ML20077C953

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Requests Deferral of Encl Preoperational Tests Beyond Fuel Load.Delay Due to Design,Delivery & Installation Problems. Evaluation Prior to Fuel Load Will Ensure Sys & Subsystem Adequacy
ML20077C953
Person / Time
Site: LaSalle 
Issue date: 07/21/1983
From: Reed C
COMMONWEALTH EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
6998N, NUDOCS 8307260301
Download: ML20077C953 (5)


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Commonwealth Edison one First National Pl za, Chicigo, litanois

-(CD Address Reply to: Post Offics Box 767 Chicago, Illinois 60690 July 21, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear-Regulatory Commission Washington, DC 20555

Subject:

LaSalle County Station Unit 2 Completion of LSCS Unit 2 Preoperational Test Program NRC Docket No. 50-374 References (a):

LSCS FSAR Chapter 14.

(b):

LSCS Unit 1 Technical Specifications, License NPF-11.

(c):

D. G. Eisenhut letter to L. O. DelGeorge dated May 3, 1982.

(d):

W. L. Stiede letter to H.

R. Denton dated June 21, 1983.

l

Dear Mr. Denton:

Reference (a) describes the LSCS preoperational and startup test program.

Commonwealth Edison Company's original intentions were to i

complete the entire preoperational test program prior to fuel load.

i However, it has become apparent that certain portions of a relatively small number of preoperational tests and system demonstrations have l

become the controlling items for fuel load.

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

j Commonwealth Edison has reviewed the remaining preoperational testing, considering both the safety aspects of the individual systems and the anticipated system completion dates.

Several of the systems and

-88.'

subsystems involved have been determined to have no impact on plant safety

.fML-during shutdown and fuel loading conditions.

This determination is based ok on the Unit 1 Technical Specifications (Reference (b)), and, where the 06 Technical Specifications have no specific requirements, prudent judgment.

,0 The Unit 1 Technical Specifications were used because of the fluid state g2 of the proposed Unit 2 Specifications; however, no differences between

$2) the two are expected to affect the justifications provided.

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

It is requested that-approval be granted to defer the completion of the

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H. R._Denton July 21, 1983 preoperational tests listed on the Attachment-beyond fuel load.-

With the exception of Primary Containment Isolation and Process Sampling, no parts of any of the-systems listed are required.

For these two tests, test evaluations will;be completed prior to fuel load to ensure the adequacy

.of the portions of the systems 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-fuel ~1oad.

The-

' delay in the date required.for test completion will allow additional time to ensure a thorough evaluation and review of the test results.

Also included on the Attachment are the appropriate milestones in the Startup Test Program prior to 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 construc-tion and preoperational testing _ completed."

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

Reference (c) extended the expiration of the Unit 2 Construction Permit CPPR-100 to September 30,.1983.

Reference.(d) stated that our review of the schedule of construction activities and preoperational testing indicated that fuel =can be loaded in LaSalle County Unit 2 not later than October 1,.1983.

This determination remains unchanged.

Commonwealth Edison Company requests that the NRC provide a prompt review and approval of this preoperational test deferral request so that priorities and' schedules may be implemented to assure that our license will be issued prior to Construction Permit:CPPR-100 expiration and fuel load will be allowed to commence in September, 1983.

If there are any questions in this matter, please contact me.

Enclosed for your use are one (1) signed original and forty (40) copies of this letter and the attachment.

Very truly yours, Cordell Reed

.OWh Vice-President CWS/lm cc:

.A.

Bournia (Fed. Express)

J.~G.

Keppler - RIII.

NRC Resident Inspector - LSCS l

'6998N-

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  • Requested Prs,op2 rational Test Program Excsptions s;

U TEST TEST SECTIONS JUSTIFICATION COMPLETION REQUIRED PRIOR TO PT-CH-201 ALL' No equipment in this test is ini tial Cri ticali ty Containment required operable during cold Monitoring shutdown or refueling operations.

a PT-CM-202 ALL No equipment.in this test is initial Criticality.

