all AP600 plants. Reactor intemals vibration testing is specified for the first AP600 plant only. This first-plant-only intemals vibration test meets the following criteria used to establish which testing is to be performed only on the first AP600 plant:

The performance parameter (s) to be measured is not provided by previous certification, qualification, or prototype testing.

and Construction / installation inspections and other preoperational tests, performed on every plant, demonstrate that -

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the performance parameter (s) does not change from plant to plant.

Dis first-plant-only reactor intemals vibration test is consistent with internals testing done on previous plants for the first plant, with NRC concurrence 1

Westinghouse Status: Closed

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K&W OITS 1963 DSER 14.2.21 Re: SSAR Chapter 14. Section 14.4

'Ihe COL applicant should provide for staff review, the scoping document (i.e., preoperational and startup test specifications) containing testing objectives and acceptance critena applicable to Westinghouse *s scope of design responsibility.

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Response

Section 14.4, has been revised to include a COL information item to provide preoperational and startup test procedures containing test objectives and acceptance criteria for Westinghouse scope systems / equipment.

Westinghouse Status: Closed 9

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OITS 1964 DSER 14.2.2-2 Re: SSAR Chapter 14, Section 14.4

'the COL applicant should provide for staff review, the scoping document, and any related documents, which delineate plant operational conditions at which tests are to be conducted, testing methodologies to be utilized, specific.

data to be collected, and acceptable data reduction techniques to be utilized.

Response

Section 14.4, has been revised to include a COL information item to provide preoperational and startup test procedures to delineate test conditions, testing method, data to be collected, and data reduction techniques.

Westinghouse Status: Closed OE e

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OITS 1965 DSER 14.2.2-3 Re: SSAR Chapter 14, Section 14.4 The COL applicant should provide for staff review, the scoping document that delineates any reconciliation methods needed to acco'unt for test conditions, methods, or results if testing is performed at conditions other than representative of design operating conditions.

Response

Section 14.4, has been revised to include a COL information item to ptuvide preoperational and startup test procedures to delineate any reconciliation methods needed to account for test conditions, methods, or results if testing 4

is performed at conditions not representative of design conditions.

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OITS 1966 DSER 14.2.2-4 Re: SSAR Chapter 14 Section 14.4 The COL applicant should provide for staff resiew, the approved preoperational test procedures (to be provided approximately 60 days before their intended use, and startup test procedures (to be pluvided approximately 60 days before fuel loading).

Response

Section 14.4, has been revised to include a COL information item to provide approved preoperational test procedures for all safety-related systems, and systems that perform defense-indepth functions approximately 60 days before their intended use; and to provide approved startup test procedures 60 days before fuel loading.

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OITS 1967 DSER 14.2.2.21 Re: SSAR Chapter 14 Section 14.4 The COL applicant should provide the startup administrative manual, which will delineate the review, evaluation, and approval of test results, for staff review.

RIsponse:

Section 14.4, has been revised to include a COL information item to provide the startup administration manual which l

delineates the review, evaluation, and approval of test results.

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OITS 1968 DSER 1419-1 Re: SSAR Chapter 14 Section 14.4 The COL applicant will provide the identified information associated with stanup test abstract 14.2.8.2.34.

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Response

Section 14.3 references Certified Design Material which commits the COL to conduct an Initial Test Program. As part of that Initial Test Program, the COL will verify that reactor coolant system pere.Ts.s am comparable to the first AP600 plant in order to obtain similar natural circulation flows.

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e RESPONSE TO DSER OPEN ITEMS EEM OITS 2035 DSER 0150 Re: SSAR Chapter 14 The NRC is not satisfied with the detail and scope of Chapter 14 (Initial Test Program). The most significa fall into four categories.

Response

Chapter 14 has been revised to include test abstracts in accordance with Regulatory Guide 1.68. Rev A, and to include the basis for tests acceptance criteria. Justification for tests only perfonned for the first AP60 plant has been provided in Westinghouse letter NSD-NRC-96-4772,7/16/96.

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OITS 2271 Re: SSAR Chapter 14, Sections 14.2.10.3.6 & 14.2.10.4.12 1

APRIL 19,1995 (HSII) DISCUSSION ITEMS l

14. Reactor Vessel Head Vent SSAR Chapter 15):

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Branch Technical Position RSB 5-1 in SRP Section 5.4.7 states that the initial test program should include tests with supporting analysis to confirm that (1) adequate mixing of borated water added prior to or during cooldown can be achieved under natural circulation conditions, and (2) the cooldown under NC conditions can be achieved within the limits specified in the emergency operating procedures. Discuss how the AP600 satisfies this position.

Response

Subsection 14.2.10.3.6 describes natural circulation testing, which includes simulation of reactor decay heat and, specifies that data characterizing the plant under natural circulating conditions be obtained. This data is sufficient ^

to support analysis to confirm that adequate mixing of borated water can be achieved under natural circulation conditions.

The capability to cooldown the reactor using active systems is demonstrated during the hot functional portion of preoperational testing of the reactor coolant system, steam generator system, startup feedwater system, normal residual heat removal system, and plant cooling water systems; prior to fuel loading. This testing verifies that each component perfonns in accordance with its design requirements. Additional testing of the capability to remove heat via the steam generators in a controlled manner is described in subsection 14.2.10.4.12, steam dump control system testing. These component perfonnance capabilities are part of the calculational basis for the cooldown limits which are specified in the operating procedures.

