ML20113G394
| ML20113G394 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 01/09/1985 |
| From: | Tramm T COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 9601N, NUDOCS 8501240339 | |
| Download: ML20113G394 (18) | |
Text
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,m Commonwealth Edison
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) One FCt National Pt'n Chicago Illinois
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C Address Reply to: Post Othee Box 767
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Chicago. Illinois 60690 January 9, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron Generating Station Units 1 and 2 Braidwood Generating Station Units 1 and 2 Startup Test Program NRC Docket Nos. 50-454, 50-455, 50-456, and 50-457
Dear Mr. Denton:
This letter provides an advance copy of FSAR revisions relating to the startup test program described in the Byron /Braidwood FSAR.
These changes appear to require NRC review before implementa-tion as described in License Condition C.2(3)(c) of the Byron Operating License, NPF-23.
If such approval is necessary, immediate consideration is requested.
Enclosed is a revised response to FSAR question 423.25, correspondingly revised FSAR sections 14.2.5 and 14.2.11, and a new FSAR table 14.2-91.
These changes establish deadlines, in terms of power level, for review and approval of specific startup tests.
This will permit reactor testing to proceed to higher power levels while certain test results are reviewed.
The overall startup sequence is thereby shortened and some schedule pressure is removed from the test review process.
The test review deadlines were established on the basis of information provided in Attachment A to this letter which is propri-etary to Westinghouse.
It is requested that Attachment A be withheld from public disclosure in accordance with 10 CFR Sec/tinghouse tion 2.790 of the Commission's regulations.
An affidavit from We supporting this request is being prepared and will be submitted within a few days.
Correspondence with respect to the proprietary aspects of this matter should reference CAW-84-lll and should be i
directed to R. A. Wieseman, Westinghouse Electric Corporation, P.O.
Box 355, Pittsburgh, PA, 15230.
A non-proprietary version of Attachment A is provided in Attachment B.
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H..R. Denton January 9, 1985 Please direct further questions regarding this matter to this office.
One signed original and fifteen copies of this letter, the enclosures, and Attachment B are provided for NRC review.
Five copies.of.the proprietary Attachment A are also provided.
Very truly yours, S /2. S + m T. R. Tramm Nuclear Licensing Administrator 1m cc:
Byron Resident Inspector (w/ proprietary Attachment A)
Attachments 9601N e
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B/B-FSAR
. _.E ND.".EN"' 3 0 C
JANrPRY 1992 QUESTION 423.25 "The information contained in Subsections 14.2.5. and 14.2.11 is inconsistent.
Revise the subsections as follows:
1.
State that all preoperational tests will be completed, evaluated, and approved prior to core load.
2.
State that all startup test data obtained at each power test plateau will be evaluated and approved before increasing power level."
RESPONSE
1.
All preoperational tests will be completed, evaluated, and approved prior to core load.
Subsections 14.2.5 and 14.2.11 have'been revised to include these commitments.
2.
All startup test data obtained at each power test plateau will be evaluated and approved before increasing power 1*V*l d...?ff d ;r 17 2 5 F'd 1i 2 il have """"
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B/B-FSAR AMENDMEtFF 45 inuw inna prerequisites have been completed.
Test personnel will be
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instructed-to initial and date the prerequisites included in L
each. test ~ procedure.
Data will be examined as each test proceeds and out-of-tolerance conditions will be recorded and described in adequate detail to permit post-test analysis.
' Test data that is unsuccessful will be recorded, evaluated during post-test review, and resolved within the Quality Assurance program..
14;2.5 Review, Evaluation, and Approval of Test Results Initial preoperational and startup tests that fall within the scope of the Quality-Assurance program will be subject to two stages of evaluation.
First, a detailed and comprehensive review by station startup personnel will be made.
The Project Engineering Department project personnel will perform a second jh and final review and evaluation.
Modifications or rework of systems or equipment required to resolve deficiencies will be accomplished in accordance with controlled procedures.
Retest-ing, if required because of modification or rework,-will be documented and filed with the initial test record.
The initial core loading procedure will specify the startup-tests that must be completed prior to commencement of fuel load.
All testing identified as falling within the pre-operational test phase will be completed and the results evaluated prior to core load.
Modification and rework on systems that is required to resolve' test-deficiencies is controlled by the Test Review Board during post test review and by Project Engineering who has responsibility for final test acceptance and approval.
additional test requirements to resolve test deficiencies prior toProject Eng final test approval.-
The power ascension procedure will specify-those startup tests or portions of startup tests that must be completed as a pre-requisite.for commencing each phase.
