ML20116A060

Provides Response to 920925 Request for Addl Info Re Unit 2 Initial Test Program,Per Reg Guide 1.108 & GL 84-15, Proposed Staff Actions to Improve & Maintain DG Reliability

ML20116A060
Person / Time
Site:	Comanche Peak
Issue date:	10/23/1992
From:	William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-1.108 GL-84-15, TXX-92513, NUDOCS 9210290173
Download: ML20116A060 (33)

Text

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O ss tog i TXX-92513

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' File i 10010 901.8

_ _ Ref. # 10CFR50.34(b) lllELECTRIC October 23, 1992

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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50 446 REQUEST FOR ADDITIONAL INFORMATION UNIT 2 INITIAL TEST PROGRAM REF: NRC letter dated September 25, 1992, from Mr. Brian Holian to Mr. William J. Cahill, Jr.

Gentlemen:

The following is provided in response to the Request for Additional Information transmitted by the referenced letter:

FRC Questions 1. 2 and 3:

1. (2.a and 2.e) FSAR Appendix 1A(B), " Discussion of Regulatory Guides,"

pages1A(D)-70and71,conformancetoRegulatoryGuides(RG)1.108,was modified to remove all " clarifications" statements to RG 1.108 except for one regarding Regulatory Position C.2.d. This clarification, concerning the reliability of both diesel generators for a condition _in which seven or inore failures in the last 100 valid tests occur, is unsatisfactory. -This clarification is in reality an exception to Regulatory Position C.3 (in addition to C.2.d) in that this regulatory position considers failures in the-last 100 valid tests on a per nuclear-unit basis, not an individual diesel generator unit basis as described in the " clarifications." It is the staff's position that the applicant should either delete this exception or modify Appendix 1A(B),

conformance to RG 1.10B to state how the concerns of Regulatory Position C.3. regarding examination of failures for the trend of critical failure mechanisms, human errors, and common mode failures, and assessment of the existing reliability of-electric power to engineered safety feature equipment, will be addressed.

2. (2.b) FSAR Appendix 1A(B), " Discussion of Regulatory Guides," page 1A(B)-70 -RG 1.108 (exceptions), was modified to indicate full compliance with RG 1.108, Regulatory Position C.2.a(3) for the Initial Test Program, but maintains the previous exception for tests performed SOOOA; 9210290173 921023 ,

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TXX-92513 Page 2 of 4 P

at the 18 month interval, it is the staff's position that the appliccnt should modify FSAR Section 1A(B) to indicate that 18 month interval periodic testing of the Emergency Diesel Generator units will demonstrate full-load-carrying capability at the continuous rating in accordance with Regulatory Position C.2.(3) or provide technical justification for any exception taken consistent with the technical specification surveillance requirements.

3. (2.c) FSAR Appendix 1A(B), " Discussion of Regulatory Guides," page 1A(B)-70, RG 1.108 (exceptions), was modified to indicate full compliance with RG 1.108. Regulatory Position C.2.a(5) for the Initial Test Program, but maintsins the previous exception for tests performed at the 18 month interval, i t is the staff's position that the applicant should modify FSAR Section 1A(B) to indicate that 18 month interval ,

periodic testing of the Emergency Diesel Generator units will demonstrate proper operation for design-accident-loading-sequence to design-load requirements in accordance with Regulatory Position C.2.a(5) or provide technical justification for any exception taken consistent with the technical tpecification surveillance requirements.

1Q Electric rejiponse to Questions 1. 2 and 3:

In preparation for CPSES Unit 1 licensing, a number of meetings were conducted with the NRC staff to finalize the UC ?. 1 Technical Specifications. The above exceptions and clarift:;tions to the FSAR Section1A(B)discussionoftheCPSEScompliancewithRegulatoryGuide 1.1W were specifically discussed and agreed to by the NRC during those meetings. The compliance with RG 1.108 Position C.2.d (NRC Question 1) was specifically revised to address an NRC concern in Generic Letter 84-15 [ Attachment 1) in Revision E to the Unit 1 Technical Specifications an interim revision prior to technical specification certification)((Attachment 2]. compliance with the RG 1.108 CPSES Positions C.2.a(3) and C.2.a(5) (NRC Questions 2 and 3) were submitted formally to the NRC in TU Electric letter TXX-89035, dated January 24, 1989 [ Attachment 3]. All CP5ES positions were approved by the NRC and were incorporated into the Unit 1 Technical Specifications -

(Attachment 4]. The FSAR was also amended to be consistent with the above changes in FSAR Amendment 78, which was accompanied by TXX-90011, dated January 15.-1990 [ Attachment 5), providing detailed descriptions / justifications of the changes.

Each recent-amendment has been accompanied by a " description" letter which provides details including references to meetings, letters, phone conversations, audits, inspections and other details which are not appropriate for inclusion into the FSAR. The description letter for Amendment 78 provides the required justification for the exceptions and clarifications to Regulatory Guide positions C.2.d. C.2.a.(3) and C.2.a(5).

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i TXX-92513 Page 3 of 4

NRC.0uestion 41  ;

(2.d) FSAR Appendix 1A(B), " Discussion of Regulatory Guides," page 1A(B)-71, RG 1.108, as modified is not in compliance with RG 1.108, Position C.2.a(9) for the Initial Test Program. The minimum start and load tests, specified in the FSAR, indicates that the applicant assumed '

a value of other than two for the number of diesel generators in the equationofRG1.018,RegulatoryPositionC.2.a(9), it is the staff's position that the applicant should either specify the number of diesel generators used to' determine the minimum start and load test and justify that number or delete this as an exception to the diesel generator

, tests. '

lV _E lectric responic_1Q_QMcitl0D_M J

The minimum diesel generator starts is 35 per diesel based on 2 diesels per unit. The fSAR will be updated accordingly [ Attachment 6). The remaining part of the exception shown in FSAR Section 1A(B) was included to indicate that some of the diesel starts could be performed outside the time interval normally associated with the Pre-operational Test Program. Since RG 1.108 indicates that the testing should be done during the Pre-operational Test Program, the exception is still valid, i

HRc_guestion 5:

(3) FSAR figures 14.2-3 and 14.2-4 and the responses to Questions 423.2 and 423.10 were modified to provide the requested information and consistency for extending the reactor control-system test and the operational vibration tests past fuel load. The response states that the incore nuclear instrumentation test and auxiliary startup instrumentation test were relocated to the initial startup test program and added to Table 14.2-3, " Initial Startup Test Summaries" in a previous FSAR amendment. Deferral of these tests until after fuel load constitutes exceptions to RG 1.68, Appendix A Subparagraphs 1.J.(13) and1.j.(18), it is the staff's position that the applicant should modify FSAR appendix 1A(B) to discuss and justify these exceptions.