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Re: SSAR Chapter 14, Section 14.2.9.1.1 Question 260.35 Initial Test Program (ITP) Test Abstract 14.2.8.1.25, Reactor Coolant System (RCS) Hydrostatic Test: The s

Acceptance Criterion should be revised to clearly indicate that if there is any evidence of leak within the hydrostatic

, test boundaries, the eak should be repaired and retested prior to final inspection.

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Response

Subsection 14.2.9.l.1, which includes the hydrostatic test of the reactor coolant system, has been revised to indicate t

that if there is evidence of leakage, the leak is to be repaired and retested prior to final inspection.

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-u rau OITS 2544 Re: SSAR Chapter 14 Section 14.2.9.2.9 Question 260.36 ITP Test Abstract 14.2.8.1.26, Chilled Water System: (1) Use of system nomenclature should be consistent. This abstract and/or SSAR Section 9.2.7, Central Chilled Water System of the Standard Safety Analysis Report (SSAR) should be re-labeled accordingly; (2) The Objective subsection should be revised to include verification of proper

' performance of the system components.

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Response

The test abstract for the central chilled water system in subseci.

4.2.9.2.9, has been revised to refect the correct nomenclature and to require verification of the proper operat.' c / the system components.

Westinghouse Status: Closed 1

s RESPONSE TO DSER OPEN ITEMS OITS 2545 Re: SSAR Chapter 14, Sections 14.2.9.2.9 & 14.2.9.4.6 Question 260.37 ITPTest Abstracts 14.2.8.1.26 Chilled Water System and 14.2.8.1.61, Circulating Water Sys and Acceptance Criterion subsections of these abstracts should be revised to incorporate v system testing requirements at rated volumetric flow conditions, pressu applicable SSAR sections. instrumentation and system controls in all logic combinations, (2 air-operated control valves, including open/ closure cycling and timing, and position indicator v functions (when applicable),(3) proper operating conditions (flow, vibration, bearmg temperature) of system in design mode of operations, including verification of acceptable net positive suction head (NPSH) u limiting design flow conditions, and (4) proper operating conditions and system performance capa during all operational (normal and abnormal) modes.

Response

Test abstracts for the central chilled water system in subsection 14.2.9.2.9, and for the circulating water sy subsection 14.2.9.4.6 have been revised to provide verifications to assure proper operation of the system component Westinghouse Status: Closed 1

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RESPONSE TO DSER OPEN ITEMS jis-m OITS 2546 Re: SSAR Chapter 14. Section 14.2.9.4.11 Question 260.38 ITP Test Abstract 14.2.8.1.27, Containment Recirculation Cooling System: 'Ihe Objective subsection should be revised to incorporate verification of integrated system testing requirements at rated volumetric flow conditions, pressure, and temperature as specified in SSAR Section 9.4.6.

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Response

The test abstract for the containment recirculation cooling system in subsection 14.2.9.4.11, has been revised to incorporate verification of the integrated system performance.

Westinghouse Status: Closed 1

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Wh1 OJTS 2547 Re: SSAR Chapter 14, Sections 14.2.9.1.2 & 14.2.10.1.22 Question 260.39 ITP Test Abstract 14.2.8.1.30 Feedwater Control System: The Test Method subsection should be revised to incorporate verification that automatically initiated valve open/ closure cycling and timing meets the system design basis requirementa.

Response

The test abstract for the steam generator system in subsection 14.2.9.1.2, speci.fies that the proper operation of the main and startup feedwater valves is verified, including automatic open/close valve operation and timing. Additional testing of the main feedwater valves is specified with the reactor at power during the startup testing described in subsection 14.2.10.l.22.

Westinghouse Status: Closed 4

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e RESPONSE TO DSER OPEN ITEMS ra OITS 2548 Re: SSAR Chapter 14 Sections 14.2.9.1.1, 14.2.10.1.18, & 14.2.10.4.12 Question 260.40 ITP Test Abstract 14.2.8.1.40, Reactor Coolant Pump initial Operation: The Test Method subsection should specify the system and pump operating parameters to be tested or measured.

Response

The test abstract for the reactor coolant system in subsection 14.2.9.1.1, has been revised to include verification of proper reactor coolant pump operation. Additional testing of the reactor coolant pumps is specified during the startup testing described in subsections 14.2.10.l.18 and 14.2.10.4.12 following the initial fuel loading.

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e OITS 2549 Re: SSAR Chapter 14. Section 14.2.9.l.1 Question 260.41 ITP Test Abstract 14.2.8.1.41 Reactor Coolant System: (1)"Ihe Test Method subsection should specify the data and parameters to be verified during con: ol systems circuitry and system valves operation; (2) The Performsnce Criteria subsection should specify (i) acceptance criteria for the measured parameters, including response times, for "the control systems and valves, and (ii) acceptance criteria for the head vent system operation.

Response

The test abstract for the reactor coolant system in subsection 14.2.9.1,1, has been revised to include verification of proper valve and control system operation and to include reference to design specifications which specify the functional requirements and operating parameters.

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OITS 2550 Re: SSAR Chapter 14. Section 14.2.9.2.4 Question 260.42 ITP Test Abstract 14.2.8.1.42. Normal Residual Heat Removal System: The Test Method subsection should specify the functional requirements, parameters to be measured, and data to be recorded for each test objective and each mode of operation.

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Response

The test abstract for the normal residual heat removal system in subsection 14.2.9.2.4 has been revised to include reference to design specifications which specify the functional requirements and operating parameters for each mode of operation.

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OITS 2551 Re: SSAR Chapter 14, Section 14.2.9.1.7 Question 260.43 ITP Test Abstract 14.2.8.1.49, Thermal Expansion: Westinghouse should n: vise this abstract to provide a committnent that this test will be conducted in accordance with the American Society of Mechanical Engmeets (ASME) OM Standard. Part 7 (Ref.: Draft Safety Evaluation Report (DSER) Confirmatory Item 3.9.2.1-3).

