ML20086A784
| ML20086A784 | |
| Person / Time | |
|---|---|
| Site: | LaSalle |
| Issue date: | 11/14/1983 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 7605N, NUDOCS 8311160109 | |
| Download: ML20086A784 (5) | |
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N Commonwealth Edison
(\\
) ons First National Ptrza. Chicago. Illinois C
C ' Addrtss Riply to: Post Office Box 767 Chicago. Illinois 60690 November 14, 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 Updated Status of Completion of LSCS Unit 2 Preoperational Test Program (Deferral Request)
NRC Docket No. 50-374 References (a):
(b):
LSCS Unit 1 Technical Specifications, License NPF-ll.
(c):
Cordell Reed letter to H. R. Denton dated July 21, 1983.
(d):
C.
W.
Schroeder letter to H. R. Denton dated October 6, 1983.
(e):
C. W. Schroeder letter to A. Schwencer dated October 5, 1983.
(f):
C W. Schroeder letter to H. R. Denton.
dated November 1, 1983.
Dear Mr. Denton:
7 Referenca (a) describes the LSCS precoerational and startup test p rograra.
Coma.onvcalth Edison Company's original intentions were to complete the entire preoperational test prontam prior to tuel load.
However, as explained in Reference (c), it has become apoarent that certain portions of a relatively small number of preoperational-tests and system demonstrations have become the controlling items for fuel load.
The delays in completing these tests are due to a variety of design,-
delivery, and installation problems.
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-subsystems involved have been determined to have no impact on plant safety during shutdown and fuel loading conditions.
This determination is based on the Unit 1 Technical Specifications (Reference (b)), and, where the Technical ~ Specifications have no: specific requirements, prudent judgment.
The Unit l' Technical Specifications were used because of the fluid state of the proposed -Unit 2. Specifications; however, no Jdif ferences.between l
the two are expected to affect _the justifications provided.
8311160109 831114
. g PDR ADOCK 05000374 A
PDR 7 l j
e H. R. Denton November 14, 1983 References (c), (d), and (f) provided Commonwealth Edison's request for approval to defer the completion of certain 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.
As explained in Reference (c), it should be noted that in a majority of cases it is anticipated that the physical testing will be completed prior to fuel load.
The delay in the date required for test completion of remaining tests will allow additional time to ensure a thorough evaluation and review of the test results.
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.
The purpose of this letter is to provide you with another update of the status of the systems listed in Reference (c).
The attachment to this letter indicates the current status of the preoperational tests for which deferral was requested and further substantiates our expectations that it is anticipated tnat, in a majority of cases, the physical testing will up completed prior to fuel load.
Please note that the status of preoperational test deficiencies was eadressed in Reference (e) and continues to be handled as described therein.
Reference (e) is also enclosed as an attachment for your information.
If there are any questions in this matter, please contact this office.
Very truly yours, lYf83 Il j C.
W.
Schroeder Nuclear Licensing Administrator CWS/Im cc:
J. G. Keppler - RIII NRC Resident Inspector - LSCS 760SN
p Rrquested Prsop; rational Test Program Exceptions E
ST47ks 88/se/83 TEST TEST SECTIONS JUSTIFICATION COMPLETION REQUIRED PRIOR TO s
PT-CH-201 ALL No equipment in this test is initial Criticality 90 7, bre.o rs Containment t
required operable during cold Honitoring shutdown or refueling operations.
PT-CH-202 ALL No equipment in this test is initial Criticali ty.
140 % Cowirou ra required operable during cold Past LOCA shutdown or refueling operations.
Contsinment Honitcring PT-IN201 ALL No equipment operated by drywell Initial Criticality 1007, 4 ftK78 Drywell pneumatics is required operable gg yntiwyseev sesvesw l
Pn;umatics during cold shutdown or refueling norv e ope ra t i,on s.
PT-LD201 ALL
'No leakage de'tection equipment Initial Criticality 100 1 b et,,eTe
.is r. quired operable during e
Lm ktge Detsction cold shutdevn or refueling D***
operations.
PT-MS201A ALL
,The HSIV Leakage Control System Initial Criticality g g g c,g,g,,7g HSIV Leakage
~1s not required operable during
'Contral System cold shutd gn or refueling operations.
PT-MS201B ALL ilo equipn.ent in this te'st is initial Cri ticality g y.1 w a yg MSIV's and MS required operable during cold Instrumentation shutdown or refueling operations.
PT-MS201C ALL No equipment in this system is initial Heatup, prior to exceeding required to be operable until 122 psig.
.y o g, e,,,, p g 7,
ADS cnd MS Sefcty/ Relief the reactor is critical and above 122 psig, Per FSAR Cliapter 14, this test is to be finished dyring heatup in the startup test program.
i S1rw ms PROPOSED COMPLET10N
.t /14 / ib'5 TEST TEST SECTIONS JUSTIFiCAT10N PT-NR202 ALL lo equ8pment in this system is Ini tial Cri ticall ty C $ Cem et.e vs Travarsing required during cold shutdown or retucling operations.
incora Probe PT-0G201 ALL.