TV Electric response to Outstion 5:

The FSAR will be revised to include the additional exceptions to RG 1.68. See items 22, 23 and 24 in draf t revised FSAR pages 1A(B)-43 and 1A(B)-43a (Attachment 7].

NRC question 6:

-(4) FSAR Appendix 1A(B), " Discussion of Regulatory Guides," page IA(B)-43,RG1.68,AppendixA, Subparagraph 5.z,wasmodifiedregarding use of calibration of radiation checks to demonstrate their proper r

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TXX-92513 Page 4 of 4 operation. Subparagraph 5.z guidance calls for demonstrating the correct response of process and effluent radiation monitoring systems by performing independent laboratory or other analyses. The applicant i should modify FSAR Table 14.2-3 and the response to Q423.16, item 2, as '

appropriate to reinstate independent analyses to demonstrate this capability for Unit 2, or provide technical justification for this exception in FSAR Appendix 1A(B) which explains how the alternative fulfills the same verifying function as independent laboratory analysis.

10 Electric response to Question 6: ,

The justif ication for this exception to RG 1.68 was provided in the

" description" letters accompanying Amendments 81 and 86, TXX-91099 dated March 21, 1991 (Attachment 8), and TXX-92391 dated September 6, 1992 (Attachment 9], respectively.

Sincerely.

Y Nt h' h' William J. Cahill, Jr.

By: M b-Roger (1. Walker Manager of Regulatory Affairs BSD/bsd Attachments

1. Generic Letter 84-15, Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability, July 2, 1984  !

Enclosure 2 (1 page)

2. Revision E to the Draf t CPSES Unit- 1 Technical Specifications page 3/4 8-10

3. TU Electric letter TXX-89035, dated January 24, 1989 Attachment 11, pages 2, 7, 3 and 9

4. NUREG 1399, CPSES Unit 1 Technical Specifications pages 3/4 8-6, 7 and 8

5. TU Electric letter TXX-90011, dated January 15, 1990 Attachment pages 4, 5 and 6

6. Draft revised FSAR pages 1A(B)-71 and T14.2-2 (sheet 34a) ,

7. Draft revised FSAR pages 1A(B)-43 and 1A(B)-43a

8. TV Electric letter TXX-91099, dated March 21, 1990 Attachment pages 35 and 36

9. TU Electric letter TXX-92391, dated September 4, 1992

. Attachment pages 2 and 3 c - Mr. J. L. Milhoan, Region IV Mr. B. E. Holian, NRR ResidentInspectors,CPSES(2)

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Generic Letter 84-15. Proposed Staff Actions to improve and.  !

Maintain Diesel Generator Reliability, July 2, 1984 l Enclosure 2 (1 page)  ;

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Attachment 1 to TXX-92513 Page 1 cf 1 ffCLOSURE 2 DIESEL GEf;EPAiro PELI/ FILI'Y DATA itr reliability of diesel teneraters has been idertified as one of the nadr

' actors af fectino the rist of core carane fron stetion blackout. Thus, attainment and contirued maintenance of high reliability for diesel renerators is necessary to the resolution of USI A ad. To assist the staff ir assessing the current reliability of dintel aenerators at operatino plan's, licensees are recuested to reprrt the reliability of each diesel generator at their plant for its last 20 ard 100 demands. This should include the number of failures in the last 20 and 100 valid denands indicatina the time history for there failures.

Licensees are requested +n indicate whether they raintain a record which itemizes the demands ard failures experienced by each diesel generator unit, in the manner outlined in Pegulatory Guide 1.108 position C.3.a. for each diesel generator unit. Licentres should also indicate whether a yearly data report ds maintaired for each diesel generator's reliability. The criteria 'cr determining the reliability of diesel cererators is as follows!

a. Valid demands and failuret are to be deternined in recordance with the raconnendatinns of Reculatory Guide !.108 posit.en c.2.e.

b. The reliability of ePch diesel gererator will be calculated based on the nc-ber of failures in the lest 100 valid derands.

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ATTACHMENT 2 Revision E to the Draft CPSES Unit 1 Technical Specifications ,

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Attachment 2 to TXX-92513

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[Lf11RICALPOWER SYSTEMS SURVEILLANCE REQVIREMENTS (Continued) __

11) Verifying that the fuel transfer pump transfers fuel from the fuel storage tank to the day tank of its associated diesel via the installed lines;

12) Verifying that the automatic load sequence timers are OPERABLE with the interval between each load block within 10% of its design interval;

13) Verify that the following diesel generator lockout D features prevent diesel generator starting:

D a) Barring device engaged, or D b) Maintenance Lockout Mode 0

g. At least once per 10 years or af ter any modifications which D could affect diesel generator interdependence by starting both diesel generators simultaneously,* during shutdown, and veriffing that both diesel generators accelerate to at least 441 rpm (58.8Hz) in less than or equal to 10 seconds and

h. At least once per 10 years by:

{D

1) Pumping out each fuel oil storage tank, removiilg the C accumulated sediment and cleaning the tank using a sodium hypochlorito solution or equivalent, and

2) Performing a pressure test of those portions of the diesel fuel oil system designed to Section !!!,

subsection ND of the ASME Code, when tested pursuant to Specification 4.0.5.

4.8.1.1.3 Reoorts All diesel generator failures, valid or non-D valid, shall be reported to the Commission in a Special Report pursuant to Specification 6.9.2 within 30 days. Reports of diesel generator failures shall include the information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1.

August 1977.

If the number of failures in the last 100 valid tests E on a per diesel generator basis is greater than or equal to 7, the report shall be supplemented to include the additional information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1, August 1977.

All planned diesel engine starts for the purpose of this surveillance may be preceded by a prelube period in accordance with vendor recommendations.