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Response

The test abstract for thermal expansion testing in subsection 14.2.9.1.7, has been revised to include reference to the ASME OM Standard. Part 7.

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OITS 2552 Re: SSAR Chapter 14, Section 14.2.9.1.1 Question 260.44 ITP Test Abstract 14.2.8.1.64, Reactor Coolant System Flow Measurement: (1) The Objective sub j

be modified to include verification of proper operation of the RCS at conditions approaching rated opera Baseline RCS pressure drops will also need to be established; (2) 'The Test Method -

temperature and pressure.

subsection needs to be modified to include closer coordination of the performsuse of this test with this o Reactor Coolant System, in order to adequately demonstrate proper integrated system response and o The Performance Criteria subsection needs to be revised to include acceptance criteria for the RCS pressu flow rate (accounting for measurement uncertainty allowances), or provide reference to the appropriat delineating such acceptance criteria.

Response

1 The test abstract for the reactor coolant system in subsection 14.2.9.1.1 has been revised to include flow measurement testing at elevated pressure and temperature and references the appropriate SSAR sections a specifications for acceptance criteria.

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x OITS 2553 Re: SSAR Chapter 14, Sections 14.2.9.1.1 & 14.2.9.1.7 Question 260.45 ITP Test Abstract 14.2.8.1.67. Reactor Coolant System Hot Functional Test: (1)'Ihe Objective subsection should outline all preoperational tests that will be performed (or encompassed) as part of this test. and (2) In response to

. request for additional infonnation (RAI) 210.59, Westinghouse agreed to implement a monitoring program at the first AP600 plant to record temperature distributions, thermal displacements and other pertinent parameters of the pressurizer surge line for verifying assumptions used in the surge line thermal stratification analysis. Therefore, the implementation of this monitoring program should be reflected in this abstract and/or in another section of the ITP, accordingly.

In addition. DSER Open Item 3.12.5.10-1 requests identification of other piping systems susceptible to thermal stratification, and a description of the methods used to assure their structural integrity. If a monitoring program is intended to be implemented by Westinghouse during the hot functional test for resolving thisopen item, the program should also be included in the ITP.

Response

The test abstract for the reactor coolant system in subsection 14.2.9.1.1, has been revised to include the testing performed at elevated pressure and temperature. 'Ihe expansion / vibration test abstract, subsection 14.2.9.1.7, has bee revised to include testing on surge line temperature distributons, thermal displacements, etc. for surge line thermal stratification analysis, as previously commited in RAI response to Q210.59. Also in response to DSER item 3.12.5.10-1, additional temperature measurments on the pressurizer spray piping are specified.

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-a n-OITS 2554 Re: SSAR Chapter 14, Section 14.2.9.2.3 Question: 260.46 ITP Test Abstract 14.2.8.1.75, Boric Acid Batching Operation: Westinghouse should clarify whether the test is to be performed with or without boric acid.

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Response

Chapter 14 has been revised and a specific test abstract for boric acid batching is not included. Test abstracts for the chemical and volume control system which perfotms this function, subsections 14.2.9.1.5 and 14.2.9.2.3, specify testing of valves that control boric acid use.

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OITS 2555 i

Re: SSAR Chapter 14. Section 14.2.9.2.2 Question 260.47 i

11P Test Abstract 14.2.8.1.91, Startup Feedwater Control System: (1) The Objective subsection should be revised to incorporate verification of the startup feedwater control system automatic initiation capability, and (2) The Test Method subsection should be revised to require verification of the automatic initiadon of the startup feedwater control system upon receipt of a loss of main feedwater supply signal.

Response

The test abstract for the main and startup feedwater system in subsection 14.2.9.2.2, has been revised to specify that i

the proper actuation / start of the startup feedwater pumps is to be Air.ca.tised.

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RESPONSE TO DSER OPEN ITEMS OITS 2556 Re: SSAR Chapter 14, Section 14.2.1.10 Question 260.48 ITP Test Abstract 14.2.8.1.93, Reactor Containment Structural Integrity Test: In the Objective subsection, the reactor containment building should be changed to reactor containment vessel.

Response

The test abstract for the containment isolation and leak rate testing in subsectinn 14.2.9.l.10 has been revised to specify that the containment vessel is pressure and leak tested.

Westinghouse Status: Closed 4

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OITS 2557 Re: SSAR Chapter 14 Section 14.2.9.1.4 Question 260.49 ITP Test Abstracts 14.2.8.1.%, Passive Containment Cooling System and 14.2.8.I.97, Passive Containment Cooling System (First Plant Only): These test abstracts should be modified to encompass the Objective of 14.2.8.1.97 into a single comprehensive test abstract based upon 14.2.8.1.%. Such abstract would then be applicable to all plants.

not just the prototype.

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Response

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The test abstract for the passive containment cooling system in subsection 14.2.9.1.4 has been revised to include system testing for each AP600 plant.

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OITS 2558 Re: SSAR Chapter 14. Section 14.2.10.1.1 Question 260.50 ITP Test Abstract 14.2.8.2.1, Initial Fuel Loading Test Sequence: (1) The Prerequisites subsection of this abstract should: (1) include the Objectives in 14.2.8.2.2. Initial Fuel Loading, and in 14.2.8.2.3, Fuel Loading Prenquisites

,and Periodic Checkoff, and (ii) outline all systems required for the n t ai i i l fuel loading; (2) The perform for 14.2.8.2.2 and 14.2.8.2.3 should be included in the Performance Criteria subsection of this abstrac

Response

The test abstract for the initial fuel loading in subsection 14.2.10.1.1, has been revised to include fuel loading 14.2.10.1.5 is l

prerequisites and periodic checkoff. A checklist for the initial fuel loading abstract in subsection provided.

