RS-11-036, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation.
| ML110960216 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/04/2011 |
| From: | Hansen J Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-11-036 | |
| Download: ML110960216 (24) | |
Text
n n
Nuclear Nuclear RS-11-036 RS-11-036 10 CFR 10 CFR 50.90 50.90 April 4, April 4, 2011 2011 U. S.
U. S. Nuclear Nuclear Regulatory Regulatory Commission Commission Attn: Document Control Attn: Document Control Desk Desk Washington, DC Washington, DC 20555-0001 20555-0001 LaSalle County Station, LaSalle County Station, Units Units 1 1 and and 2 2 Facility Operating Facility Operating License License Nos.
Nos. NPF-11 NPF-11 and and NPF-18 NPF-18 NRC Docket NRC Docket Nos.
Nos. 50-373 50-373 andand 50-374 50-374
Subject:
Subject:
License Amendment Request License Amendment Request forfor Adoption Adoption of of Technical Technical Specifications Specifications Task Task Force (TSTF)
Force (TSTF) Traveler Traveler TSTF-514, TSTF-514, Revision Revision 3, 3, "Revise "Revise BWR BWR Operability Operability Requirements and Requirements and Actions Actions for for RCS RCS Leakage Leakage Instrumentation" Instrumentation" In accordance In accordance with with 1010 CFR CFR 50.90, 50.90, "Application "Application forfor amendment amendment of of license, license, construction construction permit, permit, or early site or early site permit,"
permit," Exelon Exelon Generation Generation Company, Company, LLC LLC (EGC)(EGC) is is submitting submitting a a request request for for an an amendment to amendment to the the Technical Technical Specifications Specifications (TS)(TS) ofof Facility Facility Operating Operating License License Nos.
Nos. NPF-11 NPF-11 andand NPF-18 for NPF-18 for LaSalle LaSalle County County Station, Station, Units Units 11 and and 2 2 (LSCS).
(LSCS).
The proposed amendment The proposed amendment would would revise revise the the TS TS toto define define a a new new time time limit limit for for restoring restoring inoperable Reactor inoperable Reactor Coolant Coolant System System (RCS)
(RCS) leakage leakage detection detection instrumentation instrumentation to to operable operable status; establish status; establish alternate alternate methods methods of of monitoring monitoring RCS RCS leakage leakage when when oneone or or more more required required monitors are monitors are inoperable; inoperable; andand make make TS TS Bases Bases changes changes which which reflect reflect the the proposed proposed changes changes andand more accurately more accurately reflect reflect the the contents contents ofof the the facility facility design design basisbasis related related to to operability operability of of the the RCS RCS leakage detection leakage detection instrumentation.
instrumentation. These These changes changes are are consistent consistent with with NRC-approved NRC-approved Revision Revision 3 to 3 to TSTFTSTF Improved Improved Standard Standard Technical Technical Specification Specification (STS) (STS) Change Change Traveler Traveler TSTF-514, TSTF-514, "Revise BWR "Revise BWR Operability Operability Requirements Requirements and and Actions Actions for for RCSRCS Leakage Leakage Instrumentation."
Instrumentation." The The availability of availability of this this TS TS improvement improvement was was announced announced in in the the Federal Federal Register Register on on December December 17, 17, 2010, (75 2010, (75 FR FR 79048) 79048) as as part part of of the the consolidated consolidated line line item item improvement improvement process process (CUIP).
(CUIP).
- Attachment 1 Attachment 1 provides provides an evaluation an evaluation of of the the proposed proposed changes.
changes.
- Attachment Attachment 2 2 provides provides the markup pages the markup pages of of existing existing TS TS toto show show thethe proposed proposed changes.
changes.
- Attachment 3 Attachment 3 provides provides the markup the markup pages pages of of the the existing existing TS TS Bases Bases to to show show the the proposed proposed changes.
changes.
- Attachment 4 Attachment 4 provides provides revised (clean) revised (clean) TS TS pages.
pages.
EGC EGC requestsrequests approval approval ofof the the proposed proposed license license amendment amendment by by April April 4,4, 2012, 2012, with with the the amendment being amendment being implemented implemented within within 60 60 days.
days.