The data obtained at
. increasing power level, wen. 'exeptee seach power test plateau will b as meted. e-TaHe 14.f.-91, 14.2.6 Test Records The initial startup test procedures and test data will be retained'and maintained in accordance with the Quality Assurance program described in Chapter 17.0.
The original test records willLbe reviewed for completeness, identified, and indexed to establish them as part of a permanent record to be retained.
These records willoinclude data sheets completed..during the-
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114.2.7 b
Conformance of Test' Program-with Regulatory Guides k_3
. Appendix A'to the FSAR' identifies those Regulatory Guides applicable to Byron /Braidwood and describes'the anticipated degree of conformance to each.
14.2-3 L _
B/B-FSAR Preoperational testing will proceed concurrently with
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construction testing as various systems reach completion and are turned over to the station startup staff.
during this phase are expected to be the reactor coolant systemThe principal mil hydrostatic test and the integrated hot functional test.
The f ormer test is expected to be accomplished approximately 10 months prior to f uel load.
begin about 3 months before fuel load. Hot functional testing is expected to
_' 3 Tests of other systems will be scheduled as appropriate to support these tests.
A schedule for testing is provided in Figure 14.2-1.
Individual preoperational tests will be conducted as early in the test program as practical and at no time will the safety of the plant be totally dependent on the performance of untested systems, components and features.
Core load will occur only after the satisfactory completion and approval of all preoperational tests.
Individual startup tests will be conducted after core load and test data obtained at each power test plateau will be evaluated and approved prior to increasing power load, wdd. excephs*,
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as Any initial test schedule overlap at the Byron and Braidwood Stations will not result in significant divisions of responsi-bility or dilutions in the staff provided to implement the test program.
C Preoperational test procedure drafts will be available for review by I&E inspectors at least 60 days prior to their intended use and not less than 60 days prior to the core loading date for startup test procedure drafts.
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14.2-10 l
'l TABLE 14.2 TEST.RESULTS REVIEW AND APPROVAL SCHEDULE DEFERRALS-Precritical, Post Coreload Test No.
Title Approval Before--
2.63.32 RCS Flow Coastdown
>75% Power Low Power (15%-Power)
Test No.
Title Approval Before-2.64.33 Baron Endpoint
> 50% Power 2.47.30-Isothermal Temp. Coeff.
750% Power 2.45.31 Incore Flux Map 750% Power-2.64.30A RCCA Bank-Worth 7 50% Power 2.64.30B Bank Worth Overlap
> 50% Power
.2:.45.33 RCCA Psuedo Rod Ejection
>75% Power 30% Power Test No.
Title Approval Before-2.52.37 Load Swing
> 75% Power 2.45.33 RCCA Psuedo Rod Ejection
> 75% Power
.2.47.31 Power Coefficient 750% Power 50%-Power Test No.
Title Approval Before-2.64.36 RCCA Psuedo Rod Ejection 790%' Power 2.45.32A Flux Map 775% Power
'2.45.328 Flux Map
> 75% Power
~2.45.32C Flux Map
>75% Power
~2.63.31 RCS Flow Measurement 775% Power
- 2.52.30 Plant Trip
> 90% Power 2.47.31 Power Coefficient
>75% Power e
4 75% Power-
. Test No.
Title Approval Before-2.47.31 Power ~ Coefficient
> 90% Power 2.52.~37 Load Swing
> 90% Power 2.64.39 Large Load Reduction 7 90% Power r
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E ATTACHMENT B Basis for Test Review Deadlines Non-Proprietary Version 960lN
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PROPRIETARY INFORMATION NOTICE TRANSMITTED HEREWITH ARE PROPRIETARY AND/OR NON-PROPRIE g
DOC 11MENTS FURNISHED 10 THE NRC IN CONNECTION WITH R PLANT SPECIFIC REVkEW AND APPROVAL.
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~ IN ORDER 10 CONFORM 70 7HE RDQUIREMENTS OF 10CFR2.790 0F REGULATIONS CONCERNING THE PROTECTION OF PROPRIETARY I TO THE NRC, 7HE INFORMATION WHICH IS PROPRIETARY IN INE PROPRIETARY 4
CONTAINED WITHIN BRACKETS AND WHERE THE PROPRIETARY INFOR DELETED IN 7HE NON-PROPRIETARY VERSIONS CELY THE BRACKETS REMAIN, THE INFORMATION THAT WAS CONTAINED WITHIN 1HE BRACKETS IN HAVING BEEN DELETED.