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OITS 2559 4

Re: SSAR Chapter 14 Que:, tion 260.51 Westinghouse should revise the following AP600 SSAR Chapter 14 test abstracts in order to provide specific 1

acceptance criteria or design basis functional requirements traceable to the appropriate SSAR sections:

l s.14.2.8.1.40. Reactor Coolant Pump initial Operation

b. 14.2.8.1.42 Normal Residual Heat Removal System
c. 14.2.8.2.11. Fod Drop Time Measurement
d. 14.2.8.2.32. Bank Worth Measurement e.14.2.8.2.55. Plant Trip from 100 Percent Power R,esponse:

The test abstracts for the tests listed below have been revised to include acceptance criteria or reference to design specifications and the appropriate sections of the SSAR:

a.

14.2.9.1.1 Reactor Coolant System Testing which includes reactor coolant pump initial operation b.

14.2.9.2.4 Normal Residual Heat Removal System c.

14.2.10.1.14 Rod Drop Time Measurement d.

14.2.10.3.5 Bank Worth Measurement e.

14.2.10.4.24 Plant Trip from 100 Percent Power i

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OITS 2560 Re: SSAR Chapter 14, Sections 14.2.10.l.5 & 14.2.10.1.1 Question 260.52 ITP Test Abstracts 14.2.8.2.2. Initial Fuel leading, and 14.2.8.2.3, Fuel Loading Prerequisites and Periodic Checkoff:

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'Ihe objectives of these two tests appean to be redundant. Westinghouse should amalgamate them with 14.*,8.2.1.

Response

The test abstract for the initial fuel loading in subsection 14.2.10.1.5, has been revised to include both initial fuel loading and initial fuel loading sequence tests. Subsection 14.2.10.1.1 contains the test abstract for fuel loading and J

prerequisites and periodic checkoff.

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OITS 2561 Re: SSAR Chapter 14, Section 14.2.10.1.2 Question 260.53 i

ITP Test Abstract 14.2.8.2.4, Reactor System Sampling for Fuel Imding: Vedfication of the requirements in the Objective of this abstract should be included in its prerequisites.

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Response

The test abstract for reactor systems sampling for fuel loading, subsection 14.2.10.1.2, specifies the boron concentration requirements that are to be verified prior to initiating fuel loading in the performance criteria section.

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OITS 2562 Re: SSAR Chapter 14. 14.2.10.l.4 Question 260.54 ITP Test Abstract 14.2.8.2.6. Inverse Count Rate Ratio Monitoring for Fuel leading: The requirements in the Prerequisites. Test Method and Perfonnance Criteria subsections do not appear to be consistent with the Objective of the test abstract.

Response

The test objectives of the abstract for inverse count rate ratio monitoring, subsection 14.2.10.1.4, have been revised to rnore clearly denote the test purpose.

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RESPONSE TO DSER OPEN frEMS m-Oi 'S 2563 Re: SSAR Chapter 14. Section 14.2.10.1.6 Question 260.55 ITP Test Abstract 14.2.8.2.7, Post-Fuel Loading Precritical Test Sequence: (1)1he Prerequisite subsection should be revised to include specific plant system conditions; and (2) The information in the Test Method and Acceptance Criteria subsections is inadequate.

Response

Subsection 14.2.10.1.6 on post-fuel loading precritical test sequence, has been revised to specify plant system conditions and acceptance criteria as contained in subsequent precritical testing.

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OITS 2564 Re: SSAR Chapter 14, Section 14.2.10.1.18 Question 260.56 1

Response

' Subsection 14.2.10.1.18 on reactor coolant system flow coastdown, has been revised to include flow coastdown testing with two and four reactor coolant pumps tripped, and reference to the appropriate SSAR analyses in Chapter 15 are provided. This testing is consistent with the events analyzed in the SSAR where the trip of two of four pumps is the limiting condition Il loss of flow event, while the trip of all four pumps is the limiting condition [Il ;oss of flow event. Analyses of the trip of one pump and of three of four pumps are not perfomed since the one pump case

~ is not limiting, and the loss of three pumps would require two simutaneous, independent failures.

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OITS 2565 Re: SSAR Chapter 14. Section 14.2.10.3.4 Question 260.57 ITP Test Abstract 14.2.8.2.31, Isothermal Temperature Coefficient Measurement: It appears that the isothermal t

temperature coefficient (ITC) mervrement will be limited to just two end-point rod configurations (near fully withdrawn or near fully inserted) while the reactor coolant system boron concentration remains constant.

Westinghouse should revise the Prerequisite and/or Test Method subsections of this abstract to perform ITC measurements at various rod configurations and boron concentrations which would more conservatively reflect actual reactor coolant system behavior or should provide justification to establish that the proposed measurement in the current abstract would yield similarly conservative values.

Response

The isothermal temperature coeffient measurement testing specified in Subsection 14.2.10.3.4 need only be performed at the near fully withdrawn and near fully inserted rod positions since this provides the most positive value, and a design verification point, of the moderator temperature coefficient, respectively; over a large range of the isothe temperature coefficient.

