ML20133K727
| ML20133K727 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 10/07/1985 |
| From: | Ainger K COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 0697K, 697K, NUDOCS 8510220271 | |
| Download: ML20133K727 (5) | |
Text
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N Commonwealth Edison 22 ' ) One First National Plaza. Chicago. Ilhnois O'
Address Riply to: Post Office Box 767 w -
Chicago, Illinois 60690 October 7, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron Station Unit 2 Braidwood Station Units 1 and 2 Startup Test Program NRC Docket Nos. 50-455, 50-456, & 50-457
Dear Mr. Denton:
This letter provides an advance copy of FSAR revisions related to the Startup Test Program described in Chapter 14 of the Byron /Braidwood FSAR. ' These changes modify the manner in which we conduct our two stage evaluation of startup test results._ The first stage of review is performed by station personnel and approved by the onsite Test Review Board. The second stage of review and final approval is conducted by the Project Engineering Department.
Previously, we have fulfilled our commitment in Chapter 14 concerning evaluation and approval of startup test results by requiring the completion of both stages of review prior to proceeding to the next power level plateau. We have re-evaluated this commitment and it is being modified to require only the first stage of test results review and approval to be completed prior to proceeding to the next power level plateau.
The startup test program for the remaining three units is a repetition of the Byron Unit 1 program, except for minor improvements based upon lessons learned from Byron Unit 1 testing. Accordingly, testing on the remaining three units should proouce results similar to those experienced on Byron Unit 1.
The Test Review Board (TRB) review involves judging the acceptability of the test results against the same criteria used by the Project Engineering Department. The same qualified personnel will be performing the detailed evaluation of the test' results. Collectively, the three members of the onsite TRB meet or exceed the experience qualification requirements for the Technical Manager and Operations Manager positions defined in ANSI N18.1-1971 and one of the members of every TRB holds a Senior Reactor Operator license.
The Project Engineering Department will still have the responsibility for final test acceptance and approval as well as. the authority to require additional testing, if necessary, prior to their acceptance of test results.
I 851022 271 85 455 pg ADOCK pg i
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H. R. Denton October 7, 1985 For the reasons stated above, we believe the level of quality and rigor of review of the startup test results will not diminish as a result of this~ revision to our test evaluation process.
This change in GJr test evaluation process will relieve the schedular burden placed upon our resources for the second stage of test results review, especially when testing at a given power plateau is complete.
We expect this proposed change to result in significant time savings in the overall completion of the startup test program for Byron Unit 2 and Braidwood.
We are requesting NRC concurrence with this proposed change to our test evaluation process. The enclosed FSAR revisions will be included in the next FSAR amendment.
Please direct any questions regarding this matter to this office.
One signed original and fif teen copies of this letter and enclosure are provideo for NRC review.
Very truly yours,
]yf 1 K. A. Ainger Nuclear Licensing Administrator im Enclosure cc: Byron Resident Inspector Braidwood Resident Inspector 0697K
5 B/B-FSAR AMENDMENT 46 JANUARY 1985 14.2.4 Conduct of Test Program The initial preoperational and startup test prograus will be conducted using detailed written procedures that include provisions for assuring that prerequisites have been completed.
Test personnel will be instructed to initial and date the prerequisites included in 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 or Project Startup personnel (as applicable) will be made.
The Project Engineering Department project personnel will perform a second and final review and evaluation.
Modifications or rework of systems or equipment required to' resolve deficiencies will be accomplished in accordance with controlled procedures.
Retesting, 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 preoperational test i
phase will be completed and the results evaluated prior to core i
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 the responsi-l bility for final test acceptance and approval.
Project Engineering may specify additional test requirements to resolve test deficiencies l
prior to final test approval.
The power ascension procedure will specify those startup tests or portions of startup tests that must be completed as a prerequisite for commencing each phase.
The data obtained at each power test plateau will be evaluated and approved,before increasing power level.
Qy ne mNe %sf Redeu Boarc( and Sk4 ton Sperinfen det 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 will be reviewed for completeness, identified, and indexed to establish them as part of a permanent record to be retained.
These records will include data sheets completed during the test.
14.2-3 l
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s B/B-FS AR JUNE 1984 Preoperational testing will proceed concurrently with construction testing as various systems reach completion and are turned over to the station startup staff.
The principal milestones l
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during this phase are expected to be the reactor coolant system hydrostatic test and the integrated h'ot f unctional test.
The f ormer test is expected to be accomplished approximately 10 months prior to f uel load.
Hot functional testing is expected to begin aoout 3 months before fuel load.
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 cnd test data obtained at each power test plateau will be evaluated and approved prior to increasing power load, k by +he ensi+c Tes+ Review Board and Sfa4 ion L erin +endent P
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.
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
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B/B-FSP.R AMENDMENT 36 JANUARY 1982 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 approvedabefore-increasing power level.
Subsections 14.2.5 and 14.2.11 have been revised to include these commitments.,)
by Me, onsife. 'Tes]. Revieu; bard and $bflon Supe.rinhnde nt V
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