ML20213D586

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Forwards Listing & Description to Support Deferral of Limited Aspects of Initial Test Program.All Preoperational Tests Listed in Attachment a Completed & Test Results Approved
ML20213D586
Person / Time
Site: Byron Constellation icon.png
Issue date: 11/03/1986
From: Ainger K
COMMONWEALTH EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
2336K, NUDOCS 8611120151
Download: ML20213D586 (9)


Text

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.E One First Nemonal Plaza, Chca00, Illinois '

Address Reply to: Post Omos Box 767 Ches00, Illinois 80U30 0767 November 3, 1986 Mr. Harold.R. Denton, Director Office of Nuclear Reactor Regulatica U.S. Nuclear Regulatory Commission Washington,.DC 20555 g

Subject:

Byron Station Unit 2 Deferral of Limited Aspects of the Initial Test Program NRC Docket No 50-455 i Reference (a): October 1, 1986 letter from D. L. Farrar to-H. R. Denton  ;

Dear Mr. Denton:

Reference (a) transmitted a request for schedular relief for a few items contained in the Byron Unit 2. Initial Test Program. Since October 1, 1986, significant additional progress has been made to complete items for-which schedular relief was requested.

i .

. .All preoperational tests listed in Attachment A of reference (a)

[ have been completed and the test results have been approved. However, for seven systems, minor deficiencies remain which will require some retesting.

These systems, a description of the deficiencies, and schedules for

completing retesting are contained in Attachment A of this letter. Most of these items were described in reference (a). For two of these items, the schedular relief has been extended beyond what was previously requested.

Two additional deferral items have been identified and they are discussed in the attachment, also. It is our understanding that the Technical Specifications for Byron Unit 2 will contain a temporary specification to address interim operation of the auxiliary building ventilation system as discussed in Attachment B of reference-(a).

l One of the systems listed in Attachment A is the essential water system. Preoperational testing to date has demonstrated the capability of the system to handle design basis accident heat loads under limited

. atmosphuic conditions. Additional information is required to demonstrate i

8611120151 861103 PDR A

ADOCK 05000455 PDR B oo t L(i

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O Mr. H. R. Denton November 3, 1986 the capability of the system under full design' basis conditions. Attachment-B of this letter details the current capability of the system and contains a proposed license condition to govern operation of Byron Unit 2 in the interim.

One signed original and fifteen copies of this letter and attachment are provided for NRC review.

Please direct any questions regarding this matter to this office.

Very truly yours,

) b K. A. Ainger Nuclear Licensing Administrator la Attachment cc: Byron Resident Inspector l

2336K

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ATTAOSENT A SYSTEMS WITH TEST RESULTS APPROVED - MINOR DEFICIENCIES REMIAN DEFICIENCY TECH SPEC COPFLETION NATURE TEST DESCRIPTION APPLICABILITY REQUIRED OF DEFERRAL STATUS AS OF 10/30/06 SX 76.60 Insufficient data on Mode 4 See Note 1 See Note 1 See Note 1 Essential Service ESW cooling tower Wat:r heat load conditions CV 18.67 Seal injection flow Not applicable Prior to Mode 2 See Note 2 See Note 2 CVCS-IHF indication reverification CV110A valve internals See Note 3 Prior to Mode 1 See Note 3 Waiting for delivery of replacement modification valve trim.

RY 69.67 PZR level and pressure Mode 3 In Mode 3 See Note 4 Instruments have been recalibrated.

Reictcr Coolant indication & controls Perform retest during Mode 3.

Pressurizer - IHF reverification VP 93.61 RCFC flow Mode 3 Prior to Mode 1 See Note 5 See Note 5 Primary Cont. reverification / cooling Vint. - IHF capability evaluation SI 73.63 Leakage of one RCS pressure Mode 2 Prior to Mode 2 See Note 6 Valve seating surface has been repaired.

ECCS Chk Valve isolation check valve not Perforin retest during Mode 3.