No equipment in this system is initial Criticall ty 75'I, b eta re required during cold shutdown Of f-G::s or refualing operations.
PT-PC201 ALL Primary Containment Integrity Initial Criticali ty l O D T, Cers eb is'not required during cold g
g ggy Primary shutdown or refueling operations.
Contsinment Integrity PT-PC203 Everything except only' secondary containment initial Criticality 100 f, Cm e t.c a Containment Secondary Containment
' integri ty is required during
.ggg7 ggig Isciction isolations refueling operations. Prima ry g
g containment connot be maintained g g,y g,g,yg Systems while fueling.
100 f, Cam ps.e TE l
inthisshste' mis-Initial Criticality PT-R1201 ALL No eq'ulpment SV42 t4 4-r80ev 4EviEW l
required du' ring cold shutdown Resctor Core or refueling operations.
DowE Issiction Cooling The remote shutdown system is initIa1 Criticality l DO $ GrWLETE PT-RP202 ALL not regulved during cold g v o g,u grew R evie w Remote
- shutdown or refueling operations.
pone Shutdown
.PT-RR201 ALL The reactor recirculation and Ini tIal Cri tIcali ty>
$01 % m TE flow control system is not Reactor.
required operable during cold R; circulation shutdown or refueling operations.
S74 p S.
TEST TEST SECTIONS JUSTIFICATION PROPOSED COMPLETl0N L1/ Ut / C3
[
PT-Sl202 ALL The probability of a severe transient initial Heat-up MO % 4mrs' Pipe Vibration (e.g., seismic, LOCA) occurring during t
Honitoring the preoperational test program that EVht"*T'"
could dama*:e system piping or com.
({EviEtv Dorvs ponente if the dynamic restraints are not installed le. acceptably low; and the testing will be completed prior to power operation which would generate der.ay heat and fission product inventory.
Therefore, the use of these systems will not be required to protect the health and safety of the public prior to the tests.
PT-VP202 Portions involving The hydrogen recombiner are Initial Criticality O Io Can#4tTE Past LOCA
' Unit 2 IBoth recom-not required to support Unit; 2 during Hydrogen biners have been col'd: shutdown'and refueling operations.
R:icombiners demonstr.cted with the Unit ] containment PT-VP203.
ALL
' Containment ventilat'lon is not Initial Heat-up 371 4 pt.ETE ContcInment
. required to maintain temperatures V;ntilation until after reactor heatup has occur.ed and the reactor,is adding heat to thq containment.
SD-PS201 All portions other No requirements exist to maintain initial Criticality l 0 0 g M sW Procsss than those necessary water quality other than for the
'rE$r GE7 NN Sampiing to monitor reactor reactor water.
t;Evn u m Ei'Y water quality ar 4 8 4 ** 8 **'v A SD-SA201 ALL This system is non-safety related.
Initial Criticality l00 % @ pexTE S3rvice and Although 1: supplies some safety-Instrument Air related components, they are designed to fall in the conservative Pf EV 8 EL8 D O NEF di rection upon loss of ai r.
This system has been in operation for a year, and has been a reliable air source.
SD-Si201 ALL For the same reasons as applied to initial Heat.-up
' fa 'f T. (smFL.mTE PT-Si202 (above).
Commonwealth Edison LaSalb Ccunty Nuctur Station Rural Routa #1, Box 220 M;rs;illss,I!!inois 61341 Telephone 815/357-6761 October 5,1983 Mr. A. Schwencer, Chief Licensing Branch #2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
LaSalle County Station, Unit 2 Deferral of LSCS Preoperational Test Deficiencies Beyond Fuel Load NRC Docket No. 50-374
REFERENCES:
1 C. W. Schroeder letter to A. Schwencer dated April 1, 1982 2.
R. L. Tedesco letter to L. O. DelGeorge dated April 14,1982.
3.
C. Reed letter to H. R. Denton dated July 21, 1983.
Dear Mr. Schwencer:
The technical adequacy o' the pre-operational testing program at LaSalle Unit 2 hes been evaluated and approved by Ceco. The prograns is mere than 87% comolete. This letter identifies outstanding discrepancies' from test cormitrents and provides Justification for nese!ving them after fuci Ioad.
,u it has been requested that CECO submit a list of pre-operational test daficiencies, that may not be completed prior to fuel load, for revicw by the office of HRR.
The subject list of deficiencies is attached alorg with the time frame for completion.
The list does not include pre-operational testing for, wnich deferral beyond fuel lead has al tuady been requested by Reference 3.
Justification fo-Jefer-al of each of.these items is that it does not degrade the capability of a system required by Technical Specifications to handle an accident. They have been scheduled for completion on the basis of Tech. Spec. requirements.
Each item will be evaluated by the Project Engineering Group to en-sure that none impacts the safe and reliable operation of the plant. Project Engineering will evaluate and approve the resolution of significant items on the attached list. Station proce'dures are adequate to resolve the other items.