U. S.
U. S. Nuclear Nuclear Regulatory Regulatory Commission Commission April 4, 2011 April 4, 2011 Page 2 Page 2 In accordance In accordance with with 1010 CFR CFR 50.91(a)(1),
50.91(a)(1), "Notice "Notice for for Public Public Comment,"
Comment," the the analysis analysis about about the the issue issue of of no no significant significant hazards hazards consideration consideration using using the the standards standards in in 10 10 CFR CFR 50.92 50.92 isis being being provided to provided to the the NRC.
NRC.
The proposed amendment The proposed amendment has has been been reviewed reviewed by by the the LSCS LSCS Plant Plant Operations Operations Review Review Committee and Committee and approved approved by by the the Nuclear Nuclear Safety Safety Review Review BoardBoard inin accordance accordance withwith the the requirements of requirements of the the EGC EGC Quality Quality Assurance Assurance Program.
Program.
EGC is EGC is notifying notifying thethe State State of of Illinois Illinois of of this this application application forfor aa change change to to the the TS TS byby sending sending a a copy copy of this letter of this letter and and itsits attachments attachments to to the the designated designated State State Official Official in in accordance accordance withwith 10 CFR 10 CFR 50.91, 50.91, "Notice "Notice forfor public public comment; comment; State State consultation,"
consultation," paragraph paragraph (b).(b).
There are There are no no regulatory regulatory commitments commitments contained contained within within this this letter.
letter. Should Should you you have have any any questions concerning this questions concerning this letter, letter, please please contact contact Mitchel Mitchel Mathews Mathews at at (630)
(630) 657-2819.
657-2819.
II declare declare under under penalty penalty of of perjury perjury that that the the foregoing foregoing is is true true and and correct.
correct. Executed Executed on on the the 4th 4th day day of April of April 2011.
2011. : : Evaluation of Evaluation of Proposed Proposed Changes Changes Attachment : 2: Markup Markup pagespages of of existing existing TS TS to to show show thethe proposed proposed changes.
changes. : : Markup pages Markup pages of of existing existing TS TS Bases Bases to to show show thethe proposed proposed changes.
changes. : : Clean TS Clean TS Pages Pages cc:
cc: Illinois Emergency Illinois Emergency Management Management Agency Agency -- Division Division of of Nuclear Nuclear Safety Safety
ATTACHMENT 1 ATTACHMENT 1 Evaluation of Proposed Evaluation of Proposed Changes Changes
Subject:
Subject:
License Amendment Request License Amendment Request for for Adoption Adoption of of TSTF-514, TSTF-514, Revision Revision 3, 3, "Revise "Revise BWR Operability BWR Operability Requirements and Actions Requirements and Actions for for RCS RCS Leakage Leakage Instrumentation" Instrumentation" 1.0
1.0 DESCRIPTION
DESCRIPTION 2.0
2.0 PROPOSED CHANGE
S PROPOSED CHANGES 3.0
3.0 BACKGROUND
BACKGROUND 4.0
4.0 TECHNICAL ANALYSIS
TECHNICAL ANALYSIS 5.0 5.0 REGULATORY SAFETY REGULATORY SAFETY ANALYSIS ANALYSIS 5.1 5.1 No Significant No Significant Hazards Hazards Consideration Consideration Determination Determination 5.2 5.2 Applicable Regulatory Applicable Regulatory ReqUirements/Criteria ReqUirements/Criteria 6.0
6.0 ENVIRONMENTAL CONSIDERATION
ENVIRONMENTAL CONSIDERATION 7.0
7.0 REFERENCES
REFERENCES Page 1 Page 1 of of 7 7
ATTACHMENT ATTACHMENT 1 1 Evaluation of Evaluation of Proposed Proposed Changes Changes 1.0
1.0 DESCRIPTION
DESCRIPTION The proposed amendment The proposed amendment would would revise revise thethe Technical Technical Specifications Specifications (TS) (TS) to to define define a a new new time time limit for limit for restoring restoring inoperable inoperable ReactorReactor Coolant Coolant SystemSystem (RCS) (RCS) leakage leakage detection detection instrumentation instrumentation to operable to operable status; status; establish establish alternate alternate methods methods of of monitoring monitoring RCS RCS leakage leakage when when one one or or more more required monitors required monitors are are inoperable inoperable and and make make conforming conforming TS TS Bases Bases changes.
changes. These These changes changes are are consistent with consistent with NRC-approved NRC-approved Revision Revision 3 3 to to Technical Technical Specification Specification Task Task ForceForce (TSTF)
(TSTF)
Standard Technical Standard Technical Specification Specification (STS) (STS) Change Change Traveler Traveler TSTF-514, TSTF-514, "Revise"Revise BWR BWR Operability Operability Requirements and Requirements and Actions Actions for for RCS RCS Leakage Leakage Instrumentation."