COMANCHE PEAK - UNIT 1 3/4 8 10 spreusa is, tese

ATTACHMENT 3 TV Electric letter TXX-89035. dated January 24, 1989 Attachment 11 pages 2. 7, 8 and 9 i

Attachment 3 to TXX-92513 Page 1 of 4 fxA 89035 Attachment 11 Page 2 of 27 CPSES Technical Specifications NRC Draft 3 Markup Section 3/4.8 Change 10.8 Justification For Change 5125 (cont) The real concern is not necessarily that water may get into the fuel but that micro-biological groath will occur at the DF0/ water interface and get sucked ir.to the system which would clog filters / strainers and restrict flow of DF0 to the diesel. This is not a concern at CPSES since microbiocide is added to the DF0 to prevent reicro- ,

biological growth. By having 600 gallons of unusable volume it is anticipated it would take a significant failure to accumulate that amount of water and water would be identified during the monthly sample. All water will be removed every 18 months. This change is also necessary based on manpower required to perform the sample and the potential for fuel contamination is significantly increased based on past experience, in order to get all the water out of the fuel oil storage tank, the manway must be removed which leaves a 3 foot diameter opening in the tank. This increases the likelihood of fuel oil contamination. This justification supersedes the justi-fication for ID #0928 in TV Electric Letter Txx 88512. ,

5149 This surveillance requirement has been changed based on the recalculations of the accident loads during the validation process. Since this surveillance is to ensure

, the Diesel Generator (DG) can carry the accident load l

0300KW was selected as the minimum loaded condition. The

i. actual accident load is around 5700KW, 6300KW was selected l to allow margin in case loads needed to be added at a later date and to keep the 110% load less than 7,000kW (maximum rated load of the DG). The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating on the diesel (i.e. 110%) is now changed to 6900 based on 110% of I the accident loads, which is 6930, and prevention of having to run the diesel in excess of the rormal maximum rated load.

5150 The batte ~ chargers.are being re evaluated to determine what the actual rated capacity is. This number will be provided at a later date.

5154 The loading time requirement has been changed based on operator lockouts being in effect until 120 seconds after the diesel generator start signal. Since this loading time is after breaker closure, 10 seconds has been i

subtracted from this 120 seconds. This time still meets the requirements Ff Regulatory Guide : 108.

Attachment 3 to TXX-92513 Page 2 of 4 1:s.89035 Attachment 11 Page 7 of 27 QQ{ [ g / p q/

ELECTRICAL POVER $Y$TEMS SURVE!LLANCE REQUIREMENTS (Contint.ed),

a) An API Gravity of within 0.3 degress at 60'F, or a speci-fic gravity of within 0.0016 at 60/60'F, when compared to the suppiter's certificate, or an absolute specific gra-vity at 60/60*F of greater than or equal to 4,4) but less I than or equal to 9tf+, or an API gravity of/ greater than i orequalto/26/degreesbutlessthanorAqualtof387 l degrees; / c,egd 4 0.Ovv b) A kinematic viscosity at 40'F of greater than or equal to 1.9 contistokes, but less than or equal to 4.1 centistokes (alternatively, $aybolt viscosity, $US at 100'F of greater than or eQu41 to 37.6, but less than or equal to 40.1), if gravity was not determined by comparison with the sup-

, piler's cif rtification; c) A flesh point equal to or greater than 125'F; d) A clear and bright appg::ance with proper color when tested in accordance with A$TW D4176 1982;

2) By verifying within 30 days of obtaining the sample that the other properties specified in Table 1 of ASTWD975-1981 are met when tested in accordance with ASTM-0975-1981 except that the analysis for sulfur may be performed in accordance with ASTH-D1552-1979 or ASTM-02622-1982.

e. At least once every 31 days by obtaining a sample of fuel oil in accordance with A$TW D2276-1978, and verifying that total particu- ,k, late contamination is less than 10 mg/ liter when checked in accor- #

dance with ASTM D2276 1978, Method Ar ed c.he.5 kg for- atee; l

f. At least once per 18 months", during shutdown, by:

1) Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service; '

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2) Verifying the generator capability to reject a load of greater l than or equal to /783/ kW while maintalping voltage at 6900 t l f690f volts and frequency at 60 t firef Hz; i

4. 71r l 3) Verifying the generator capability to reject a load of 70f 0 kW without tripping. The generator voltage shall not exceed 7590 volts during and following the load rejection;

4) Simulating a loss of offsite power by itself, and:

a) Verifying doenergization of the emergency busses and load shedding from the emergency busses, and T

l For any start of a diesel, the diesel must be operated with* a load in

) sccordance with the manufacturer's recommendations.

, COMANCHE PEAK - UNIT 1 3/4 8 $

Attachment 3 to TXX-92513 Page 3 of 4 ,

Dx-89035 Attachment 11 Page 8 of 27 PT(OoF REWFW

-El. ECTR! cat, POW R $Y$fEMS SURVE}QANCE REQUIREMENTS (Continued) _ _

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b) Verifying the diesel starts on the 69to start signal, energizes the emergency busses with permar:antly connected loads within 10 seconds, energizes the aute connected shut

• down loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energitation, the steady

• state voltage and frequency of the emergency busses shallbemaintainedat6900tf6907voltsand601fl.27Hz during this test. j

5. Verifying that on a Safety Injection Actuation test signal, without loss of-offsite power, the diesel generator starts on the auto

• start signal and operates on standby for greater than or equal to 5 minutes. The generator voltage and frequency shall be 69001/690gvoltsand60if1.2fHzwithin10 seconds after the auto-start signal; the steady-state generator voltage

- and frequency shall be maintained within these linits during this test;

6. Simulating a loss-of-offsite power in conjuction with a $4fety injection Actuation test signal, and:

a) Verifying doenergization of the emergency busses and load shedding from the emergency busses; b) Verifying the diesel starts on the auto start signal, energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto ec'inocted emergency (accident) loads through the load sequencer and l

operates for greater than or equal to 5 einutes while its ,

' generator is loaded with the emergency loads. Af ter ener-

{ giration,thesteady-statevoltageandfrequenc[yofthe emergency pusses shall be maintained at 6900

• 690Jvolts l and60tfl.2/Hzduringthistest;and j c) Verifying that all automatic diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a Safety injection Actuation signal.

7) Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator COMANCHE PEAK - UNIT 1 3/4 8-6

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Attachment 3 to TXX-92513 Page 4 of 4 4

in.89035 '

Q?;72Y Prcoor i Review -

ELECTRICA( POWER SYSTfMS SURVE!LtANCE AE0VIRIMENTS (Continued) '

090o

- *nd ii O shall be loaded to an indicated Met- 7700 kr, and during the  :

remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be 4

Gsoo a loaded to an indicated M !?C 7000 kW". The generator voltage and frequency shall be 6900 t /690 10secondsafterthestartsignal;7voltsand60t/1.2fHzwithin the steady-state generator l

voltage and frequency shall be saintained within these lietts during this test. Within 5 minutes after completing this 24-hour test, perform Specification 4.8.1.1.2f.#)b);" (L b

8) Verifying that the auto connected loads to each diesel generator do not exceed the continuous rating of 7,000 kW;

9) Verifying the diesel generator's capability tot a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b) Transfer its loads to the of fsite power source, and c) 8e restored to its standby status.

10) Verifying that with the diesel generator operating in a test modJ. connected to its bus, a simulated Safety Iniaction signal overrides the test mode by: (1) returning the diesel generator a

to standby operation, and (2) automatically energizing the emergency loads with offsite power;

11) Verifying that the fuel transfer pump transfers fuel from fuel storage tank to the day tank of its associated diesel via ths

, installed lines;  ;

12) Verifying that the automatic load sequence timers are 09 ERA 8LE

' with the interval between each load block within '+ 101 of its design interval;

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This band is meant as guidance to avoid routine overloading of the diesel generator. Loada in excess of the band or nosertary variations due to changing bus loads shall not invalidate the test.

"IfSpecification4.8.1.1.2f.bb)isnotsatisfactorilycompleted,itisnot lN' necessary to repeat the preceding 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test. Instead, the diesel generator may be operated between 4406 - 7000 kW for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or until operating tempera- '

ture has stabilized. (330o 2b26 TWh

-COMANCHE PEAK - UNIT-1 3/4 8-7:-

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-i ATTACHMENT 4 i NUREG 1399, CPSES Unit 1 Technical Specifications "

pages 3/4 8-6, 7 and 8 >

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Attachment 4 to TXX-92513

.Page 1 of 3 I'.!!':::: . :Tw E 8 .Oi'EuS EUGvEP..ANCE RE001oEuENTS (Continuec) 4)

Simulating a less-of offsite co.er by itself, anc:

a) y verif ing ceenergization of the emergency tusses ar: 7:ac sneacing from the emergency busses, and o)

Verifying the diesel starts on the auto-start signs',

energizes tne emergency busses with permanent 1,  ::arecte:

1caos within 10 secenas, energtzes the' auto-connectes ss i-down greater loads throuqh the lead secuencer and coerates # r tnan or equal to 5 minutes while its geaeastor loaded with the st.utdown loads. After energizaticm, tneis steady-state voltage and frequency of the em6rgency ousses shall be curing thismaintainea test. at 6900 2 690 volts ana 60 : 1.2 8: '

5) verifying that on a Safety injection Actuation test sigra' without loss of offsite power, the diesel generator starts en theequal or auto-start signal and operates on stancby for greater t~an to 5 minutes.

snall be 6900 The generator voltage and frecue t-690 volts ano 60 2 1.2 Hz within 10 sec:rc,s after the auto-start signal; the steady-state generator N ts;e and this frecuency test; shall be maintained within these limits curing 6)

Simulating a loss of-offsite lt'jection Actuation power test signal, and:in . , junction with a safetj a)

Verifying deenergization of the e legency busses anc icac sneccing from the emergency busset, c)

Verifying the ciesel starts on the auto-start signal, energites the emergency busses wita pe rmanent i;. cen ecte:

loacs within 10 seconds, energizes the auto-connectec emergency (accident) loads througn the load secuence" an:

operates for greater than or ecual to 5 minutes one its generator is loadeo with.the emergency leads. After ener-gization, the steady state voltage ano frequency of tre emergency busses shall be maintainea at 6900 : 690 solts and 60 1 1.2 Hz curing this test; and c) Verifying that 211 automatic diesel generator trics.

exceDt engine overspeed and generator differential, are automatically bypassed upon loss of voltage on tre emergency signal. r $ concurrent with a Safety injection ac t.ation 7)

Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Curing the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator COPANCHE DEAK - UNIT 1 3/4 8 6

Attachment 4 to TXX-92513 Page 2 of 3 ELECTRI:AL-:0WE# S'5TEMS i SURVE!LLANCE REQUIREMENTS (Continueel  !

shall be loaced to an indicatea 6900 7700 kw' a romaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generano curing the tor snali ce loacea to an indicated 6300 - 7000 kw# .

The generator *.oltage sod frecuency snall be 6900 2 690 volts and 60 : 1.2 *: *itnin 10 secones after the start signal; tne steady state qenerator voltagethis curing and test. frecuency shall be maintainee within the<e-limits 24-hour test perform Specification 4.8.1.1.2f.4)b);"With 8)

Verifying that the auto-connected loads to each diesel  ;

generator do not exceed the continuous rating of 7,000 kW: '

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Verifying the diesel generator's capability to:

i a)

Synchronize with the offsite power source while the ,

generator is loaded with its emergency loacs upon a simulated restoration of offsite power, j b)

Transfer its loads to the offsite power source, anc c) Be restorea to its standby status, 10) verifying that with the diesel generator operating in a test moce, connected to its bus, a simulater iafety injection signal i overrides the test moce by: (1) returng the diesel generator i to standby operation, and (2) automati:tily energizing the emergency loaas with offsite power; 11) verifying that the fuel transfer pump transfers fuel from fuel-storage tank to the day tank of its associated diesel via the installed lines:

12) verifying that the automatic load sequence timers are OPERABLE with theinterval; cesign interval between-each load block within + 10', of its ~

13)

, Veritying that-the following diesel generator lockout features prevent diesel generator starting:

k. :.