Westinghouse Status: Closed e

o RESPONSE TO DSER OPEN ITEMS sw m-OITS 2566 Re: SSAR Chapter 14. Section 14.2.10.4.6 Question 260.58 ITP Test Abstract 14.2.8.2.47 Rod Cluster Control Assembly Out of Bank Measurement (First Plant Only): (1) The l

Test Method subsection requires that a group of selected rod cluster control assemblies (RCCA) be inserted "first,

, to the technical specification limit of misalignment." However SSAR Chapter 15 currently specifies RCCA alignment limits. Westinghouse should revise the text in the abstract accontingly; (2) The test Method subsection should specify parameters to be measured and describe expected power distributions; and (3) The Performance Criteria subsection should specify the acceptance criteria for the sensitivity of the incore and excore instrumentation to RCCA misalignment.

Response; Subsection 14.2.10.4.6 on rod cluster control assembly out of bank measurements, has been revised to reference SSAR subsection 15.0.5 for the rod misalignment limit, and to provide additional infonnation on parameters to be, measured and acceptance criteria.

Westinghouse Status: Closed 4

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OITS 2567 Re: SSAR Chapter 14, Section 14.2.10.4.20 Question 260.59 ITP Test Abstract 14.2.8.2.49 L,oad Swing Test: (1) The Test Method subsection should identify the plant parameters to be monitored and recorded: and (2) The Performance Criterion subsection should specify the acceptable ranges of the primary and secondary pressure, level, temperature, etc. at various power levels, or provide specific acceptance criteria or design basis functional requirements traceable to the appropriate SSAR sections.

Response

The test abstract for the load swing test, subsection 14.2.10.4.20, has been revised to identify key plant parameters to be monitored, and the acceptance criteria has been expanded to include a review of plant response and adjustment of control systems,if necessary.

Westinghouse Status: Closed g

o RESPONSE TO DSER OPEN ITEMS OITS 2568 Question 260.60 Re: SSAR Chapter 14 ITP Test Abstract 14.2.8.2.50,50 Percent Load Rejection: The Performance Criterion acceptable ranges.of the primary and secondary pressure, level, temperature, etc. or p criteria or design basis functional requirements traceable to the appropriate SSAR sections.

Response

The test abstract for the 50% load rejection test has been deleted.1he AP600 is designed t 14.2.10.4.21.

rejection which is included in the startup testing program in subsection Westinghouse Status: Closed 6

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o RESPONSE TO DSER OPE % ITEMS g=m tn EM-OITS 2569 Re: SSAR Chapter 14 Section 14.2.10.4.21 Question 260.61 ITP Test Abstract 14.2.8.2.51,100 Percent Load Rejection (First Plant Only): The Test Method subsection sh identify the plant parameters to be monitored and recorded.

Response

The test method section of the 100% load rejection test, subsection 14.2.10.4.21, has been revised to include the k plant parameters to be measured.

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OITS 2570 Re: SSAR Chapter 14 Question 260.62

'Ihe staff has identified the following systems, components, and/or features that do not appear to have been incorporated within the AP600 ITP:

a. Ventilation System through Fire Walls and Smoke Removal
b. Fire Dampers and Doors
c. Onsite Standby Power System (Onsite Standby Diesel Generator Support System)
d. Containment Igniters
e. Annex /Assiliary building Non-Radioactive HVAC System j

f.

Health Physics and Hot Machine Shop HVAC System l

g. Turbine Building Ventilation System hl Reactor Vessel Flooding System / Vessel Insulation Arrangement (testing should not inv'olve flooding the cavity.

but would encompass confirming: (1) flow paths / areas between the IRWST and the cavity, (2) drainage paths, j

into the cavity, (3) flooder valve operability, (4) gaps / openings in the insulation systern for water ingression and

)

egression, (5) integrity of insulation support system and outer surface of vessel lower head)

For the items listed above, Westinghouse should identify and revise the pertinent test abstracts or summaries to encompass them, or create additional abstracts accordingly.

Response

Chapter 14 has been revised to include test abstracts as specified in Regulatory Guide 1.68, Revision 2. Appendix A which includes testing for the listed systems / components:

Ventillation through fire walls and smoke removal Fire dampers and doors Diesel generator support systems (cooling, ventilation, oil, etc)

Containment igniters Nuclear Island non-radioactive and radiologically controlled area HVAC Drain paths to the containment sump Confirmation of the reactor vessel flood flow areas and insulation arrangement are inspections performed during/after Constmetion.

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OITS 2571 Re: SSAR Chapter 14. Sections 14.2.9.1.16 & 14.2.9.4.16 Question 260.63 Westinghouse should include a pre-operational test abstract for (a) the 480V non-Class IE transportable ac generator and its distribution panel, including the incoming and outgoing feeder circuit breakers and plug-in type twist lock,

, connectors pre-wired to outgoing feeder circuit breakers; and (b) the Digital Metal Impact Monitoring System.

Response

The test abstract for long term safety-related system testing in subsection 14.2.9.1.16, has been revised to include verification of the proper operation of the 480V non-Class IE transportable ac generator.

In addition, the test abstract for the digital metal impact monitoring system is included ir, subsection 14.2.9.4.16.

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-m raw-OITS 2572 Re: SSAR Chapter 14 Section 14.2.10.4.23 Question 260.64 JTP Test Abstract 14.2.8.2.53. Hot Full Power Boron Endpoint: (1) De Test Method subsection specifies that measurement of the RCS critical boron concentration be only performed for a single RCCA configuration (all rods out, hot fiill power, and equilibrium xenon). Westinghouse should revise the Prerequisite and/or Test Method' subsectiorn of this abstract to perform critical boron concentration measurements at various RCCA configuradons l

which would more conservatively reflect actual reactor coolant system behavior, or should provide adequate justificadon to establish that the proposed measurement in the current abstract would yield similarly conservative values; and (2) ne Test Method requires the renormalization of the predicted boron concentration as a function of core bumup using the corrected (or resultant) measured boron concentration. De Acceptance Criterion should specify the difference between the measured and predicted boron concentrations expected after renormalizatio provide specific acceptance criteria traceable to the appropriate SSAR sections.

