ML20207Q049

Requests Schedular Relief Until 871001 to Complete Several Items in Initial Test Program,Including Preoperational Integrated Testing of Auxiliary Bldg Ventilation Sys. Temporary Tech Specs Encl

ML20207Q049
Person / Time
Site:	Byron
Issue date:	01/13/1987
From:	Ainger K COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
2587K, NUDOCS 8701210262
Download: ML20207Q049 (6)

Text

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- One First Nemonal Plaza, CNcago, ignois 7 Address Reply to: Post Omco Box 767 V CNce00,luinois80000 0767 January 13, 1987

-Mr. Harold Denton, Director Office of Nuclear Reactor Regulation

. U.S. Nuclear Regulatory .Comunission Washington,.DC 20555

Subject:

Byron Station Unit,2 Auxiliary Building Ventilation System-NRC Docket No. 50-455 References (a): October 1, 1986 letter from D. L. Farrar to H. R. Denton (b): October 24, 1986 letter from S. C. Hunsader to H. R. Denton

Dear Mr. Denton:

Reference (a) transmitted a request for schedular relief for a few items in the Byron Unit 2 Initial Test Program. One of the items which was.

-deferred in reference (a) involved completion of preoperational integrated testing of the auxiliary building ventilation (VA) system. Completion of this testing was deferred until July 1, 1987. . Reference (a) described the functional capability of the installed system and provided a technical justification for operating the plant without the testing completed. A temporary technical specification was proposed to address interim operation of the VA system. Reference (b) described the surveillances of ECCS leakage that would be performed to assure plant operation remains within the bounds of the technical justification for operating the plant without the testing complete.

-At the time completion of the preoperational integrated testing of the VA system was deferred to July 1, 1987, it was fully expected that the

{. construction testing and balancing activities would be completed by

' February 28, 1987. This would have resulted in minimal overlap with the Unit I refueling outage scheduled to begin February 13, 1987. However, installation of unanticipated design modifications to the VA system have caused a delay in completion of testing and balancing activities. At this point in time, it is apparent the testing and balancing activities will not be completed before the Unit 1 outage impacts this work. This will prevent completion of the preoperational integrated testing by July 1, 1987.

The testing and balancing activities will be hindered, and sometimes i stopped, because of the following types of activities that will occur during I

the Unit 1 outage:

1) Miscellaneous building internal boundaries within Unit 1 and common plant areas will'be removed to provide access to equipment for maintenance and modifications. These boundaries include removable floor plugs, removable block walls, penetration seals, etc. These openings will affect air flows and pressure drops and therefore cause delays in obtaining measurements required by the testing and balancing activities. g 8701210262 870113 PDR ADOCK 05000455 }s p PDR

Mr. H. R. Denton January 13, 1987

2) Increased personnel traffic in. Unit 1 and common plant areas and maintenance and modification activities will cause doorways to subcompartments to be open for extended periods of time. These openings will also affect air flows and pressure drops and cause delays in obtaining measurements required by the testing and balancing activites.

3) Installation of additional design modifications (i.e., balancing dampers) may be delayed due to plant conditions during the outage period. The work activities to incorporate these modifications may be restricted by requirements for clean zones for other equipment maintenance / modification activities, or ductwork airf1 ws may not be allowed to be interrupted due to potential airborne radioactive contamination concerns in equipment subcompartments.

Attachment A contains a description of the Unit 2 testing and balancing status as of January 6, 1987. This activity should be completed mid to late April, 1987. The preoperational integrated testing of the VA system will commence upon completion of the construction testing and '

balancing activity. However, due to delays already encountered and further delays expected, we do not expect the preoperational integrated testing to be complete until September, 1987. We therefore request this schedular relief be extended to October 1, 1987. The leakage surveillances. identified in reference (b) will continue to be performed until the preoperational testing has been successfully completed.

Attachment B contains a revised temporary technical specification to address interim operation of the VA system.

The circumstances which resulted in our inability to complete the preoperational integrated testing in the time frame previously expected were not identifiable until sufficient data was obtained from the testing and balancing activities. Under these circumstances, the failure to complete these activities in spite of a good faith effort to do so constitutes special l circumstances justifying the additional relief sought.