$V, "This banc is meant as guidance to avoid routine overloading of the diese generator, loaos shall nat invalidate the test. Momentary loaa excursions outside this ban

• 1f Specification.4,8.1,-1,2f,4)b) is not satisfactorily completed. it is not necessary to repeat the preceding 24-hour test. Instead, the diesel generator may be ocerated between ture has stabilized before repeating 4.8.1.1.2f.4)b).6300 - 7000 kw for 1 '

COMANCHELPEAK UN!T-1 3/4 8 7 . .

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Attachment 4 to YXX-92513 Page 3 of-3 i l

\

ELEC70! CAL ;C'aEs 3 5;;ug SURVEILLANCE REQUIREMENTS (Continued) a) Barring device er. gaged, or o) "aimtenance Lockout Moce. -

g. At least once per 10 years or after any modifications whic9 ::alo affe;t diesel generator interdependence by starting both diesel generators simultaneously,' during shutdown, and verifying '. st Oct$

diesel generators accelerate to at least 441 rpm (58.8 P:) sn less than or equal to 10 seconds; and

h. At least once per 10 years by:

1) Pumping out each futi oil storage tank, removing the accumul-ated sediment and cleaning the tank using a sodium hypocelor te solution or equivalent, and

2) Gerforming a pressure test of those portions of the ciesel fuel

' oil system cesigned to Section III, subsection ND of the ASME Coce. . hen tested pursuant to Specification 4.0.5.

A . B.1.1. 3 Reports - A11 diesel generator failures, valid or non-valic, snall be reported to tne Commission in a Special Report pursuant to Specification 6.3.2 ithin 30 days. Reports of diesel generator fad'ures shall incl. ace t e information recommended in Regulatory Position C.3.b Regulatory Guide 1.108. Revision 1, August 1977.

If the number of fai' *es in tne last 100 valid tests on a per diesel generator basis is greater than or ecual to 7, tae recort shall be' supplemented to include the additiona' 'nformation recommenceo in Regulatory Pesition C.3.b of Regulatory Guide 1.10E, Revision 1, August 1977.

' *All planned diesel engine starts for the purpose of this surveillance may be-preceded by a prelube period in accordance with vendor recommendations.

COMANCHE DEAK C UNIT-1 3/4 8 8-t

. _ . _ - _. _ _. _ _ .- _. _ . . . _______...__.._...._..__..____.__...-.m._.._._

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.I ATTACHMENT 5 ,

TV Electric letter TXX-90011, dated January 15, 1990 Attachment pages 4, 5 and 6

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Attachnent 5 to TXX-92513

.Page 1 of 3 Attachment to TXK 90011 Janu ry 15, 1990 Page 4 of 304 FSAR rage it.L8efAdtQ ) Et11r_iD1110 1A(B) 61

Description:

(Revision)

Revise the discussion on Regulatory Guidt .88.

Justification:

This change is required to provide for the adequate protect on of quality related documentation once the work .,civity has been completed and to require the timely submittal of quality related documentation to the records storage facility for retention.

Groups 3 FSAR Change Request Number: 89 74b

$ER/SSER impact: No IA(B) 70. 71

Description:

(Addition)

Adds text re: Regulater Jide 1.108. clarifying the number of requited dit jnerator starts.

Justification:

Text re: Regulatory Guidt 1.108 is added to clarify the number of required diesel generator starts. A total of 69 (but no less than 2J per F.mergency Diesel Generator) valid start and load tests on the Emergency Diesel Generators (EDG) is conducted from cold ambient condi-tions to at least 50 percent continuous rating far at least one hour with no failures. This addition /cle-i*

fication is proviqed as a result of the construction /

operation delay of Unit Z; Unit 2 EDG's cannot be

ounted for the total reliability of the EDG. since they are not tested at present.

Also, the addition / clarification indicates that the testing is not required to be performed during the pre operational testing period of the EDG, but may be perfoceed at any time prior to the required operability of the EDG.

Group: 3 FSAR Change Request Number: 89 738 Related SER Section: 14 SER/SSER 1mpact: No IA(B) 70. 71

Description:

(Revision)

Provides clarifications and exceptions to several Regulatory Positions in Reg. Guide 1.108.

Justification:

The justification for the clarifications / exceptions is listed below the Regulatory Position it applies to:

Regulatory Position C.2.a.5:

Regulatory Position C.2.a.S requires the demonstration of proper operation for design-accident loading-sequence to design load requirements. Based on meetings with the NRC to discuss and agree on the final Unit 1 Technical Specifications, the NRC stated-that CPSES will be required to demonstrate the proper operation for snutdown loading sequence to shutdown-

i Attachment 5 to TXX-92513 Page 2 of 3 Bttacnment to TsI 90011 January 15. 1990 Page 5 of 304 i

F$AR Page lil_t*1EAid) Descriptign '

-r losd reautrements. Demonstration of the shutdown-loading sequence is the more conservative of the two since the diesel generator will be subjected to its  !

maximum expected loading requirements (Sea Technical L Specification 4.6.1.1.2f 7) which references the shutdown loeding sequence testing requirement of  ;

Technical $pecification 4.8.1.1.2f.4)b)).

Regulatory Positions 0.2.a.3 and C.2.c.2 Since.the intent of the testing requirements is to ensure that the diesel generator can catry its maximum ,

expected load. 6300 KW (90% of rated load) was  !

selected as the minimum loaded condition. The 6300 KW  ;

value exceeds the maximum expected diesel gene ato.

loading requirements (see FSAR Tables 8.3 1A. 8.3 18. &

6.3 2) and still allows a margin in case loads need to be added at a later date. [

The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> test requirement (C.2.a.3) will be conducted at a minimum of 6900 KW which is approximately 110% of the maximum expected Icading requirements. This change ,

will prL<ent unnecessary running of the diesel in cess of the normal maximum rated load (7000 KW).

Die ~1 loading is accomplished in accordance with vendor recommendations as suggested in NRC Generic Let.ter 84 15, dated July 2 1984 'These changes are consistent with the current Unit 1 Tech. Specs, as Continued on next page --

Group 3 FSAA Change Request Number: 89 770 Related SER Section: 8.3.1 SER/SSER Impact: No 1A(Q)-87 Descriptions (Addition)

Adds exception ~to Reg. Gaide 1.140.

