NUREG 75/087

& g RREGg %

@ Me'$) STANDARD REVIEW PLANb U.S. NUCLEAR REGULATORY COMMISSION

%,' ".. ./ OFFICE OF NUCLEAR REACTOR REGULATION*.

SECTICN 14.2 INITIAL PLANT TEST PROGRAM - FINAL SAFETY ANALYSIS REPORT

REVIEW RESPONSIBILITIES

Primary - Quality Assurance Branch (QAB)

Seccnda ry Analysis Bra,ch (AB)Core Performar,Je Branch (CPS)Instrumentatior. & Control Systems Branch (ICSB)Reactur Systems Br,3nch (RSB)

I. AREAS C7 REVIEW

Ihe QAE reviews items I through 11 belcw, telating to initial plant test programs,described in Chapter 14 of the final safety analysis report (FSAR) sutmitted by theapplicant as part of its operating license (OL) application. Fcr standard plantdesigns, see SRP Section 14.3, Initial Plant Test Program - Final Design Approval.

1. Summary of Test Program and Cbjectis es

The summary cescripticns for each major phase of the test program and the specifcbjectives for each major phase are reviewed.

2. Organization and Staffing

@ The information provided on the applicant's crganizational units and any augmentingcrganizaticns, or other personnel that will manage or execute any phase of the testprogram, is reviewed. The ilformaticn provided on the responsibilities, authorities,level of staffing, and qualification, of principal participants is reviewed. Theinformation desciibing the extent and nature of the participation of tN plantoperating and technical staff in the test program is reviewed.

3. Test ProceduresThe system the applicant will use to develop, review, and approve individual testprocedures is revie-ed. The responsibilities of the organizational units that willperform these activities, the designated functions of each organizational unit, andthe general steps to be folicwed in conducting these activities are reviewed. Thetype and source of design parformance inSrmation trat will be, or is being, usedin the development of detailed test procedures is reviewed. The format for thetest procedures is also reviewed.

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USNRC STAND ARD REVIEW PLAN

st.ndo o e..ew eiene e,e ,vepared to, the g-danc e of the otoce of Nucre.. R e.cier R esui.f.ca st e** re.pon .nie to the re..ew of appucet.ons to con.truct endIvetry and the

operate nuc ese power ciente These documeate ere mede eva,lebee so the pubsee os part of the Commission e polec v to mform the aus. lear ir :

9 . tory procedures and pohcees $tanderd revrew plans e e not subetstute s br seguietory guedes or the Commission S requiet ont andgoaerel public of tegtcornpIhonce wit 99 them to f4.t feg asted The Stendard feweew plan Sectier's are k eyed to Rev teon 2 of the $tenused f oemet end Contorst of Safet y Ans we e Repo"tstof Nuc4eae Rower Phants Not oal e estione e' :he Standard Fo-met have a cc espondrag review plan

new m urmat on and e.per'anceeP.,s hoked sto*ideed reweew p6ans will be row sed poe=odically es appropeiste to accommodate ;orninerite seid to retiec t

Commeate and suggest.ons tot emproveeneat wiel be ceae dered and should be sont to the U S Nuclear Regulatory Commise.oa Office of Nucle ** Reacto' R*guletton INeohengton. D C 20E46 , , ,

Pev . | r i90

4. Conduct of Test Program

The administrative controls that will gover n the conduct of each major phase of thetest program are reviewed. The specific methods to be used to assure that prereq-uisites are satisfied for individual tests a'e icciewed. The procedures to befollowed in initiating plant modifications, or repairs that are determined to berequired by the test program are reviewed. The measures taken to ensure thatnecessary retesting is performed following repairs or modifications are reviewed.The controls ' hat will be in effect to require adherence to approved test pro-cedures are reviewed.

S. Review, Evaluation, and Approval of Test Results

The controis that will govern the review, evaluation, and approval of test resultsfor each phase of the test program are reviewed, including the specific controls tobe used to assure notification of responsible organizations, such as design organi-zations, when test acceptance criteria are not met and the specific controlsestablished to resolve such problems. The applicant's controls relating to themethods and schedules for approval of test data for each major phase are reviewedas well as the methods used for initial review of parts of multiple tests

(e.g. , hot functional testing) prior to proceeding with the test phase.

6. Test Programs' Conformance with Regulatory Guides

The applicant's plans pertaining to conformance with regulatory guides applicableto initial test programs (see subsection V) are reviewed to establish the extent of

conformance. Exceptions to regulatory positions in applicable regulatory guidesare reviewed, along with the justification provided, for each guide.

