ML20032C643

Requests That Encl List of Sys & Subsystems Be Exempt from Preoperational Test Program Prior to Fuel Load.Listed Sys Have No Impact on Plant Safety During Shutdown & Fuel Loading Conditions

ML20032C643
Person / Time
Site:	LaSalle
Issue date:	11/06/1981
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8111100682
Download: ML20032C643 (5)

Text

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1 Commonwealth Edison

[

) One First Nabontt Plaza Chicago. Illinois

(

D ] Address Reply to: Post Office bov 767

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/ Chicago. Illinois 60690 November 6, 1981 y

Mr. A. Schw ence r, Chief M

Licensing Branch #2

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,1v h4 Division of Licensing L

1.

-4 U.S. Nuclear Regulatory Commission

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987 Washington, D.C.

20555 7

Subject:

LaSalle County Station Unit 1 Completion of Preoperational Q\\

Test Program NRC Docket No. 50-373 References (a):

LSCS FSAR Chapter 14 (b):

LSCS Proposed Technical Specifications dated October 14, 1981.

Dear Mr. Schwencer:

Reference (a) described the LaSalle County Statior.

preope-rational and startup test program.

Commonwealt h Edison Company's original intentions were to complete the entire preoperational test program prior to f uel load.

However, it has become apparent that certain portions of a relatively small number of preoperational test and system descrip-tions have become the controlling items f or f uel load.

The delays in completing these tests were due to a variety of design, delivery and installation problems.

Commonwealth Edison has reviewed the remaining preopera-tional testing, considering both the safety aspects of the individual systems and the anticipated system completion d ates.

Several of the systems and subsystems involved have been determined to have no impact on plant safety during shutdown and fuc1 loading conditions.

This determination is based on the proposed Technical Specifications (Reference (b)), and, w here the Technical Specification have no specific requiremens, prudent judgement.

Attachment A presents the results of Commonwealth Edison's review and justification that these systems and subsystems should not be required to be tested or operable as a prerequisite for fuel load.

I. t is requested that approval be granted' to defer the completion of the preoperational tests listed on Attachment A beyond fuel load.

With the exception of Process Radiation Monitoring, no parts of any of the systems listed are required, and it is proposed that no test evaluation will be prepared until the test is completed.

For the process Radiation Monitoring System, a test evaluation will be 90 8111100682 811106 PDR ADOCK 05000373 A

PDR

e s

A. Schwencer November 6, 1981 completed prior to fuel load to ensure the adequacy of the portions of the system required to support fuel load.

It should be noted that in a majority of cases, it is anticipated that the physical testing will be completed prior to f uel load.

The delay in test completion will allow additional time to ensure a thorough evaluation and review of the test results.

Also included on Attachment A are the appropri-ate milestones in the Startup Test Program by which the tests and test evaluations must be completed.

A review of Chapter 14 of the FSAR has revealed that several of the startup test abstracts list, as an Initial Condition, "All construction and preoperational testing completed."

Approval by the NRC to defer completion of preoperational tests will include authorization to deviate from this startup test prerequisite until the specified milestone is attained.

It is requested that your consideration be given to this matter as soon as possible so that site resources can be allocated to complete the necessary task.

If there are any questions in this regard, please contact this office.

Very truly yours, bbs h

Direc/sl.O.DelGeorge tor of Nuclear Licensing Attachment cc:

NRC Resident Inspector - LSCS I

w/ Attachment CES/lm 4

I 2828N i

3 ATTACHMENT A Requnsted Preoperational Test Program Exemptions TEST TEST SECTIONS JUSTlFICATION PROPOSED COMPLETl0N*' ',

PT CM 101

1. Testing of particulate and

1. Per Technical Specifications, this equiprent Heatup Con ta i nmen t gaseous radioactivity monitors.

is not required to be operable during Cold Monitoring Shutdown or Refueling operations.

2. Suppression Pool Temperature

2. Suppression Pool temperature is not restricted Heatup Channels by Technical Specifications during Cold Shutdown or Refueling operations.

3. Suppression Pool Level

3. Per Technical Specifications, the Suppression Heatup Instrumentation Pool is not required to be filled if paragraph 3.5.3.b is satisfied.

PT CM 102

1. Containnent High Range Radia-

1. Per Technica! Specifications, these monitors are Heatup Post LOCA tion Monitors not required during Cold Shutdown or Refuel Containment Operations.

Mcnitoring

2. Auto Initiation of H nd 02

2. Per Technical Specifications, these monitors are Heatup 2

Monitors not required during Cold Shutdown or Refuel Operations.

PT IN 101

1. ADS Bottle Bank Regulation

1. No components supplied by Drywell Pneumatics are Heatup Drywell Valve required by Technical Specifications to be oper-Pneumatics able during Cold Shutdown or Refuel Operations.