I Post LOCA required operable during cold Containment shutdown or refueling operations.

l Honitoring PT-IN201 ALL No equipment operated.by drywell Initial Criticality Drywell pneumatics is requi red' operable i

l Pneumatics during cold shutdown or refueling ope ra't i.ons.

PT-LD201 ALL

' No leak.,ga ddtection equipment initial Criticality Leakage

. is r. equi red operable during Detection

, cold shutdown or refueling operations.

PT-MS201A ALL.

The MSIV Leakage Control System ini tial Criticali ty MSIV Leakage

'is not requi red operable during Control System cold shutdopn or refueling 0

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operations.

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ALL

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No equipment in this te'st is initial Criticality

') ; 9 PT-MS201B

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MSIV's and MS l,

79.5 re, quired operable durin9 cold.

instru. mentation shutdown or refueling operations.

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PT-MS201C.

ALL No'equipnyentyin this system is initial Heatup, prior to exceeding s

ADS and MS requi red to beioperable' Until 122-psig.

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safety /RelleN-r the reactor is critical"and f

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above 122 psig.

Per FSAR 4. l i,'

Chapter 14, this test is.to be

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4 finished dyring heatup in the

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,startup test progr,am.

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i TEST TEST SECTIONS JUSTlFICATION PROPOSED COMPLETION-PT-NR202 ALL No equipment-in this system is ini tial Cri ticali ty.

Traversing requi red during-cold shutdown incore~ Probe or refueling operations.

'1 No equipment in this system is ini tial Cri ticali ty PT-0G201 ALL Off-Gas required during cold shutdown or refueling operations.

j PT-PC201 ALL

. Primary Containment Integrity ini tial Cri ticali ty Primary is not required.during cold.

fi Containment

. shutdown or refueling operations.

Integrity

't PT-PC203 Everything except 0aly' secondary containment initial Criticality Containment Secondary Containnisnt integrity is required during isolation isolations refueling ' operations.

P rima r.y 0

. Systems

?N containment cannot be maintained s

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while fueling.

PT-RIN01 ALL No equipm'nt in this s stem ~is initial Criticality e

Reactor Core

required du' ring cold shutdown isolation or refueling operations.

Cooling PT-RP202 ALL The remote shutdown system is ini tial Cri tica11 ty Remote not required during cold Shutdown shutdown.or refueling operations.

PT-RR201 ALL The reactor recirculation and initial Cri ticali ty.

Reactor flow control system is not Recirculation required operable during cold shutdown or refueling operations.

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-TEST.

. TEST SECTIONS JUSTIFICATION PROPOSED COMPLETION

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j PT-Sl202

.ALL The probability of a severe transient initial Heat-up j'

Pipe Vibration 0

(e.g., seismic, LOCA) occurring during Monitoring the. preoperational test. program that 1

could damage system piping or com-ponents.if the dynamic restraints are i

i not-installed is acceptably low; and l

the testing will be completed prior

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to power operation which would l

generate decay heat'and fission l

product. Inventory. Therefore, the i

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use of these systems will not be required to protect the health I

and safety of the public prior to the tests.

l PT-VP202 Portions involving The hyd'rogen recombiner are initial Criticality Post LOCA Unit 2 (Both recom-not (equired to support Unit 2 during Hydrogen biners have been cold : shutdown 'and refueling operations.

Recombiners demonstrated with the Unit I containment PT-VP203 ALL

' Containment ventilat'lon is not initial Heat-up Containment

. required to maintain temperatures Ventilation

.until after reactor.heatup has occur.ed a,nd the reactor,Is adding heat to thq containment.

SD-PS201 All portions other No requirements exist to maintain initial Criticality Process than those necessary water quality other than.for-the Sampiing to monitor reactor reactor water, water quality SD-SA201 ALL This system is non-safety related.

Initial Criticality Service and Although it supplies some safety-Instrument Air related components, they are designed to fall in the conservative direction upon loss of air.

This system has,been in operation for

.a year, and has been a reliable ai r source.

SD-51201 ALL For-the same reasons as applied to initial Heat-up i

PT-Sl 202 (above).

..---a-A