7. Utilization of Reactor Operating and Testing Experiences in the Deve!apment of theTest Program

The status of the applicant's program for review of operating experiences at otherreactor f acilities is reviewed. The oegree of cunformance to commitments in thepreliminary safety analysis report (PSAR) is reviewed. A sunmary of the principal

conclusiens or findings from this review and the effect on the test program are

reviewed.

8. frial Use of Plant Operating and Emergency Procedures

The information pertaining to how, ano to what extent, the plant operating,

emergency, and surveillance procedures will be use-tested during the test program

is reviewed.

9. Initial Fuel Loading and Initial Criticality

The procedures that will guide initial fuel loading and initial criticality,

including the orerequisites and precautionary measures to be used to assure safety,are reviewed.

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IU Test Program Schedule and Sequence

The schedule for conducting each phase of the testing program relative to fuelloading date, is reviewed. Information pertaining to anticipated schedule nwrlapof the test program with test program schedules for any other reactor facilities atthe site is revie ed. The anticipated sequential test schedule for preoperationallytesting individual plant structures, systems, and co,nponerts for each test phase isreviewed. This revie is ccoducted to 35sure (1) that the planned sequence of

testing will provide for apprcpriate prerequisite system tests prior to conductingtests of critical systems or 4tems and (2) that the approximate scheduled time fortesting (relative to fuel loading) of critical structures, systems, and componentsis established such that reascnable confidace can be ma,atained in test results inthe time period between the tests and fuel loading (during which time construction<nd other test activities are being conducted). The sequence for conducting thetests planned for the startup test phase is reviewed. The time available betweenapproval of testing procedures and tneir intenced use is reviewed.

11. Individual Test Descriptions

The individual test abstracts for each test phase are r eviewed to establish thedegree of confermance with applicable tests identified in Regulatory Guide 1.63,other applicable regulatory guides, and other special testing requirements for thefacility, including those identified for special or unique plant featJres. Theobjectites for each test, summary of prerequisites and test method, and specificacceptance criteria fcr each test are revieaed to establish that the functionaladequacy of those structures, systems, or components involved will be verified.

The AB reviews information in Chapter la of the FSAR relating to those startup

transient tests that will be used, in part, for validation of transient codes and

design modeis that were used for predicting plant performance. Particular eTphasisis given to test objectives, test methods, and acceptance criteria relating totransient code and design model verification.

The ICSB and AB review the testing prorosed for cn-line digital based protectioncalculators to assure that the proposed test methods and acceptance criteria areadequate to verify the performance of the system, both during the preoperationaltest phase and the startup test phase.

The CPB reviews the information in Cnapter 14 relating to core physics tests toassure that the test objectives, test methods, and the acceptance criteria areacceptable and consistent with the design requirements for the f acility.

The RSS reviews the information in Chapter 14 relating to the items listed below toassure that the test objectives, test methods, and the acceptance criteria areacceptable and consistent with the design requirements for the facility:

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14.2-3 Rev. 1

1. Decay Heat Remsval System

2. Reactor Core Isolation Cooling System (BWRs)

3. Primary Pressure Relief System

4. Leak Detection aystem

5. Emergency Core Cooling System

6. Natural Circulation Test (PWRs)

7. toss of Reactor Coolant System flow Test

S- Contro! Rod Scram Test

9. Transient Tests

II. ACCEPTANCE CRITERIA

The tcceptance criteria for the areas of review described above are as follows:

1. Summarv of Test Program and Objectives

The applicant's description should establish that the major phases of the

pregram and the objectives for each phase are consistent with the generalguidelines and applicable regulato y posit. ions contained in RegulatoryGuide 1.68 or the justification ,, ovided for any exceptions should be found

to be acceptable by the r? viewer.

2. Organization and Staffingfhe information provided should conform to the general guidelines and regulatory

positions contained in Regulatory Gu' des 1.68 and 1.33. The minimum qualiti-

cation requirements of priricipal participants are found to be acceptable

based on the revie.er's judgment. Factors to consider in this judgment are

the assigned responsibilities of augmentinq personnel and the overallorganizational pian sur i. n e i.est program.

fhe ipplicant's commitments, pertaining to how and to what extent the plantoperating and technical staff will be utilized, should provide assurance that

such personnel will be used to the m3xirrum extent practicable. Participants

in the test program should receive plant specific training / indoctrination inthe administrative controls for the test program prior to the start of testing.

The level of staffing shuuld be adequate based on the rev iewer's judgwnt.