Records of the retests and approvals will be available onsite for review.
.,4
l 1
A. Schwencer
,2 -
Octobe r. 5, 1983 1
The attached list of deficiencies is based on the September 22, 1983, Deficiency Status Report.
It is suggested that. deficiencies identified subse-quent to September 22, 1983, will be scheduled for completion by Ceco on the 4
basis of Tech. Spec. requi rements.
l This approach parallels the method utilized for LaSalle County Unit 1 and approved by Reference 2.
This approach was discussed by the LSCS Senior Resident inspector with representatives of NRC Region li t and the Office of Nuclear Reactor Regulations on October 5,1983, and deemed to be conceptually i
acceptable.
If there are any further questions in this matter, please contact this of fice.
Ve ry t ru l y you rs,
't Cid
,.Isies O
C. W. Schroeder 4
Nuclear Licensing, Administrator RDB/rg Attachnen t cc:
B. Shelton R. Bishop Region t il Inspector - LSCS 3775N J
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4 ATTACHMENT DEFICIENCIES REPRESENTING INCOMPLETE TESTING (BASED ON SEPTEMBER 22, 1983 DEFICIENCY LISTING)
TEST NO.
DEF. NO.
DESCRIPTION
- COMPLETION PT-AP201 551 Annunciator not received when switchyard J
relay house feed breaker tripped N/A PT-AP202 158 verify load requi rements for 250 ' VDC battery S/U PT-DG2018 28 Both local fuel pump failure lights energize when either pump has low discharge pressure N/A PT-FC201 43 Check for turbulence at fuel pool diffusers N/A 52 Leak check reactor cavity and dryer / separator pit liner S/U 53 Leak test transfer canal S/U PT-FR201 42 One' (of two) fuel prep machines not tested 1st R/F PT-NB201 101 High pressure excess flow check valves did -
N/A not automatically reopen 102 Low pressure excess flow check valve S/U indicating lights 147 Reactor pressure instrument not checked S/U 154 Vessel temperature element reads improperly Heatup 155 Vessel temocrature element reads improperly Heatup PT-PR2019 97 Off Gas pretreatment panel needs h!/ low flow setpo'nts S/U 110 Main steam line rad monitor channel D not calibrated S/U 137 Cable resistance too low (OG pra. treatment)
N/A 138 Cable resistance too low (OG pretreatment)
N/A 194 Source check not complete (OG post treatment)
S/U 196 Pream'plifier not working (OG post treatment)
S/U 211 Aux steam rad monitor needs source check S/U PT-RH201 249 Check redundant Indicating lights for, Heat Exchanger vent ' valves S/U e
(_
l TEST NO.
DE F._ NO.
DESCRIPTION
_ COMPLETION PT-Rl201 134 Inbd testable check valve not tested S/U 196 Outbd testable check valve not tested S/U PT-RP201 14 TCV fast closure scram not tested S/U 71 RPS response times not verified S/U PT-Sl202 4
3/4 inch LPCS line: excessive ' ibration S/U v
8 HPCS min' flow line: excessive vibration S/U 9
HPCS min flow line: excessive vibration S/U 13 1-1/2 inch SBLC line; excessive vibration S/U PT-VP201 51 Test VQ train af ter chaNoal and filter installation S/U PT-VR201 9
System balancing and airflows not verified S/U 19'S Station heat recovery coil bypass valve control circuit N/A
~
PT-VX201 301 Fan / Damper interlock check for heat recovery fan N/A SD-CQ201 17 4 PA handsets, 6 speakers not checked (Service Building)
N/A 29 Drywell PA and S.P. phones not tested S/U SD-CX201 135 Computer input from rect re flow Unit D not checked S/')
138 Computer inputs from EHC not checked S/U 139 Computer inputs f rom Turbine. Supervisory Instrumentstion not checked S/U 141 Computer inputs from RCIC net cher.ked S/U 147 Computer inputs from TORFP's not checked Turbine Roll 149 Computer input from D/W Gross Gama monitor not checked S/U SD-FC201 62 Pressure instrument reads improperly 1st R/F.
99 Conductivity Indication'has wrong scale.
N/A 100 Conductivity Indl. cation has wrong scale' N/A 101 Conductivity indication has wrong scale N/A 104 F/D precoat logic dIdn't reduce flow after-
.N/A application
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TEST __NO.
DEF. NO.
_ DESCRIPTION COMPLETION SD-PS201 2
Conductivity monitor not tested (Condensate Polishers)
S/U 42 Conductivity recorder not checked (Condensate header)
S/U 103 Conductivity Recorder not tested (Condensate Polishers)
S/U S0-55201 175 Radiation door not tested S/U 191 Radiation door card reader not tested S/U 208 Radiation door not tested S/U 209 Radiation door not tested S/U 210 8 doors not tested (Secondary containment boundary)
S/U 214 Radiation door not tested (Secondary Containment)
S/U a
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