Response

The test abstract for the hot full power boron endpoint, subsection 14.2.10.4.23 has been revised to include reference to SSAR subsection 4.3.3.3 which specifies the acceptance criteria. His abstract correctly specifies that the rods*

be at a nearly withdrawn position for boron endpoint determination. Le boron endpoint determination at zero power, subsection 10.2.10.3.3, and the bank worth measurement test, subsection 10.2.10.3.5, provide data for establishing the bcron concentrations for other rod positions.

j Westinghottse Status: Closed i

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o RESPONSE TO DSER OPEN ITEMS gi!ausmui OITS 2639 Re: SSAR Chapter 14, Section 14.2.9.1.14 Question 260.65 Chapter 14 Initial Test Program: 14.2.8.1.2. Class IE Uninterruptible Power Supplies: This test abstract does not reflect the design and configuration of the AP600 Class IE DC distribution system. Specifically, SSAR Section 8.3.2.1.1.1, Class IE DC distribution, states that there are four independent, Class IE 125Vdc divisions (A. B, C, and D) each comprised of one battery bank (designated as 24hr battery bank) that provides power sources to the loads required for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a loss of all ac power concurrent with a design basis accident (DBA).

The second battery bank in divisions B and D (designated as 72hr battery bank) is used to supply those loads requiring power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a DBA. No load shedding or load management program is needed to feed the, essential loads during the required safety actuation periods.

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All subsections of this test abstract need to be revised to reflect the unique design features of the AP600 de power systems as described in the SSAR.

Response

The test abstract for the Class IE DC and UPS system in subsection 14.2.9.1.14 has been revised to properly reflest the AP600 design.

Westinghouse Status: Closed i

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RESPONSE TO DSER OPEN ITEMS fuim OITS 2640 Re: SSAR Chapter 14 Section 14.2.9.2.12 Question 260.66 Chapter 14 -Initial Test Program: 14.2.8.1.17. Process Computer: The Performance Criteria subsection of this test abstract should be revised to provide specific acceptance criteria or design basis functional requirements traceable to the appropriate SSAR section(s).

Response

The test abstract for the plant control system in subsection 14.2.9.2.12 has been revised to include reference to the appropriate SSAR section for the performance criteria.

Westinghouse Status: Closed i

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OITS 2641 Re: SSAR Chapter 14 Section 14.2.9.4.13 Question 260.67 Chapter 14. Initial Test Program. 14.2.8.1.18,In-Plant Communication System: The Test Methods and Performance Criterion subsections of this abstract need to be revised to demonstrate acceptable performance of all subsystems encompassed by the In Plant Communication System as described in SSAR Section 9.12.

Response

The test abstract for the plant communication system in subsection 14.2.9.4.13 has been revised to include verification of the proper perfotmance of the system subsystems.

Westinghouse Status: Closed G

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OITS 2642 Re: SSAR Chapter 14, Section 14.2.9.2.12 Question 260.68 Chapter 14 - Initial Test Program. 14.2.8.1.51, Operations and Control Center System: This test abstract does not.

. reflect the design and configuration of the AP600 Opera: ions and Control Center System. Specifically, the primary plant control system operator interface is a set of " soft" control units that replace conventional switch / light or potentiometer / meter assemblies used for operator interface with control systems. The function-based test analysis serves as the basis for determining the alarms, displays, contre!s, and procedures in the main control area.

The Test Methods and Performance Criterion subsections of this abstract need to be revised to demonstrate acceptable performance of, and to encompass, these unique AP600 design features.

Response

The test abstract for the plant control system in subsection 14.2.9.2.12 has been revised to reflect the use of " soft" controls and function-based analysis for alarms, displays, controls, and procedures used in the AP600.

Westinghouse Status: Closed 9

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OITS 2643 Re: SSAR Chapter 14, Section 14.2.9.1.12 Question 260.69 Chapter 14 Initial Test Program. 14.2.8.1.59, Engineered Safety Features Actuation Cabinets Test Capability: This test abstract does not reflect the configuration of the AP600 computer based protection system design. This section is's subset of Section 14.2.8.1.72, " Protection and Safety Monitoring." The primary pugose of Section 14.2.8.1.72 is to demonstrate the acceptability of reactor trip logic functions while the primary purpose of this section is to demonstrate acceptable perfonnance of the Engineered Safety Features Actuation System (ESFAS). This test needs to be revised to encompass and properly verify acceptable performance of the isolated fiber-optic data / communication links, including associated protocols, of (a) the Integrated Protection Cabinet to/from Engineered Safety Features Actuation Cabinets (b) the Engi.,eered Safety Features Actuation Cabinets to/from the Protection Logic Cabinets, and (c) the Protection logic Cabinets to/from the Protection Multiplexer Cabinets.

R'esponse:

The test abstract for the protection and safety monitoring system in subsection 14.2.9.1.12 has been revised the AP600 computer based protection system design.