3. Test Procedures

The applicant's system that will t,e o ed to develop, review, and approse individualc

test orncedures should proviae for appropriate le wis of review prior to final

14 (,) 7 [L f'-ae, i n.2.1

approval. The dif ferent organizational units or personnel perf orming thesefunctions should possess, by virtue of prior training and experience, the necessaryqualifications to develop comprehensive and technically sound test procedures. Theformat for the test orocedures should be similar to tha format contained inRegulatory Guide 1.68 or the justification for exceptions should be found to beacceptable by toe reviewer. The applic:at should utilize system designers toprovide the test objectives and acceptance criteria used in developing detailedtest procedures. The participating system designers should include those of thenuclear steam supply system (NSSS) vendor, architect engineer, ar.d other majorcontrMtors, subcontractors, and vendors, as appropriate.

1. Conduct of Test Prog gThe test program should be conducted by appropriately qualified personnela.

using detailed procedures approved by designated management positions within

the applicant's organization.

b. The controls used by the applic3nt to assure that test prerequisites are metshould include requirements for inspections, checks, etc. require identifica-

tion of test personnel completing data forms or checksheets and requireidentification of dates of completion.

c. The controls provided for plant modification and repairs, identified as aresult of plant testing, are found to be acceptable if: (a) the controls aresuf ficient to assure the reqaired repairs or modifications will be made, (b) thecontrols will assure retesting is conducted following ,uch modifications orrepairs, and (c) the controls will assure a revis- of any proposed ficilitymodifications by the original design organization or other designated designorganizations. Tne applicant's requirements for documentation associatedwith such controls should permit audits to be made to assure prcper imple-

mentation of controls.

d. lhe controls pertaining to adherence to test procedures and ta methods forchanging test procedures are found to be acceptable based on the reviewer'sjudgment. Modifications to startup test procedures should be made inaccordance with tecnnical specifications for post-fuel laading tests.

S. Review, Evaluation, and Approval of Test Results

a. The controls that will govern the review, evaluation, and approval of testresults should provide for a technical evaluation of test results by qualifiedpersonnel and approval of test results by designated management positions inthe applicant's organization.

b. Design organizations should be notified and should participate in the resolutionof problems involving design that result in or contribute to a failure to moettest acceptanca criteria.

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74.2-5

c. The applicant should establish requirements for review and approval of thetest data for each major test phase, prior to beginning the next phase.

d. The applicant should establish requirements for review and approval of thetest data at each major power test plateau or power / flow test condition beforeproceeding to the next test level during the power ascensien test phase.

6. Test Program's Conformance with Regulatory GuidesThe applicant should establish and describe an initial test program that is con-sistent with regulatory positior.s in applicable regulatory guides listed inSubsection V. If exceptions to regulatory positions are taken, the applicantshould specifically identify all exceptions, and provide suitable justification.Exceptions to regulatory positions will be reviewed for acceptability on acase-by-case basis. The applicant should address all applicable regulatory guidesand identify them by guide numbe and revision number.

7. Utilization of Reactor Opera _ti..g and Testing Experiences in the Development of theTest Program

The study conducted by the applicant of operating experiences should have beena.

accomplished substantially in accordance with PSAR conmitments.

b. The conclusions reached, and the effect on the test program, should recognizeand account for categories of reportable occurrences that are repeatedly beingexperienced and other operating experiences of safety concern.

8. Trial Use of Plant Operating and Fmergency ProceduresThe applicant should incorporate the plant operating, emergency, and surveillanceprocedures into the test program or otherwise verify these procedures through useto the extent practicable dur og the test program

Initrn fuel Loading and Initial Criticality^

The procedur that will guide initial fuel loading and initial criticality shouldinclude preca ions erequisites, and measures consistent with the guidelines andregulatory positions contained in Regulatory Guide 1.68 or e c ations should befound to be acceptable by the reviewer.

10. Test Program Schedule and Sequence

a. At least nine months should be allowed for conducting preoperational testing.

b. At least three months should be allowed for conducting startup testing including

fuel loading, 1ew power tests, and power ascension tests.

Overlapping test program scheoules (for multi unit sites) shuuld not result inc.

significant divisions of responsibilities or dilutions of the staff providedto implement the test program.

\hfRev. I 14.2-6

d. The approximate sequence and time sc hedule (reiative to fuel loading) forconducU ng preoperational tests are deemed acceptable based on the reviewer's

juagmezi

lhe sequential schedule for individual startup tests should establish, insofare.

as practicable, that test requirements w:11 be completed prior to exceeding25% power for all plant structure >, systems, and components that are reliedupon to prevent, to limit or to mitigate the consequences of postulatedaccidents.