Oper. & Leakage less than 1 gpm AF 3.60 Suction pressure return See Note 7 See Note 7 See Note 7 See Note 7 Auxiliary auto-start, retest of dual Feedwater pump start PS,61.60 Letdown heat exchanger, Not applicable See Note 8 See Note 8 See Note 8 Primary Process BTRS domin. sample Sampling flowrates a

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ATTAOSENT A - NDTES -

(1) SX 76.60/ Essential Service Water cooling tower data. Preoperational testing and results review and approval have been completed. Due to insufficient data obtained during the Byron Unit 2 Integrated Hot Functional Testing on ESW cooling tower parameters, additional data was required. Proper heat load conditions on cooling tower (s) are required to obtain this data. These conditions require more stable heat loads -

with sufficient atmospheric conditions. Testing was perfomed on 10/18/96 and was repeated on 10/27/96 using the heat load from Unit One; operation to collect cooling tower operating data. -The data has been analyzed to determine the predicted perfomance of the ESW cooling tower (s). Attachment B of this letter details the predicted perfonnance of the cooling towers based on the testing recently cogleted.

Additional testing may.be required next year, when the outside air temperature is high enough, to collect data to demonstrate the cooling towers will handle full design basis conditions or to provide data for developing long tenn plans. Alternatively, data from operation of-similar cooling towers may be used to demonstra % proper operation of the Byron cooling towers under full. design basis conditions. The assential service water pump discharge tageratures were demonstrated to be less than the values specified in Technical Specification 3.7.5.d.

Therefore, no relief from Technical Specification 3/4.7.6 (Mode 4 requirements) is required.

(2) CV 18.67/ Chem & Volume Control - IHF. Seal injection flow indication reverificatioq. Preoperational testing and results review and approval have been completed. The post test instrument accuracy checks found that on certain flow indicating instrument units, the cardinal points had drifted and therefore, were out of calibration. The instrument recalibration has been completed, but Mode 3 conditions are required to retake data required of the test. Retesting will be perfonned during Mode 3.

(3) CV 18.67/ Chem. & Volume Control - IHF. Preoperational testing and results review and approval have been completed. . The results evaluation detemined that a modification to the 2CV110A valve internals would optimize automatic operation of the boric acid blender. . Proper manual operation of the blender has been demonstrated. The incorporation of this modification and its associated testing will be perfomed post fuel load in accordance with 10 CFR 50.59. The boron injection flow path from the boric acid storage system to the reactor coolant system has been successfully tested. Therefore, no relief from Technical Specifications 3.1.2.1, 3.1.2.5 and 3.1.2.6 is~ required.

(4) RY 69.67, Pressurizer level and pressure indication and controls reverification. Preoperational testing and results review and approval have been completed. The post test instrument accuracy checks found that at the high range of two instrument units,-the cardinal points had drifted and therefore, were out of calibration. The instrument recalibration has been completed, but Mode 3 pressurizer conditions are required to retake data. The instrument inaccuracies were at points outside the scope of Technical Specification 3/4.3.2 Table 3.3-4 items 1.d and 9.a.

Therefore, no relW from Technical Specification 3/4.3.2 Table 3.3-3 items 1.d and 9.a (Mode 3 requirements) is required. Retesting will be perfonned during Mooe 3.

(5) VP 93.61, RCFC flow reverification / cooling capability evaluation. Preoperational testing and results review and approval have been completed.

RCFC perfonnance testing was perfonned during Integrated Hot Functional testing. The results evaluation found that fan flow data required retesting. Restesting to provide additional fan flow data was perfonned without nonnal plant operating conditions. The predicted perfonnance' at FSAR design conditions was marginally below the required values, but was accepted as having no significant impact. Reverification of contalrunent cooling capability will be perfonned or an appropriate FSAR change will be submitted prior to Mode 1. The retesting, if perfonned, requires Mode 3 operating conditions. The primary containment average air temperature during IHF testing was demonstrated to be less than 120*F. Therefore, no relief from Technical Specification 3/4.6.1.5 is required. Additionally, all RCFC fans were demonstrated to operate.

Therefore no relief from Technical Specification 3/4.6.2.3 is required.

v.

ATTAQWENT A - NOTES Cont'd (6) SI 73.63, Valve 25189480 leakage not less than or equal to 1 gpm. Valve 25189480 is a reactor coolant system (RCS) pressure isolation check valve. The valve was tested for leakage at RCS operating pressure and tagerature during the Unit 2 integrated hot functional test. Leakage

.was greater than I gpm. The valve seating surface has been repaired subsequent to hot functional testing. Mode 3 plant conditions are required to establish the necessary parameters for testing. Technical Specification 4.4.6.2.2 requires all RCS pressure isolation valves to be t:sted for leakage prior to entering Mode 2. The retest will be co gleted in Mode 3.