Westinghouse Status: Closed

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OITS 2644 Re: SSAR Chapter 14. Section 14.2.9.1.1 Question 260.70 Chapter 14. Initial Test Program. 14.2.8.1.68, Resistance Temperature Detector Cross Calibration: Westinghouse should revise the subsections of this test abstract as follows: (a) the Objective subsection should include verification of response times, and accuracy requirements consistent with the safety analysis included in Chapter 15 of the SSAR:

(b) the Prerequisites subsection should be revised to describe the in-situ or laboratory calibration testing that will be performed to verify the manufacturer's calibration data (including range, accuracy, repeatability, dynamic response, environmental qualification, calibration reference, and calibration intervals): (c) the Test Method subsection should be revised to clearly establish bounds for RTD calibration. Particularly, the dependency of the data on uniform 4

coolant temperature and flow should be emphasized; and (d) the Performance Criteria subsection should be revised to include the basis for the acceptance criteria and values of cross-calibration points monitored in-situ throughout the RTD range, to assure that the data is adequate for detecting degradation or systematic drift.

. Response:

The test atstract for the reactor coolant system in subsection 14.2.9.1.1 specifies that the proper operation of tip resistance ten.perature detectors is verified, and additional testing is described in subsection 14.2.10.1.8.

Westinghouse Status: Closed 4

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Re: SSAR Chapter 14. Section 14.2.9.1.12 Question 260.71 1

Chapter 14 - Initial Test Program. 14.2.8.1.72. Protection and Safety Monitoring System: This test abstract does not reflect the configuration of the AP600 computer based protection system design. See item 260.69 above.

' Response:

The test abstract for the protection and safety monitoring system in subsection 14.2.9.1.12 has been revised to reflect the AP600 computer based protection system design.

Westinghouse Status: Closed

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RESPONSE TO DSER OPEN ITEMS mm-OITS 2646 Re: SSAR Chapter 14. Section 14.2.9.1.1 Question 260.72 Chapter 14 -Initial Test Program. 14.2.8.1.81, Pressurizer Pressure and level Control: The Test Method subsection does not include testing of signal selector arxl isolation devices. Westinghouse should revise this subsection to encompass testing of these devices or should identify the test abstract that encompasses such testing.

Response

The test abstract for the reactor coolant system in subsection 14.2.9.l.1 specifies that the proper operation of the pressurizer pressure and level control is verified. Additional testing is also performed during the startup testing.

Detailed methods for perferming this verification, including signal selector and isolation devices, are to be included in the actual test procedures developed by the COL applicant.

Westinghouse Status: Closed i

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SSAR Chapter 14. Section 14.2.9.1.12 Question 260.73 Chapter 14 - Initial Test Program. 14.2.8.1.95, Reu: tor Trip System and Engineered Safety Features Actuation Cabinets System Response Time Test: This abstract should be revised as follows: (a) the Objective subsection,

, should incorporate verification of "Real Time Performance" of the digital system (the architecture of the digital system affects the response time of the RTS and the ESFAS performance); (b) the Prerequisites subsection should incorporate the determination of sensor delays and actuator delays (by setpoint study). Since real-time deadlines for the digital part of the reactor protection system are computed by subtracting sensor delay and actuator delay (mm the maximum response times established by analysis of Chapter 15 events, software units timing limits should be available to demonstrate that software units adequately meet their timing specifications.

Response

The test abstract for the protection and safety monitoring system in subsection 14.2.9.1.12 includes testing of the, reactor trip function, and requires verification that the trip delay time is less than the allowable maximum response time. Additional testing of trip function and rod drop time is also performed during startup testing.

Westinghouse Status: Closed 4

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i Re: SSAR Chapter 14. Section 14.2.9.2.12 Question 260.74 Chapter 14 - Initial Test Program. 14.2.8.2.46, Plant Control System: The scope of this test should be expanded to encompass all other Plant Control System subsystems as identified in SSAR Chapter 7.1.

Alternatively.

Westinghouse should identify the test abstracts that currently encompass such subsystems.

Response

"Ihe test abstract for the plant control system in Subsection 14.2.9.2.12 has been revised to include the control functions specified in SSAR Section 7.1.

Westinghouse Status: Closed 1

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OITS 2931 Re: SSAR Chapter 14, Section 14.2.3 Question 260.75 i

l Westinghouse will develop criteria to be used in its graded approach to testing to detennine if identified testing should be included in preoperational testing program or " acceptance testing" program.

Westinghouse will provide the criteria for staff review by March 31,1995.

Response

Chapter 14 has been revised to include test abstracts in accordance with the applicable systems specified in Regulatory Guide 1.68, Revision 2. Appendix A. Subsection 14.2.3 and Westinghouse letter NSD-NRC-96-4772 dated 7/16/96, describe distinctions between safety-related and non-safety related system testing quality assurance requirements and procedure review.

Westinghouse Status: Closed l

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OITS 2932 Re: SSAR Chapter 14, Section 14.2.9 Question 260.76 Westinghouse will oc elop criteria for determining if an ITP test should be performed on the first AP600 only or on all AP600 plants. Westinghouse will provide the criteria for staff review by March 31,1995.

Response

Chapter 14 specifies the criteria used to determine if an ITP test should be performed on only the first AP600 plant or on all plants, in Subsection 14.2.9. Also refer to Westinghouse letter NSD-NRC-96-4772, dated 7/16/96.

Westinghouse Status: Closed i

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2 NRC REQUEST FOR ADDITIONAL INFORMATION l

Question 260.77 Re: Prevention of Passive Safety System Strainer Clogging Westinghouse will provide the method (s) that will be used to prevent strainer clogging in the passive safety systems.

Response

The AP600 has two types of sumps, the IRWST sump and the containment recirculation sump. In addition to proper sump design, screen design and layout, several other factors will prevent clogging of these sumps by debris during accident operations. Sump desigr. methods and other factors affecting the plugging potential of the strainers are listed below.