Please address any questions regarding this matter to this office.

l very truly yours, l

l K. A. Ainger Nuclear Licensing Administrator l Im 1

cc: W. L. Forney (RIII)

Byron Resident Inspector 2587K

rn ATTAC35ENT A UNIT 2 AUXILIARY BUILDING VENTILATION SYSTEM TESTING AND BALANCING STATUS (1/06/87)

The Unit 2 auxiliary building ventilation system has been divided into 12 supply and exhaust groupings for the purpose of the final integrated balancing. The 4 supply groupings are identified as: S-01, S-02, S-11, and l S-12. The exhaust system consists of: 3 accessible exhaust groupings A-13, A-14, and A-21; 4 non-accessible exhaust groupings N-15, N-16, N-17, and N-18; and 1 fuel handling exhaust group F-00. The testing and balancing status is as follows:

Supply S-01 -

Initial readings complete, testing and balancing (TAB) data evaluated by architect-engineer (A-E), new balancing damper i settings issued by A-E, primary balancing dampers reset, second readings in progress.

S-02 -

Initial readings complete, TAB data evaluated by A-E, new balancing damper settings issued by A-E, primary balancing l dampers reset, second readings in progress.

i

=S-11 -

Initial readings complete, TAB data evaluated by A-E, new balancing damper settings issued by A-E, primary balancing l

dampers reset, second readings complete and under evaluation by A-E for approval.

S-12 -

Initial readings complete, TAB data evaluated by A-E, new balancing damper settings issued by A-E, primary balancing dampers reset, second readings complete and evaluated by A-E, design modification to incorporate additional balancing damper to be issued.

4 4

1 .i i.

Exhaust

- A-13 -

Initial readings complete, TAB data under evaluation by A-E.

A-14 -

Initial readings complete, TAB data under evaluation by A-E.

A-21 -

Initial readings complete, TAB data under evaluation by A-E.

N-15 -

Initial readings complete, TAB data under e"aluation by A-E.

N-16 -

Initial readings complete, TAB data under evaluation by A-E.

N-17 -

Initial readings complete, TAB data under evaluation by A-E.

N-18 -

Initial readings complete, TAB data under evaluation by A-E.

F-00 -

Initial readings complete, TAB data under evaluation by A-E.

} Based on this present status and additional delays expected during the Unit I refueling outage, the completion of the testing and balancing activities should be completed mid to late April 1987.

b l

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2587K

P 9

ATTACHMENT B TEMPORARY TECHNICAL SPECIFICATION PAGE 3/4 7-20 2587K

C PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3) Verifying a system flow rate of 66,900 cfm i 10% through the train and 22,300 cfm 110% per bank through the exhaust filter plenum during operation when tested in accordance with ANSI N510-1980; and

4) Verifying that with the system operating at a flow rate of 66,900 cfm *10% through the train and 22,300 cfm *10% per bank and exhausting :

through the HEPA filter and charcoal adsorbers, the total bypass flow of the system and the damper leakage is less than or equal to 1% when the system is tested by admitting cold DOP at the system intake and the damper leakage rate is determined by either direct measurements or pressure decay measurements at a test pressure of 2 inches of water and the auxiliary building exhaust fans are operating at their ratea flow.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />'of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a repre-sentative carbon sample obtained from each bank of adsorbers of the train in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing cri-teria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, when the average for a methyl iodide penetraticn of less than 1% when tested at a temperature of 30'C and a relative humidity of 70%.

,, d. At least once per 18 months by:

1) Verifying for each filter bank of the train that the pressure i , drop across the combined HEPA filters and charcoal adsorber banks of less than 6.0 inches Water Gauge while operating the exhaust filter plenum at a flow rate of 66,900 cfm 110% through the train and 22,300 cfm 110% per bank; i 2) Verifying that the exhaust filter plenum starts on manual initiation or Safety Injection test signal; and

3) W Verifying that the system maintains the ECCS equipment rooms at a negative pressure of greater than or equal to 1/4 in. Water Gauge relative to the outsice atmosehere during system operation while operating at a flow rate of 66,900 cfm 210% through'the I

I train and 22,300 cfm 10% per bank.

e. After each complete or partial replacement of a HEPA filter bank, by

verifying that the exhaust filter plenum satisfies the in place penetration testing acceptance criteria of less than 1% in accord-ance with ANSI N510-1980 for a 00P test aerosol while operating at a j flow rate of 66,900 cfm 110% through the train and 22,300 cfm 110%

per bank; and

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BYRON - UNITS 1 & 2 3/4 7-20 L

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