THE JUSTIFICATION FOR CI. AIMING THE INFORMATION SO DESENATED AS PROPRIETARY IS INDICATED IN BODI VERSIONS LET.T.RS ~(a) THROUGH (g) CONTAINED WITHIN PARENTHESES LOCATED AS A S IMMEDIATEI.Y FDLLOWING THE BRACKETS ENCI.0 SING EACH ITEM IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH INF THESE LCWER CASE LEITERS REFER 1D THE TYPES OF INFORMATION HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a) through (4)(ii)(g) 0F TH AETIDAVIT ACCOMPANYING TH S TRANSMITTAL PURSUANT 7010CFR I
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WESTINGHOUSE PROPRIETARY CLASS 3 Phase 3 - Post Critical Testing Concerning the time frame for evaluating specific test results. Westinghouse has emphasized those' post critical tests which were related to safety / technical specifications parameters, in contrast to tests related to control system optimization and " historical tests".
This was done in the interest of getting nuclear power plants on line in a reasonable and timely fashion.
To this end, a table relating tests, power level of testing, and recomended power level threshold for evaluation has been supplied to our Customers.
Table 11-1 of our startup sequence document is attached.
The rationale for the recomendations made in Table II-1 derive from the fundamental parameters affecting NSSS core performance:
- 1) power distribution parameters F, FAH, quadrant power tilt g
2) primary heat removal parameters, flow, T,yg, AT,,,,,3
- 3) reactivity parameters, control bank worth, ap/4T, ap/3Cg
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WESTINGHOUSE PROPRIETARY CLASS 3 and the following transient characteristics:
- 1) reactor coolant pump trip / flow coastdown
- 2) normal load transients
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- 3) large load transients / plant trips The hot zero power tests yield the basic core neutronic performarce results.
In order to verify core neutronic performance, the basic measurements are an
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all rods out flux map, the reactivity worth of the first control bank, and the all rods out plus control bank in-moderator temperature coefficient.
These measurements are evaluated promptly to confirm compliance with applicable technical specifications and extrapolate to the next power plateau for testing.
From these tests it is confirmed that the power distribution parameters are within the design constraints for the plant.
Subsequent power distribution measurements reveal the effect of doppler and xenon on power distribution.
The hot zero power tests also yield the moderator temperature coefficient data which is' used to determine the control bank withdrawal in order to comply with the technical specification on moderator temperature coefficient.
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WESTINGHOUSE PROPRIETARY CLASS 3 9
s Measurements related to pseudo rod ejection have been shown over th'e years to yield data,of no significance when compared with design margins.
They have been kept in the test program simply because Regulatory Guide 1.68 calls for them.
Recently, twin unit stations have succeeded in deleting these tests for-Unit 2 with NRC concurrance.
Based on results from puny plants we feel the tests can be evaluated in the time frame shown on Table II-1.
To further amplify on t.he power ascension program, we are attaching Table 3.8 of our WCAP-7905, Revision 1.
This WCAP has not been submitted for NRC review and approval and the Table is submitted for information only.
This Table delineates the Westinghouse " Minimum Test Requirements For Power Escalation".
It is based on considerations described above regarding the significance of s
test results to plant safety.
One further consideration.
Westinghouse supplies an engineer during pujor testing plateaus to render technical assistance to the Customer as the tests are executed and evaluated. This engineer has resources at the Monroeville Nuclear Center for resolv'ing any problems and in many cases doing parallel data analyses.
Any anamolous test results are identified and resolved on a timely basis, following the Physics Test Acceptance criteria document.
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Test Rosette twelestion* Schedule Receptione 1..
Test Description
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3 1.3 5.3.3 ht ' 5hetdown Before Inittet Reacter Coolest System Flow Critteelity Coastdown 3.1.3 5.3.10 Wet Shetdown i
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5.15 g,,,,,,,
l RCCA Pseudo Ejection (REP Ceee) 5.1.4 5,16 Low Power 1
IM i O RCCA Poemde tjection (WFP Cese) 3.1.5 5.18 302 Load Swist i.
3.1.5 5.19 302 l
Power Coefficient 4
3.1.5 5.21 30%
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RCCA Peeedo Os 5
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502 x
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3.1.6 5.8.5 502 E
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3.1.6 5.12 502
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II. PRf0R TO POWER ESm ATION ABOVE 101
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IV. FRf0R TO PO WR ESCALATION AB0VE 752
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