The schedule should also establish that, insofar as practicable, testing will

be accomplished as early in the test program as feasible and that the safetyof the plant will not be totally dependent on the performance of untestedsystems, components, or features.

f. Test procedures should be in a form suitable for review by regulatoryinspectors at least 60 days prior to their intendeJ use, or f or fuel loadingand startup test procedures, al least 60 days prior to fuel loading.

11. Individual Test Descriptions / Abstracts

The applicant should provide abstracts of planned tests for structures, systems,

components, and design features that will provide assurance of testing of those itemsthat meet any of the criteria listed below. Abstracts should be provided for thosestructures, systems, components or design features that:

a. Will be used for safe shutdown and cooldown of the reactor under nortnal plant

conditions and for maintaining the reactor in a safe condition for an extendedshutdown period; or

b. Will be used for safe shutdown and cooldown of the reactor under transient(infrequent or moderately frequent events) conditions and postulated accidentconditions and for maintaining the reactor in a safe condition for cn ext?ndedshutdown period following such conditions; or

c. Will be used for establishing conformance with safety limits or limitingconditions for operation that will be included in the facility technicalspecifications; or

d. Are classified as engineered safety features or will be used to support orensure the operations of engineered safety features within design limits; or

i

e. Are assumed to function or for which credit is taken in the accident analysis

for the facility, as described in the FSAR; or .

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Rev. 114.2-7

f. Wi!I be used to process, stcre, control, measure, or limit the release of

radioact. ve materials.

The abstracts should include cojectives, prerequisites, test mett W , significant

parameters and pla,t performance characteristics to be monitored, and acceptance -

criteria in sufficient detail to establish that the functional adequacy of

structures, sys teros , components , and design features will be demon 3trated bytests.

If the method for testing of a structure, system, or component will not subject

tne item or system under test to representative design operating conditions.the test abstract should contain sufficient information to justify the test

metnod tc be used.

Far those areas of revie. identified in subsection I of this SRP section as being the

responsibility of other branche3 th9 acceptance criteria and their methods of application

are contair ad in th( SRP sections corre: ponding to those branches.

111 REVIEW PROCEDURES

Preparation f o- the GM resie of Chapter 14 cf the F5AP shoulJ include the following:

1. Revie- of the Commission's Safety Evaluation Repnrt that was issued upon review ofthe Ccostruction Permit application. This rev.ew is cor, ducted for the purpose of

familiarization with the principal design criteria f;r the facility and to identify

any specific staff or ACR5 concerns or unique design features that may warrant

q.ecial 'est consideration.

of Chapters 1 tnrcugh 12 of the FSAR for the purpose of familiarization with2. Rev i ew

the f acility design and the nemenclature th3t is applied to structures, systems,

and compononts ithin the facility.

3 Review of Chapters 13 and 17 of the FSAR fra the purpose of famiiiarizatio,with the applicant's organizational structure, qualifications, administrativecontrol , and quality assurance program as these cply to or impact on thainitial test program.

1i

4. Review of Chapter 15 of the FSAR to identify assumptions pertaining to performancecharacteristics that can and should be verified by testing and to identify all

structures, systems, components, and design feature 5 that are assumed to function(either explicitly or implicitly) in the accident analysis that can and should be

tested.

5. Fesiew of a computer listing (or equivalent) of Licensee Event Reports for eueratingreactors of similar design to identify potentially serious events and chronic or

generic proDlem> thit warrant special test consideration. Computerized informationon Licensee Event Reports can te ootained through tne Office of Managem(at a,d

rrogram Analysis.

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6. Review of the Standard Technical Sp cifications for the type facility to identify

all structures systems, and components that will be relied upon for establishiryconformance with safety limits cr limiting conditinns for operat. ion.

7. The reviewer should be familia) with the results of startup tests for reactors of

similar design (reported to the Commission in Startup Test Reports) to assure thatproblem areas will be appropriately factoted into the review of tae initial testprogram.