. Justification:

Adds exception to Reg. Guide 1.140 regarding Regulatory-Position C.3.h. water drains, which was deleted from Reg. Guide 1.52. Since the hydrogen purge system is no longer an ESF system, the reqJirements of Reg, Guide 1.140 now apply.

Group 3 FSAR Change Request Number: 89 628.7

-Related SER Section: 6.2.4 SER/SSER impact: No

1A(B) 89

Description:

-(Correction)-

C1srifies exception to Reg. Guida 1.140 Justifications:

Clarifies exception to Reg. Guide 1.140 to show that the HEPA filter and charcoal adsorber efficiency for all non Engineered Tafety Features (ESF) Filtration -

-- - _.,.. __. ,s _ . ._ . . _ . . . , _ _ _ . _ _ , . _ a_. ._._-

. Attachment 5 to TXX-92513 Page 3 of 3 Attachment to TXX 90011 January 15. 1990 Page 6 of 304 FSAR Page (alae 3nded) Descrioti_qn

'Jnits is 90% which co- .gunds to an acceptance criteria of ass than 1% for in place penetration and bypass leckage at rated flow. The value for efficiency is consistent with information submitted in FSAR Amendment 76. Although these are non ESF ltration Units, the value for in place penetration and bypass leakege is conservatively established consistent with the ESF value, broup: 3 FSAR Change Request Nuwber: 89 628.11 Ralated SER Section: 6.5.1 SER/SSER Impact: No 1A(B)-70.71 See Page No(s): Continued from previous page

Description:

(Revision)

Justification:

Continued from previous page.

submitted in TyX-89035. dated January 24. 1989.

Regulatory Positions C.2.d and C 3.b:

These clarifications and exceptions resulted from the recommendations provided by the NRC in Generic letter 84-15. dated July 2. 1984. and from direction provided by the NRC during meetings to discuss and agree on the final Unit 1 Technical Specifications.

Group: 3 FSAR Change Request Number: 89 770 Related SER Section: 8.3.1 SER/SSER Impact: No IA(N)-34

Description:

(Con /ection)

Discussion in response to regulato*y guide 1.60 is cor-rected to be consistent with critical damping value criteria presented by previous amendments to tection 3.7N and 3.78.

Justification:

Correction is consistent with critical damping criteria '

presented in FSAR sections 3.7N and 3.78.

Grou': 3 FSA .ange Request Number: 89 713.4 Related SER Section: 3.7.1 SSER21 3.7.1 SER/SSER Impact: No 1A(N)-35

Description:

(Update)

Delete "6 cay and Green Books" at the last line.

Justification:

The NRC Gray and Green Books are no longer used.

Group: 4 ,

FSAR Change Request Number: 89-603.1 SER/SSER impact: No

ATTACHMENT 6 Oraft revised FSAR pages 1A(B)-71 and T14,2-2 (sheet 34a)

)

I m

Attachment 6 to TXX-92513 Page 1-of 2 CPSES/FSAR

c. Regulatory Position C.2.a.9 Demonstrate'the reliability of the Emergency Diesel Generator by performing at least a total of 69 (but no less than 35 per Emergency Diesel Generator) consecutive valid l DRAFT start and load tests on the Emergency Diesel Generators from cold ambient conditions to at least 50 percent continuous rating for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with no failures. These tests need not be performed as part of the pre-operational test program, but may be performed at any time prior to the required operability of the Emergency Diesel Generator,

d. Regulatory Position C.2.c.2 Periodic testing of the diesel generator units during normal plant operation to demonstrate full-load-carrying capability will be conducted at a load which exceeds the maximum expected diesel generator load requirerants. During this-test, loeding to the diesel gneretor is accomplished in accordance with vendor recommendations,

e. Regulatory Position C.2.d for the purposes of determining the required test frequency, the previous test failure count may be reduced to zero if a complete diesel overhaul to.like-new condition is completed, provided that the overhaul, including appropriate post-maintenance op m tion and testing, is specifically. approved by the manufacturer and if acceptable reliability has been demonstrated.

The interval for periodic testing of an individual diesel generator will be determined on a per diesel generator basis rather than on the basis of the nuclear unit's collective diesel generator performance.

Draft Version 1A(B)-71

Attachment 6-to TXX-92513 '

Page 2 of 2 i

CPSES/FSAR TABLE 14.2 (Sheet 34a) Q423.12 j

5. Perform at least 35 valid start and load tests per diesel DRAFT l

generator with no failures from cold ambient conditions to at least 50 percent continuous rating, l Q040.111!

Q423.12

6. Demonstrate loading capability for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 6 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> will be a load equivalent to the diesel generator continuous rating and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will be a load equivalent to the-diesel generator 2-hour rating.

Q423.12

7. Demonstrate the ability to synchronize the diesel generator unit- 6 ,

with offsite power while the unit is connected to the emergency load, transfer this load to the offsite power, isolate the diesel generator unit, and restore it to standby status.

Q423.12

8. Demonstrate that the diesel generator capability to supply -6 emergency load is not impaired during periodic testing.

Q423.25

9. Demonstrate functional capability at full-load conditions by 10 reperforming the automa:ic start and load sections of Steps 2 and 3 immediately after Step 6 is completed.

Q423.25

10. Demonstrate that no common failure modes exist by starting the 10 redundant diesel generators simultaneously.

ACCEPT &Y1E CRITERIA Q040 '.12 Q423.11 --

The diesel generators surp y emergency power to the 6.9KV C M i 4E 6 l buses on loss of the preferred and alternate offsite power feeds to the emergency buses. The diesels start, attain speed and voltage and accept emergency load or rated load as designed. The fuel oil, lubricating oil, cooling'and heating systems function as designed.

Interlocks, alarms, controls and tripping devices function properly in l response to normal or simulated input signals.

Graft Version I

e

+ e. +e E

ATTACHMENT 7

~0 raft revised FSAR pages 1A(B)-43 and 1A(B)-43a

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Attachment 7 to TXX-92513

1. 98 CPSES/FSAR for Unit 2, one low power flux map will be taken prior to 86 exceeding 30% RTP as a fulfillment of Regulatcry Guide 1.68, Appendix A, subparagraph 4.e. At power, flux maps will be taken l

at 50%, 75% and 100% RTP to satisfy hegulatory Guide 1.68, Appendix A, subparagraph 5.b. Additional flux maps will be taken if required by Pegulatory Guik 1.68, Appendix C, subparagraph 4.h.