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Sump design and sump locations meet Regulatory Guide l'.82 Revision 2 and incl.ude:

C.l.1 Two sump locations for each type of sump C.I.2 Separated sump locations C.I.3 Sumps located t,.. lowest floor above reactor cavity. Each sump has two screens, coarse and fine, -

and debris curb capability C.I.4 Floors stone away from sumps i

C.I.5 No inconung.i.ains impinge on sumps C.l.6 Sump screens can withstand accident loads and missiles C.I.7 Conservative sized screen area to account for plugging C.I.8 System and Sump performance evaluated C.I.9 Sumps have solid top cover

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C. I.10 Seismic qualified screens j

C. l.11 Screen openings sized properly C. I.12 Sumps designed for adequate pump performance (Note that the nonsafety-related normal residual I

heat removal pumps are designed to take suction from the IRWST and the containment recirculation line..)

C.I.13 Corrosion resistant screens C. I.14 Access openings in sump screens C. I.15 Sumps inspected each refueling (COL)

2) Large screen flow areas sized for at least 50% plugging.
3) Low velocities < 0.2 ft/s in IRWST and (boded containment lirdg the transport of heavy debris (Specific Gravity > l.05).
4) Use of stainless steel reflective insulation.
5) Enclosed IRWST limits debris egress to IRWST sump.

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6) Containment recirculation screens located above lowest levels of containment.-
7) Long settling time (> 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) before initiation of containment recirculation.
8) Cleanliness program limits debris in containment (COL information item)

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260.77-1

4 NRC REQUEST FOR ADDITIONAL INFORMATION IRWST Sump The IRWST sump is at the bottom of IRWST tank and isolated from the remainder of containment. The IRWST tank is fully enclosed (except for vents and condensate collection pipes) and is lined with stainless steel. The water has a high cleanliness as it is filtered and demineralized (by the spent fuel pit cooling system) during and after each refueling. Sludge will be minimal and the COL cleanliness program will prevent foreign debris from being introduced into the tank. During a LOCA, vented RCS steam will condense on the containment shell and be directed

'by gutters to 4 inch pipes which drain into the IRWST Containment paint or other lose debris will have to be smaller than 4 inches to be drained into the tank. Since the tank is normally full, floating debris will stay on the surface above the sump, and containment paint (which has a high specific gravity) will quickly sink to the bottom of the tank. Curbs in the gutters and inside the IRWST will trap the heavier debris preventing migration to the sump.

With the low injection flows and long tank drain down times (>6 hours), no significant transport of heavy debris is expected. When the tank rea.:hes its minimum level during recirculation the water level is sMe :he top of the screens and floating debris can not be trapped on the screens.

Containment recirculation sump The intakes for containment recirculation are located on the walls above the floor elevation at 83 feet. This is 11.5 feet above the waste sump below the reactor vessel (at elevation 71.6 feet). The bottom of the inlet screen is one foot off the floor, providing a curb function. During a LOCA, water will flood the vessel cavity and adjacent floors

  • up to the 107 foot elevation. The containment recirculation line is not opened until the water level in the IRWST reaches a low level setpoint. Water level in the flooded containment when IRWST reaches the setpoint is above the top of the recirculation inlet screens. Thus during the long floodup time (>6 hours) there is not a transport of floating debris to the screens and heavy materials will have settled to the waste sump level or the 83 foot floor level.

During recirculation the water level in containment will not change significantly nor will it drop below the top of the screens. Thus the recirculation screens will be not be clogged by floating debris or by heavy debris.

The methods and factors described above will prevent clogging of the strainers.

SSAR Revision: NONE l

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OITS 2934 Re: SSAR Chapter 14 Section 14.2.9.l.4 Question 260.78 l

Westinghouse will provide additional information on testing of the passive containment cooling, which will include i

the feasibility of testing with a heated shell and the determination of air velocity as it relates to differences in J

temperature.

J

Response

The test abstract for the passive containment cooling system in Subsection 14.2.9.1.4 has been revised to include verification of the system parameters that characterize system performance. Heating the inside of containment with steam, to heat the containment shell and demonstrate passive containment cooling syqtem operation is not feasibic.

Such a test would require a very large amount of steam generation and would h' ave an adverse impact on instrumentation and electrical equipment inside containment.

Westinghouse Status: Closed l

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OITS 2935 Re: SSAR Chapter 14, Section 14.2.9.1.11 Question 260.79 Westinghouse will provide additional information on the testing requirements for the hydrogen igniters i

Response

The test abstract for the containment hydrogen control system in Subsection 14.2.9.1.11 has been revis venfication that the hydrogen igniters properly actuate and operate.

Westinghouss Status: Closed l

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OITS 2936 Re: SSAR Chapter 14. Section 14.2.9.1.11 Question 260.80 l

Westinghouse will provide the testing requirements for the passive autocatalytic recombiners.

Response

The test abstract for the containment hydrogen control system in Subsection 14.2.9.1.11 has been revised to requim verification that the passive autocatalyic hydrogen recombiners operate properly when exposed to a hydrogen environment.

Westinghouse Status: Closed l

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RESPONSE TO DSER OPEN ITEMS OITS 2937 Re: SSAR Chapter 14. Section 14.2.9.2.14 Question 260.81 Westinghouse will provide a test abstract for the diverse actuation system.

Response

14.2.9.2.14.

Chapter 14 has been revised to include a test abstract for the diverse actuation system in Subsection Westinghouse Status: Closed 8

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OITS 2938 Re: SSAR Chapter 14 Section 14.2.9.4.17 Question 260.82 Westinghouse will provide a test abstract for the loose parts monitoring system.

Response

Chapter 14 has been revised to include a test abstract for the loose parts monitoring system in Subse Westinghouse Status: Closed G

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