U-600384, Forwards Response to 851029 Request for Addl Info Re Initial Plant Test Program

Forwards Response to 851029 Request for Addl Info Re Initial Plant Test Program

ML20141F309
Person / Time
Site:	Clinton
Issue date:	01/07/1986
From:	Spangenberg F ILLINOIS POWER CO.
To:	Butler W Office of Nuclear Reactor Regulation
References
U-600384, NUDOCS 8601090179
Download: ML20141F309 (4)

Text

& 8* U-600384 LO8-86 (01 -07 )-L 1A.120 ILLINDIS POWER COMPANY CLINTON POMR STATION P.o. BOX 678. CLINTON. ILLINOIS 61727 January 7, 1986 Docket No. 50-461 Director of Nuclear Reactor Regulation Attention: Dr. W. R. Butler, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Response to the Request for Additional Information on The Initial Plant Test Program for Clinton Power Station, dated October 29, 1985

Dear Dr. Butler:

This letter is in response to the October 29, 1985, letter which requested additional information coneerning the CPS Initial Plant Tec e Program. Attachment A provides Illinois Power Company's response t<

this request.

I trust that our response is satisfactory to ensure compliance with regulatory requirements.

Sincerely yours, F. A. Sp'a g h Manager - Licensing and Safety DLC/cke Attachment cc: B. L. Siegel, NRC Clinton Licensing Project Manager NRC Renident Office Regional Administrator, Region III, USNRC 1111nois Department of Nuclear Safety IB (LIAs)

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.- U-600384 LO8-85 (01-07)-L 1A.120 Attachment A Responses to RAI Questions QUESTION 640.13 1.n(18) Either provide an acceptance test abstract for the heat tracing system or modify appropriate test abstracts to reinstate testing of this system.

RESPONSE Heat tracing on non-safety related systems will be tested under the generic test program. Test abstracts for safety-related systecs will be revised to include verification of heat tracing as part of the system preoperational or acceptance test.

QUESTION 640.15 5.2 Either modify the response to this item to reference where testing of process and effluent radiation monitoring systems is demonstrated, or reinstate these system tests in FSAR Subsection 14.2.12.2.2, Radiation Measurements.

RESPONSE The proper response of Process and Effluent Radiation Monitoring systems will be demonstrated during preoperational testing.

(See Subsections 14.2.12.1.19 and 14.2.12.1.20)

QUESTION 640.16 (4) Exception to Regulatory Guide 1.68, Appendix A, Paragraph 1.h(10), in FSAR Section 1.8 should be modified or deleted as ultimate heat sink testing has been modified in response to this item.

RESPONSE There is no practical way of lowering the lake level for testing of the ultimate heat sink. Testing for Net Pump Suction Head and to ensure vortexing does not occur will be performed by lowering the water level in the pump pit.

Testing will be performed at simulated normal lake level and minimum design ultimate heat sink level.

QUESTION 640.16 (5) FSAR Subsection 14.2.12.1.36, Diesel Generator System, acceptance criteria relating to load testing and consecutive starts should reference Regulatory Guide 1.108 recommendations, not design considerations. 6 RESPONSE FSAR Subsection 14.2.12.1.36 will be revised in the next amendment to reference Regulatory Guide 1.108 recommendations, instead of design considerations.

QUESTION 640.16 (6) FSAR Subsection 14.2.12.1.38, 125 VDC Systems, should be modified to demonstrate that emergency D-C loads as installed will be verified to remain operable at the minimum voltage level established in the discharge test.

RESPONSE An engineering evaluatien has been performed to verify that the emergency DC loads will remain operable at the minimum voltage level established in the discharge test.

. U-600384 LO8-86 (01-07)-L 1A.120 This evaluation included calculation of voltage at the device terminals, including the worst-case voltage drop, which was determined for the longest cable in the system. The calculated available voltages were then compared with vendor-supplied operating data for each device. In all but one case the calculated voltages were well within the operating voltage range of the devices. The one exception (RCIC Gland Seal Air Compressor 1E51-C002F) will be field -

tested in Preoperational Test PTP-RI-01. This test will verify proper compressor operation at the minimum voltage available at the device terminals, considerirg voltage drop due to the cable, and the minimum allowable bus voltage of 105 volts per CPS FSAR commitment.

A copy of the above evaluation will be provided, upon request.

QUESTION 14A Modify FSAR Table 14.2-1 to include the following Regulatory Guides:

(1) Regulatory Guide 1.56, Maintenance of Water Purity in Boiling Water Reactors, and l

(2) Regulatory Guide 1.95, Protection of Nuclear Power Plant

Control Room Operators Against an Accidental Chlorine Release.

RESPONSE Regulatory Guides 1.56 and 1.95 will be added to Table 14.2-1 in the next amendment.

QUESTION 14B It is not apparent from the discussion in FSAR Subsection 14.2.4 and 14.2.10 that the commencement of fuel loading requires completion of all preoperational tests. For portions of any preoperational tests (including review and approval of test results) which are intended to be conducted after fuel loading: (a) list each test, (b) state what portions of each test will be delayed until after fuel loading, (c) provide technical justification for delaying these portions, and (d) state when each test will be completed.

RESPONSE A program has been established that will identify and track preoperational and C&IO Phase test activities determined necessary to defer until after receipt of the Operating License. The requested information for all tests to be completed after fuel load will be provided in the Readiness for Fuel Load Letter.

f QUESTION 14C The exceptions taken to Positions C.9 and C.10 of Regulatory Guide 1.8, Preoperational Testing of Instrument Air Systems, in FSAR Section 1.8 should either be deleted, justification provided for the existing project position, or delete reference to Regulatory Guide 1.80 and comply with l

Regulatory Guide 1.68.3, Preoperational Testing of Instrument l and Control Air Systems.

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. U-600384 LO8-85 (01 -07 )-L 1A.120 RESPONSE The exception to position C 9 will be deleted. In reference to exception C.10, IPC does not intend to perform the Loss-of -

instrument-air-supply test /cscribed therein, because performance of testing required by positions C.8 and C.9, in combination with the checkout and initial operation testing of each valve, will satisfy the requirements of position C.10.

This exception shall be revised in the next amendment.

QUESTION 14D Either reinstate Level 2 acceptance criteria regarding the low-low set pressure relief logic in FSAR Subsection 14.2.12.2.28, Loss of Offsite Power, or provide technical justification for deletion of the criteria.

RESPONSE These Level 2 acceptance criteria were originally included as per GE Startup Test Specification 2217217. This specification was subsequently revised per GE's Field Deviation Disposition Request - LH1 - 5121, Rev. 0 (Dated 1/8/85) in which the above reference Level 2 criteria requirement was deleted. The stated reason was: "The plant Safety Relief Valve position monitoring system is not powered by Uninterruptible Power Supply. Also, Safety Relief Valve actuation will be monitored by the other major transient testing such as Full Power Reactor Isolation Test (25B) and Load Rejection Test (27)."

Thus this Field Deviation Disposition Request (LIII-2121) deleted the Level 2 criteria requirement with respect to low-low set pressure relief logic.

In addition, in another more recent Field Deviation Disposition Request (LH1-5413. Rev. O dated 9/24/85), it was further clarified that, per GE document 2214159DK, "this test STP-31, is a verification of emergency electrical switching and not of reactor transient response." This is a further technical justification for deleting the Level 2 acceptance g criteria regarding the low-low set pressure relief logic.

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