2. ADS Accumulator Pressurization

3. ADS Accumulator Recharge Rate

4. Loss of Air Failure Mode Tests

5. Dryer Dew Point Checks

6. Relief Valve Set Point Verification

7. Component aP Checks PT H,S 101A

1. Valve Tests Per Technical Specifications, the Leakage Control Heatup MSIV. Leakage

2. Logic Checks System is not required during Cold Shutdown or Control Syscem 3. Integrated Ops Refueling Operations.

PT NR 102 '

1. Entire Test Fer Technical Specifications, the TIP System is Test Condition 1 Traversing rot required to be operable until it is used for inco're Pro' e calibration or monitoring purposes. During the S/U c

(TIP)

-Test Program it is not used until after plant heatup, and t, hen only.for p'rocess computer checkout. The system

'isinot used for APRM calibration purposes until 20%

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power is' attainedlin Test Condi tion 1.

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LATTACHMENT A

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Pequested Preop

• rational Test Program Examptions 7

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a..

i LEST ~

TEST SECTIONS JUSTlFICATION PROPOSED COMPLETION y

,s PT'0G 101

- 1r Hydrogen Sensors

'i,Per the iechnical Specif; cations,. offegas system

-Heatup

'Off-Gas ~

2. System Flow Checks L

is only required to b6 operable when the main

. System

3. Ta.mp. Control Loops, condenser air ejector system is in operation.

4. Ti lter. Leak Test,

,The air ejector system will not be operated until

5.,Pr;essurized Drain Tank Level ',

' plant heatup.

JControl PT PC 101 ALL

Per the Technfcal Specifications, primary Heatup Primary containment integrity is not requir-d during cont'ainment; Cold Shutdown or Refueling Operatione. ThIs test Leak Rate Test has been successfully comple'ted once, but is no Jonger; valid due to a shift In'the calculated x

. accident pre'ssure.

PT PR 101

1. Off Gas Pretreatment These subsy' stems'will not have anything to monitor Heatup Process

2. Off Gas Post Treatment until the main condenser air ejectors are started

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Radiation 3 ACarbon Bed Vau'l t Hon (tor during plant heatup. Although the post treatment Monitors subsystem is required to be operable at all t!mes bY the Technical Specifications, plant operation-is-allowed to continue indefinitely if the off gas f

flow is suspended, as it will be in Cold Shutdown and Refuel Conditions.

4. Main Steam Line Rad Monitors Per Technical Specifications, these monitors are Heatup not required to be operable during Cold Shutdown or Refueling Operation.

5. Radwaste Effluent Monitor Per Technical Specification, the Radwaste Effluent Prior to any dis-Monitor is required to be operable at all times; charge after the however, the only required action is to terminate liquid radwaste the release of radioactive liquids.

Prior to the system has been.

use of the liquid radwaste processing system used to process there will be no radioactive liquids to discharge. contaminated liquids.

Auxiliary Steam Radiation This subsystem monitors the Auxiliary Steam Prior to the use of Monitor System for contamination. Prior to operation of liquid radwaste to the Auxiliary Steam System to supply liquid rad-process contaminated waste, there is-no potential for contamination, liquids.

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E ATTACHiidNTJA v

R: quested Prcoperational/ Test Progi 4 Exd;ptions cl TEST TEST SF.CT10ces

' JUSTIF1(ATlCN s

- PROPOSED C0;4PLEJION' v

Aitieugh: the Ticnnical[ Specif t:atic9s require the Heatup PT SI 101 Entire Test Seismic

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seismic ~cmito.-Ing equipment te he operable at all 7

tioni toring times, thst' allow plant. operation to continue indefi-ni tcI y wi th the equipment' inoperable'. Prior to plant

, e

, pressurization, there is no credible accident. initiated or c'c,mpounded by sel:mic events wh~ch could. imperil the health i

i and safety of the.public.

O PT VP 102

1. Eeater and Flow logic

1. Pe.' Technical Specifications, the Hydrogen Recombiner Heatup Post LOCA 15 not required during Cold Shutdown or Refuel Cpe ation.

Hydrogen

2. Tempe.ature Control Logic Combiner

3. Integrated System PT VW 101

1. Flow Verifications This system does not provide ventilation to any safety Prior to using Radwaste

2. Air Conditioning Checks related eaulpnent; its design function is to prevent liquid or solid '

8 Ventilat on

3. Building Measu ramen ts ground level releases by maintaining the radwaste build-radwaste to ing at a negative pressure. No release is possible until prccess or the radwaste system is used to process centaminated handle contami-materials.

nated material.

SD CH 101 ALL

1. Not required until January 1,1982,per SER.

He.a tup HRSS -

Centainment

2. During fuel loading and open vessel testing primary con-Atmosphere tainment is not maintained.

SFould an accident occur, the Sampling con: amination would be monitored by process radiation mon-itors associated with che Stancby Gas Treatment System.

SD PS 102 ALL

1. This system is not required to be operable until Jan. 1, initial HRSS -

1982, per SER.

Criticality Liquid Sampling

2. There is no credible accident or sequence of accidents during fuel loading which could lead to contamination levels high enough to require the use of the HRSS.

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