ML20141N171
| ML20141N171 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1986 |
| From: | NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| Shared Package | |
| ML20141N167 | List: |
| References | |
| PROC-860227-01, NUDOCS 8603040440 | |
| Download: ML20141N171 (3) | |
Text
s COMANCHE PEAK RESPONSE TEAM g3 ACTION PLAN ISAP III.a.3
Title:
Technical Specification For Deferred Tests Revision No.
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3(~N ISAP III.a.3
- N.Y Technical Specifications For Deferred Tests
1.0 DESCRIPTION
OF ISSUE The NRC-TRT originally described this issue in NRC letter, D. G.
Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure 1 at Page 13, as follows:
"The TRT pointed out that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel' load, certain limiting conditions of the proposed technical specifications cannot be met, e.g., all snubbers will not be operable since some will not have been tested."
2.0 ACTION IDENTIFIED BY NRC The NRr-TRT originally identified the following action in NRC letter, D. G. Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure i at Page 13, as being necessary to resolve this~ issue:
"Accordingly, TUEC shall evaluate the required plant conditions for the deferred preoperational tests against
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limiting conditions in the proposed techrical specifications end obtain NRC approval where deviations from the technical specifications are necessary."
and subsequently modified in CPSES Safety Evaluation Report, Supplement No. 7 at Page J-18, that the action identified cited above:
"...is no longer applicable since the TRT has been informed by TUEC that these tests will be conducted prior to fuel load."
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3.0 BACKGROUND
Following completion of preoperational hot functional testing, the results of certain tests indicated that the deficiencies identified would require design modifications, component repair or replacement, or initial installation and subsequent testing. The nature of the retesting would require the primary plant to be at normal operating pressure and temperature. The next planned primary plant heatup was scheduled in the interval between fuel load and initial criticality. Therefore, TUEC sought and received j
NRC-NRR approval to defer these retests until the primary plant heatup following initial fuel loading.
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ISAP III.a.3
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3.0 BACKGROUND
(Cont'd)
TUEC had prepared administrative controls to address the review and approval process in preparation of Ats request to defer seven preoperational tests,to NRC-NRR.
Formal approval of this request was received in NRC-NRR letters dated June 19, and August-17, 1984.
The processing of this request was in accordance with Station Administrative Procedure STA-805, " Deferred Preoperational Testing," which is briefly described as follows. During this process, technical specification requirements are evaluated and the need for technical specification exceptions considered. The evalostion addresses the operability requirements of the technical specifications and the impact of incomplete preoperational testing on equipment operability. The required plant conditions for conduct.ing deferred preoperational tests are assessed against the CPSES technical spacifications including the limiting conditions for operation.
Subsequently, TUEC plarned a second heatup to operating pressure and temperature and would attempt to complete the deferred s
preoperational testing before fuel load. In correspondence dated September 30, 1985 to NRC-NRR, TUEC reported the results of the second plant heatup conducted during the interval from October 1r.84 to January 1985 in which the deferred preoperational tests were performed. Although many of the individual testing items were completed, there remain four items open pending completion of satisfactory testing and one item open pending NRC approval of a proposed technical specification change.
4.0 CPRT ACTION PLAN Although TUEC has five remaining open items in the current NRC-approved preoperational test deferral, the methods by which TUEC identifies and obtains NRC approval for technical specification deviations is, in the judgment of the CPRT, adequate 4
to address the concerns identified by the NRC-TRT.
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