ML20113E408
| ML20113E408 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/10/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| CON-#285-590 OL, NUDOCS 8504160280 | |
| Download: ML20113E408 (9) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET,
P.Ct. BOX 8699 PHILADELPHI A. PA.191o1 SHIELDS L. DALTROFF n5%U'M5Eo=
April 10, 1985 Docket No. 50-352 Mr. A. Schwencer, Chief Licensing Branch 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Schwencer:
The purpose of this letter is to request NRC approval of a change to the power ascension program at our Limerick Generating Station in accordance with License Condition No. 9(a) and (e) to Facility Operating License NPF-27, " Limerick Generating Station Unit 1", which states:
(9)
Post-Fuel Loading Initial Test Program (Section 14, SER)
The licensee shall conduct the poct-fuel loading initial test program described in Chapter 14 of the Final Safety Analysis Report, without making any major modification unless such modifications have prior NRC approval.
Major modifications are defined ass (a)
Elimination of any safety-related test.
(e)
Deviation from initial test program administrative procedures or quality assurance controls described in the FSAR.
We request approval to eliminate STP-37.
A copy of the appropriate section of Chapter 14 of the FSAR with proposed changes indicated is attached.
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ADOCK 05000352 PDR
y Mr. A. Schwencer April 10, 1985 Page 2 STP Main Steam System and Turbine Performance and Plant Dynamic Response Verification Test Objectives - The test objectives are to demonstrate (1) the satisfactory performance of the main steam system and the main turbine; and (2) that the dynamic response of the plant to the design load swings, including step and ramp changes, is in accordance with design.
An evaluation has been performed and it has been concluded that deletion of this test has no impact because the test requirements are being met by the performance of other startup tests.
Specifically, the test objectives of STP-37 are i
fulfilled by the performance of STP's 14, 15, 20, 22, 23, 27, 29 and 30.
STP-37 was added to the startup test program in response to question 640.10 regarding compliance with Regulatory Guide 1.68.
A re-analysis of the specific requirements of R.G.
1.68, App. A, Sec.
4.k, 5.v, and 5.hh, has been performed and it has been determined that these requirements are met by various other STP's and that there would be no benefit gained in the performance of STP-37.
The appropriate sections of Regulatory Guide 1.68, App. A, are restated below followed by the test i
abstracts for those STP's which demonstrate the requirements.
I Regulatory Guide Requirement 4.k. Demonstration of the operability of steam-driven engineered safety features and steam-driven plant auxiliaries and power conversion equipment.
Response
i The requirements of section 4.k are met by the performance of STP's -14, -15, -20 and -23.
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Mr. A. Schwencer April 10, 1985 Page 3 (STP-14) Reactor Core Isolation Cooling (RCIC)
System Performance Verification Test Objective - The test objective is to demonstrate operation of the RCIC system over its required operating pressure range.
(STP-15) High Pressure Coolant Injection (HPCI)
System Performance Verification Test Objective - The test objective is to demonstrate proper operation of the HPCI system over its required operating pressure range.
(STP-20) Steam Production Test Objective - The objective of this test is to demonstrate that the NSSS is providing steam sufficient to satisfy all appropriate warranties.
(STP-23) Feedwater Control System f
Test Objectives - The test objectives are:
to evaluate and adjust feedwater controls; to demonstrate the capability of the automatic flow runback feature to prevent a low water level scram, following the trip of one feedwater pump; to demonstrate acceptable performance of feedwater pumps and turbine drivers within specifications; to demonstrate adequate response to feedwater heater loss (inlet subcooling change); and to demonstrate acceptable reactor water level control.
Regulatory Guide Requirement Sv.
Verify that the main steam system and feedwater systems operate in accordance with design performance requirements.
Mr. A. Schwencer April 10, 1985 Page 4
Response
The requirementa of section Sv. are met by the performance of STP's 20 and 23.
(STP-20) Steam Production Test Objective - The objective of this test is to demonstrate that the NSSS is providing steam sufficient to satisfy all appropriate warranties.
(STP-23) Feedwater Control System Demonstration Test Objectives - The tect objectives are:
evaluate and adjust feedwater controls; to demonstrate the capability of the automatic flow runback feature to prevent a low water level scram, following the trip of one feedwater pump; to demonstrate acceptable performance of feedwater pumps and turbine drivers within specifications; to demonstrate adequate response to feedwater heater loss (inlet subcooling change); and to demonstrate acceptable reactor water level control.