For Unit 1, the unit load transient at approximately 30% RTP will 86 be performed following completion of 50% RTP plateau testing to assure proper control system response, for Unit 2, the 30% RTP unit load transient will not be performea.

The Automatic Reactor Control System test 's perform?d at 50% RTP 86 and intended as a precursor to the first Unit Load Transient test. It is designed to ensure that the automatic rod control-system can restore the Reactor Coolant System (RCS) temperature 76 to within a 11.5 Deg-F deadband of the reference temperature.

Prior to 50% RTP, proper operation of this function would be demonstrated by observation during the normal power escalation, where the control rods will be in automatic and already controlling the RCS temperature to within the deadband.

21. Appendix A, subparagraph 5.z 86 For Unit 2, each radiation monitor and detector will be 86 calibrated in lieu of only verifying response to a radiation check source as part of the preoperational test program (Table 14.2-2, Sheet 24A). The calibration of the monitors and detectors meet the intent of RG 1.68. Revision 2. Appendix A, Sections 4.g and 5.z (see FSAR 11.5.2.11) and provides a more accurate method for demonstration of their proper operation.

22. Appendix A, subparagraph 1.J.(13). DRAFT The incore neutron instrumentation portion of this subparagraph DRAFT cannot be fully tested as a preoperational test program item because the system is not fully installed until after-initial 1A(8)-43 Draft Version

- _ . . _ . = . . . _ _ _ _ _ _ . . . . . _ _ . _ _ . _ _._

Attachment 7 to_TXX-92513- i l;,

'Page:2.of 2 '

' CPSES/ TSAR DRAFT fuel load._-The fuel assemblies provide the structural support {

for the~incore flux mapping system thimbles, the thimbles'are;not-self-supporting and cannot be installed until after the fuel is_ -

all_in place, For this reason _the only valid demonstration of ,

proper system function over its full operational range must be performed after initial fuel load, Portions of this testing are

also customarily performed at normal operating temperatures prior ,

to initial reactor criticality _to ensure that thimble thermal expansion does not create any system' operation interferences..

ORAFT 23. AppendixA, subparagraph 1.j.(18).

DRAFT The neutron response checks of the auxiliary startup instrumentation are not included as part of the preoperational test program. This testing is performed prior to the start of initial fuel loading, but is addressed as an inital startup test.

The auxiliary startup instrmentition is typically received only a short time prior to the start of initial fuel load and is.

tested prior to the actual fuel movements. The neutron response check portion of this testing is required to.be performed within-8 hours J the actual start of initial fuel . loading. This time- -

constraint makes it impractical to~ retain this testing in the .

-preoperational testing program _as it allows too little time to:

~

close out the preoperational testing program prior to fuel load. .

DRAFT 24. Appendix A, subparagraph 5.q.

DRAFT The failed fuel detection system consists of the failed fuel

-monitor with letdown chemistry-samples used as bothta backup and supplement. -The failed fuel monitor, itself, is one of the process radiation monitors that are-tested elsewhere under subparagraph 5.z. Additional testing of.this one monitor, beyond that already planned as=part of the process monitor testing, would not be expected to provide additional useful test results. Normal plant operating surveillances-provide sufficient assurance of failed fuel monitor operability-and of the ability to detect any actual failed-fuel.

lA(B)-43a -Draft-Version

ATTACHMENT 8 TV Electric letter TXX-91099, dated March 21, 1990 Attachment pages 35 and 36

-. Attachment 8 to TXX-92513  :

- Page l'of 2 Attachment to-TXX 91099 March 11, 1991 Page 35 of 50 FSAR-Page (11 atended) Description Group: 2 FSAR Change Request Number: 90 213.2 Related SER Section: 13.1: SSER22 13.1 SER/SSER Impact: No 13.4 5

Description:

(Revision)

Transfers the Independent Safety Assessment Group

~

(ISEG) from the Director. Technical Interface to the Director of Nuclear Overview.

Justification:

See justification associated with page 13.1 9.

Group: 3 FSAR Change Request Number: 90-213.2 Related SER Section: 13.1: SSER22 13.1-SER/SSER Impact: No 14.2 11. 15

Description:

(Revision)

Updates organization to refect newly created Nuclear Ove view department.

Justif1 cation:

See justification associated with page 13.1-10.

Group: 2 FSAR Change Request Number: 90-213.2 Related SER Section: 13.1: SSER22 13.1 SER/SSER Impact: No Table 14.2-2 See Sheet No(s):24 and'24A

Description:

(Revision)

Revises the Preop test requirement for Unit 2 for the Process Radiation ~ Monitoring System to verify--

calibration using a radioactive source of known.

activity.

Justification:

During the CPSES Unit 1 ISU testing, it was found that-the testing of the plant monitors during-low power and; power ascension testing did not provide any-additional data other-than that achieved during the Preop testing, the majority'of the systems _ remain at such low radiatiun concentrations'that the monitors are only responding to background levels. Therefore, for_CPSES Unit 2. an-alternate method _will be used for-ensuring the proper operation of theLradiation monitors.

Each monitor and detector (s) will be calibrated.(see FSAR Section 11.5.2.11) in lieu of.only performing a radiation source check. This expanded Preop ~ testing will'be_ performed in lieu of the the Process and Effluent Radiation Monitcring Systee'ISU test. The.

calibration'of the process rad 19 tion monitors will meet-the intent of Regulatory Guide 1.68._ Revision 2 Appendix A, Sections 1 k.1, 4.g and S.z,~ requirements-will provide a more accurate method for demo.astrating the proper operation of.the radiation'aonitors.

Attachment 8 to TXX-92513

^

Page 2^of 2 -

)T .

Attachment to TXX 91099 March-21, 1991 Page 36 of 50 FSAR Pagt til amended)

Descristien Group: 2 FSAR Change Request Number: 90 169 Related SER Section: 14.0 SER/SSER Impact: No Table 14.2+3 See Sheet No(s): 13 and 13A Description (Revision)

Deletes ISU testing requirements for the Process and ,

Effluent Justification: Radiation Monitoring System for Unit 2.

See2Description for Table 14.2-2. Sheet 24A.