H. The reviewer should be familiar with regulatory guides that are applicable toinitial test programs.

fhe review consists of comparison of the information in Chapter 14 or, if applicable,other chapters in the FSAR with the acceptance criteria providad in subsection 11 above.Each element of the SAR information is to be reviewed against this SRP section.Although plant test programs are not rigidly fixed, experience has shown that certainelements are common to and necessary for all plants. The revir;wer's judgment duringthe review is to be based on an inspection of the material presented, whether itemsof special safety significance are involved, and the m unituJe and uniqueness ut 'heprcject. The revieaer should recognize that certain structures, systems, and components

are more important to safety than others. The review of individual tests should beconducted in a graded manner to assure that the most emphasis is placeo v structures,systems, and components that are considered to be engineered safety features. Any

9 exceptions or alternatives are te be carefully reviewed to assure that they are clearlydefined and that an adequate basis exists for acceptance. Coordination of the reviewwith the assigned reviewer for Chapter 13 may be necessary ior items 2 and 10 with theproject manager and other branches for item 11 abNe as deemed necessary by thereviewer. In general, the appropriate branch will be requested by the QAB to reviewproposed testing for special, unique, or first-of a-kind design features to establishthe adequacy of proposed testing including the validity of test metnods. The revie4eris respcnsible for review and evaluation of all subsequent amendments to the FSAR upto the time the Operating License is issued to assuce that any changes in design orcommitments that impact on the initial test program continue to satisfy the acceptancecriteria described in subsection II above.

When the QAB reviewer has completed preparation of requests for additional information,staff positions, and SER, they should be formally transmitted to the assigned secondaryreview branches for their review and comments prior to issuance. Under norm 3l conditions ,

a period of 2 weeks should be provided for their review and comment; however, longer

or shorter schedules may be in order depending on the overall licensing schedule

IV. EVALUATION FINDINGS

When the review of the information in the FSAR is complete and the reviewer has determinedthat it is satisfactory and in accardance with the acceptance criteria in subsection 11

'D above, a statement of the following type should be provided fcr the staff's Safety,

Evaluation Report: () lbkj L'

Rev. 114.2-9

"The staff has reviewed the information provided in the finai Safety AnalysisReport v the applicant's test program in accordance with SkP Section 14.2. This

ceview included an evaluation of: (1) The applicant's organization and sta fingf

for the development, conduct, and evaluation of the test program; (2) the quali-fications and experience of the principal participants managing and supervising thetest program; (2) the administrative controls that will govern the development,conduct, and evaluation of the test program; (4) the participation of the plantoperating and technical staff in the test program; (5) the applicant's requirementspertaining to the trial use of plant operating and emergency procedures during thetest program, (6) the schedule for conducting the test program; (7) the sequence oftesti34 to be followed; (8) the mathods for conducting individual tests and theacceptance criteria to be used in evaluating the te<* results for plant structures,

|systems, and components; and (9) the test prcgrams' conformance with applicableregulatory guides including (provide list, guide no., revision no., ano date). Thereview also included an evaluation of the results of the applicant's review ofreactor p! ant operatirg experiences, conducted to determine where improvement oremphasis was warrar,ted in the initial test program. The staff has concluded thatthe information provided in the aoplication meats the acceptance criteria inSection 14.2 of the SRP and des:r;!as an acceptable initial test program that willdamcnstrate the f unctional adequacy of plant st ructures, systems, and components. "

V. REFERENCES

1. hegulatory Guide 1.68, " Initial Test Programs fcr Water-Cooled Reactor PowerP l a nt s. "

2. Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)."

3. Regulatory Guide 1.68.1, "Preoperational and Initial Startup Testing of reedwatera d Condensate Systems for Boiling Water Reactor Power Plants."

4 Regulatory Guide 1.68.2, ":n|tial Startua Test Program to Demonstrate RemoteShutdown Capability for Wate<-Cooled Nuclear Power Plants."

5. Requlatory Guide 1.20, " Comprehensive Vibration Assessment Program for ReactorInternals During Preoperational and Initial Startup Testing."

6. Regulatory Guide 1.41, "Preoperational Testing of Redundant Onsite Electric PowerSystems to Verify Prcper Load Grouo Assignments."

7. Regulator y Guide 1. 52, " Design, Testing, and Maintenance Criteria for Engineered-Safety-f eature Atmosphere Cleanup System Air Filtration and Adsorption Units ofLight-Water-Cooled Nuclear Power Plants."

8. Regulatory Guide 1.56, " Maintenance of Water Purity in Boiling Water Reactors.'

Rev. 1 M.2-1Gl 4 9 ,"i5

's

9. Regulatory Guide 1. 79, "Preoperational Testing of Eme rgency Core Cooling Systems

for Pressurized Water Reac tors. "

10. .iequlatory Guide 1.80, "Preoperational lesting of Instrument Air Systems."

11. Regulatory Guide 1.108, " Periodic Testing of Diesel Generators Used as OnsiteElectric Power Systems at Nuclear Power Plants."

12. Regulatory Guide 1.128, " Installation Design and Installation of Large Lead$torage Batteries for Nuclear Pener Plants."

13. Regulatory Guide 1.8, " Personnel Selection and Training."

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