(7) AF 3.60, Auxiliary Feedwater, retest of dual pug start and suction pressure return autostart. As a result of a preoperational test deficiency, modifications have been installed on the AFW pump suction lines from the condensate storage tank. Modifications consisted of piping configuration changes and changes to suction pressure instrumentation. The piping configuration changes have been coupleted and the suction-pressure instrumentation changes are underway with completion dependent on deliveries scheduled for week ending'11/7. A retest to verify cutostart upon return of a loss of adequate suction pressure will be perfomed upon completion of modification to instrumentation, prior to Mode 3. The final test of the piping configration modification will consist of a dual pump start during heatup prior to initial criticality.

The steam generators will be at a no load pressure and temperature condition for this test. Testing at cold conditions, simulating steam generator back pressure, has been successfully completed. The retesting will be perfomed during Mode 3 conditions. The auxiliary feedwater pump (s) discharge pressure and flow were demonstrated to be greater than the values specified in Technical Specification 4.7.1.2.1. Therefore, no relief from Technicai Specification 3/4.7.1.2 (Mode 3 requirements) is required. The retest will be perfomed in combination with Technical Specification survelliance requirement 4.7.1.2.2 which is required prior to entering Mode 2.

(8) PS 61.60, Letdown heat exchanger, BTRS domin. sample flowrates. Preoperational testing and results approval have been coupleted. To correct minor test deficiencies, modifications were made to increase the flowrates of the. letdown heat exchanger and the boron thennal regeneration domineralizer outlet sample paths. Retesting of the letdown' heat exchanger sample path will be perfomed prior to Mode 2. Retesting of the boron themal regeneration domineralizer sample path will be perfonned when equipment is placed into service.

2336K M

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m ATTACHMbfT B The Byron Essential Service Water System contains two 100%

' redundant cooling towers. Each individual cooling tower consists of four cells. Thus, a total'of eight individual cells are available for cooling.

The licensing basis was to assume the loss of one four-cell cooling tower as a result of passive failure and one additional cell in the other cooling tower due to a tornado borne missile.

The manufacturer's original rating for each of the Byron ESW cooling towers is 1040 million BTU's per hour. Modifications to the towers for missile protection have apparently reduced the rating for each tower to about 570 million BTU's per hour with a wet bulb temperature of 78'F. This information is a result of recent preoperational testing.

This testing conducted for-the Byron towers has resulted in the development of Figure 1, attached, which depicts the tower performance. The curve _ relates tower capacity to ambient wet bulb temperature for three and four cell operation. The design basis heat load for one unit undergoing a LOCA and one unit in hot shutdown is also shown. This hee.t load peaks at about 580 million BTU's per hour.

This data supports the following modes of operation. With one unit in operation, and the other unit in cold shutdown and four ESW tower cells available (no tornado warning in effect), the original licensing basis wet bulb temperature of 78 degrees is met and no operational restriction is necessary. With two units in operation and four ESW cooling tower cells available (no tornado warning) one unit would be placed in hot shutdown if the wet bulb temperature exceeded 77.5'F. If a tornado warning were in effect such that it could be postulated that only three cooling tower cells were available with two units operating, both units would be placed in hot shutdown if the wet bulb temperature exceeded 67.8'F.

The plant operating procedures will be changed to reflect this Proposed mode of operation. The procedures will also be changed to control cooling tower fan operation in relation to inlet basin water temperature.

Table 1, attached, reflects the logic diagram supporting the above proposed modes of operation.

This proposed restricted mode of operation is required because warm weather conditions are needed to properly test the cooling towers. In addition, a higher heat load to the tower may be needed to do additional confirmatory testing. Although we believe the additional confirmatory testing will show that the towers perform better than the curve now indicates, some modifications may be necessary to achieve design performance.

The proposed method of operation provides an adequate safety margin for plant operation because all safety bases are met with up to five of the eight cooling tower cells unavailable, and because of the cold weather operation forthcoming in the next few months.

l

The following license condition is proposed: Prior to initial criticality, the licensee shall determine the capability of the essential service water system to handle design basis accident heat loads for operation of Byron Units'l and 2 under limited atmospheric conditions.

Additional information shall be provided to the NRC staff to determine system capability under design basis atmospheric conditions prior to operating above those limited atmospheric conditions.

l 2336K

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