Group:

FSAR Change Request Number: 90 169 Related SER Section: 14.0 SER/SSER Impact: No-15.0 4 See Page No(s):0 212-122 & 122e Descriptions (Editorial)-

Relocates that portion of the response to Question ,

212.66 dealing with. demonstrating that DNBR remains greater than 1,30 for Condition Il events.

Justification:

This change is made to assist in readying the 0 & R .

section Group: 4; for deletion when_the USAR is prepared.

FSAR Change Request Number:

90-174.2 Related SER Section: 15.1 SER/SSER Impact: No 15.2 33 See Page Ko(s):0 212-122 & 122e

Description:

(Editorial)-

AddsJa phrase to FSAR Section 15.2.8.2lto identify the specific sections 11n which.the DN8 considerations water Line Rupture event.-are eddressed'(or bounded.~

Jurtification:

This change is made to assist in readying the O & R section .for deletion when the USAR is prepared. Since pump coastdown characteristics are demonstrated in Sections events.

Group: 4 15.3.1 and 115.3.2. ated no'ONB o the same result is obtained in this case.

FSAR Change Request _ Number: 90174.6 Related SER Section: 15.3.6 SER/SSER Impact: No 15.3-7

Description:

(Editorial)

Editorial Change-to FSAR Chapter 15.3

~ Justification:

The enange is a rearrangement of sentences to make th meaning'of the paragraph clearer.--Additionally. the Overtemperature Trip has been_chenged to the N-16 Ov

_ _ . . . . - . . N----~~~~~~~~~ ~~

. , _ _ _ . _ . . ~ . . _ . . . _ _ - . . . . . _ ._ _.

a.

ATTACHMENT 9 TV Electric letter TXX-92391, dated September 4, 1992 Attachment pages 2 and 3 I

V E

TT ,

Attachment 9-to TXX-92513 Page 1 of_2 e

Attachment'to TXX 92391 September 4. 1992 Page 2 of 117 FSAR Page (11 noended) Descrintion or boron endpoint measurements during low power physics testing.

Group: 2 FSAR Change Request Number: 92 622.2 Related SER Section: 14.0; SSER23 14.0 SER/SSER Impact: No 1A(B) 43 Description (Revision)

Adds description that the 30% power transient. testing will not be performed on Unit 2.

Justification:

Adds Unit 2 specific information to Item 20.that-no-301 power transient will be performed on Unit 2.

See Description provided for 10% load swing transient testing on Sheet 23 of Table 14.2 3.

Group: 2 FSAR Change Request Number: 92-622.3 Related SER Section: 14.0; SSER23 14,0 SER/SSER 1mpact: No 1A(B) 43 Description (Clari'ication)

'In_ response'to-Item 1 from-the NRC RAI concerning the Startup Testing Program. Appendix 1A(B) has been

1erified to indicate at which power the Automatic.

Reactor Control System ISU test will be conducted, i (Ref NRC RAI dated-6/22/92: TXX 9231S dated 7/10/92)

Justification:

4 RG'1.68. Item 20. Section C.8. Appenidix A (Various) .

has been clarified.to indicate that the Automatic '

Reactor Control System test "is performed at 50% RTP and intended as a precursor-to the first Unit Load Transient test.

Group: 4 FSAR Change Request Number: 92 622.729 Related SER Section: 14.0: SSER23 14.0 SER/SSER Impact: No 1A(B) 43

Description:

(Clarification).

In-response to item <4 from the NRC RAI concerning the Startup Testing program. Appendix 1A(B) has been updated to indicate that an alternate method will be used for_ ensuring the proper operation of the radiation monitort for Unit 2.

Justification:

Item 21 has been added to Appendix 1A(B) for RG 1.68 to indicate the exception to Appendix A. subparagraph S.z. for ensuring the proper operation of the radiation monitors. In Amendment 81. FSAR sections R423.16.2b.

T14.2.2 Sheet 24A and T14.2-3 Sheet 13A were revised to

-reflect an alternate method for' Preop and ISU testing of the Unit 2 Process Efflusnt Monitoring System.

During the CPSES Unit 1 150 testing.~it was found that

Attachment 9 to iXX-92513

Page 2 of 2-i l

Attachment to TXX 92391 September 4. 1992 i Page 3 of 117 l FSAR Page (11 meendeds' Description the testing of the plant monitors during low power and power ascension testing did not_ provide any additional data other than that achieved during the Preop testing.

The majority of the systems remain at such low radiation concentrations that the monitors are only responding to background levels. Therefore, for CPSES Unit 2. an alternate method will be used for ensuring-the proper operation of the radiation monitors. Each monitor and detector (s) will be calibrated (see~FSAR section 11.5.2.11) in lieu of only performing a radiation source check. The expanded Preop testing will be performed in lieu of the Process and Effluent Radiation Monitoring Systee ISU test. The calibration of the process radiation monitors will meet the intent of RG 1.68 Revision 2. Sections 1.k.1, 4.g and 5.z.

requirements and will provide a more accurate method for demonstrating the proper operation of the radiation monitors. This update will make Appendix 1A(B) consistent Group: 4 with the previous revised FSAR sections.

FSAR Change Request Number: 92 622.729 Related SER Section: 14.0 SER/SSER Impact: No IA(B)-70. 71

Description:

(Clarification)

In response to Item'2:from the NRC RAI concerning the Startup Testing Program, Appendix 1A(B) has been updated to recatorgized the clarifications and exceptions to RG 1.108.

Justification:

Regulatory Position C.2.a.3 has been clarified to state that "During preoperational testing testing will' be -

conducted at the full load-carrying capability for an=

interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> will be at_the continuous rating capability of the diesel generator and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at a load equivalent to the two hour rating of the diesel generator.

Regulatory-Position C.2.a.5_has been clarified to state that during preoperational testing the proper operation for the design-accident-loading sequence to design-load-requirements will be demonstrated.

Regulatory Position C.2.a.9 has been clarified to state ~

that the number ef valid tests with no failure for each emergency diesel generators will be from " consecutive" tests. ,

Regulatory Position C.2.d has been clarified to correct the typographical error from "10" to "100" for the number of valid tests.

Group: 4 FSAR Change Request Number: 92-622,729 Related SER

-SER/SSER Section:

Impact: No 14.0: SSER23 14.0 .