Regulatory Guide Requirement 5.hh.
Demonstrate that the dynamic response of the plant to the design load swings for the facility, including step and ramp changes, is in accordance with design.
Response
The requirements of section 5.hh are met by the performance of STP's 22, 23, 27, 29 and 30.
Mr. A. Schwencer April 10, 1985 Page 5 (STP-22) Pressure Regulator Response Test Objectives - The-test objectives are:
to demonstrate the reactor pressure control system responses to pressure regulator setpoint changes, the stability of the reactivity-void feedback loop to pressure perturbation, the control characteristics of the bypass and control valves, and the takeover capabilities of the backup pressure regulator; and to optimize the pressure regulator settings to give the best combination of fast response and small overshoot.
(STP-23) Feedwater Control System Demonstration Test Objectives - The test objectives are:
to evaluate and adjust feedwater controls;.to demonstrate the capability of the automatic flow runback feature to prevent a low water level scram, following,the trip of one feedwater pump; to demonstrate acceptable performance of feedwater pumps and turbine drivers within specifications; to demonstrate adequate response to feedwater heater loss (inlet subcooling change); and to demonstrate acceptable reactor water level control.
(STP-27) Turbine Trip and Generator Load Rejection Demonstration Test Objectives - The test objectives are:
to determine the response of the reactor system to a turbine trip; and to evaluate the response of the bypass, safety / relief valve, and the reactor protection systems.
(STP-29) Recirculation Flow Control Demonstration Test Objective - The test objective is to determine the plant response to a change in recirculation flow, to optimize the setting of the master flow controller, and to demonstrate the plant loading capability in master manual flow control mode.
Mr. A. Schwencer April 10, 1985 Page 6 (STP-30 ) Recirculation System Test Objectives - The test objectives are:
to determine transient responses and steady-state conditions following recirculation pump trips at selected power levels; to obtain jet pump performance data; and to demonstrate that no recirculation system cavitation occurs in the operation region of the power flow map.
Philadelphia Electric Company hereby requests permission to change the Post-Fuel Loading Initial Test Program as defined in Chapter 14 of the Limerick FSAR by deletion of STP-37.
Deletion of this test does not reduce the overall effectiveness of the startup test programs as the objectives of this deleted test are adequately demonstrated elsewhere.
A prompt response to this request will be appreciated so that the impact on the power ascension program is minimized.
Very truly yours, 47^-['-
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Attachment cc:
J. T. Wiggins, Resident Site Inspector See Service List i
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TABLE 14.2-2 (Cont'd)
(Page 3 of 3)
TEST NUMBER TEST TITLE STP-35 Recirculation Flow Calibration (Formerly SUT-30)
STP-36 Piping Dynamic Transient (Formerly SUT-36)
STP_37
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Plsr.t Dyna.T.ic Respe..sc '!crific tier.: (F ::: ly.
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STP-38 MSIV Leakage Control System Performance f
Verification (Formerly SUT-38)
STP-70 Reactor Water Cleanup System Performance Verification (Formerly SUT-31)
STP-71 Residual Heat Removal System Performance Verification (Formerly SUT-32) 1
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Rev. 28, 01/84
LGS FSAR TABLE 14.2-3 (Cont'd)
(Page 22 of 23) l 9
instrumentation is adjusted to function properly at rated conditions.
(STP-36) Pipino Dynamic Transient (Formerly SUT-36)
Test Obiectives
.The objective of this test is to verify the design adequacy of the piping systems for the transients indicated in Table 3.9-7.
Prerequisites - An engineering review of the piping system after construction is completed.
The required preoperational tests have been completed, and the Station Superintendent has reviewed and approved the test procedures and initiation of testing.
Instrumentation has been installed and calibrated.
Test Method - Response of the piping system (displacements or restraint loads) is measured during the transient event specified.
Acceptance Criteria - The measured response of the piping system and restraint loads shall be less than the acceptable response determined by analysis as specified in Section 3.9.2.1.b.1.
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(STP-37) Main Steam System and Turbine Performance and Plant Dynamic Response Verification (Formerly SUT-37)
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Rev. 38, 11/84
cc:
Judge Helen F. Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B. Conner, Jr., Esq.
Ann P. Hodgdon, Esq.
Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Phyllis Zitner Charles W. Elliott, Esq.
Zori G. Ferkin, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Martha W. Bush, Esq.
Spence W. Perry, Esq.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section. (3 Copies)
James Wiggins Timothy R. S. Campbell l
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January 16, 1985 1
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