Instrumentation." The The availability availability of of this this TSTS improvement was improvement was announced announced in in the the Federal Federal Register Register on on December December 17,201017,2010 (75 (75 FR FR 79048) 79048) as as part of part of the the consolidated consolidated line line item item improvement improvement process process (CUIP).(CUIP).
2.0
2.0 PROPOSED CHANGE
S PROPOSED CHANGES The proposed changes The proposed changes revise revise and and addadd a a new new Condition Condition D D to to TS TS 3.4.7, 3.4.7, "RCS "RCS Leakage Leakage Detection Detection Instrumentation," and Instrumentation," and revise revise thethe associated associated bases.bases. New New Condition Condition D D isis applicable applicable when when the the drywell atmospheric drywell atmospheric gaseous gaseous radiation radiation monitor monitor is is the the only only operable operable TS-required TS-required instrumentinstrument monitoring RCS monitoring RCS leakage, leakage, i.e., i.e., TS-required TS-required particulate, particulate, sump, sump, and and drywell drywell air air cooler cooler condensate condensate flow monitors flow monitors are are inoperable.
inoperable. New New Condition Condition D D Required Required ActionsActions require require monitoring monitoring RCS RCS leakage by leakage by obtaining obtaining and and analyzing analyzing grab grab samples samples of of the the drywell drywell atmosphere atmosphere every every 12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; hours; monitoring RCS monitoring RCS leakage leakage using using administrative administrative means means every every 12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; hours; and and taking taking action action to to restore monitoring restore monitoring capability capability usingusing another another monitor monitor within within 7 7 days.
days.
Additionally, Additionally, the the TS TS Bases, Bases, whichwhich summarize summarize the the reasons reasons for for the the specifications, specifications, are are revised revised to to clarify the clarify the specified specified safetysafety function function for for each each required required instrument instrument in in Limiting Limiting Condition Condition for for Operation (LCO)
Operation (LCO) Bases, Bases, deletedelete discussion discussion from from thethe TS TS Bases Bases thatthat could could be be construed construed to to alter alter the meaning the meaning of of TS TS operability operability requirements, requirements, and and reflect reflect thethe changes changes made made to to TS TS 3.4.7.
3.4.7.
Exelon Generation Exelon Generation Company, Company, LLC LLC (EGC)
(EGC) is is not not proposing proposing variations variations or or deviations deviations from from the the TS TS changes described in changes described in TSTF-514, TSTF-514, RevisionRevision 3, 3, or or the the NRCNRC staffs staffs model model safetysafety evaluation evaluation (SE) (SE) published in published in the the Federal Federal Register Register on on December December 17, 17, 2010 2010 (75 (75 FR FR 79048) 79048) as as part part of of the the CUIP CUIP Notice of Notice of Availability.
Availability.
3.0
3.0 BACKGROUND
BACKGROUND NRC Information NRC Information NoticeNotice (IN) (IN) 2005-24, 2005-24, "Nonconservatism "Nonconservatism in in Leakage Leakage Detection Detection Sensitivity,"
Sensitivity,"
dated August 3,2005, dated August 3,2005, informed informed addressees addressees that that the the reactor reactor coolant coolant activity activity assumptions assumptions for for primary containment primary containment atmospheric atmospheric gaseous gaseous radioactivity radioactivity monitors monitors may may be be non-conservative.
non-conservative.
This means This means the the monitors monitors may may not not bebe able able toto detect detect a a one one gallon gallon perper minute minute leak leak within within oneone hour. Some hour. Some licensees, licensees, in in response response to to IN IN 2005-24, 2005-24, have have taken taken action action to to remove remove the the gaseous gaseous radioactivity monitor radioactivity monitor from from thethe TSTS list list of of required required monitors.
monitors. However,However, industry industry experience experience has has shown that shown that the the primary primary containment containment atmospheric atmospheric gaseous gaseous radiation radiation monitor monitor is is often often thethe first first monitor to monitor to indicate indicate an an increase increase in in RCS RCS leak leak rate.
rate. As As a a result, result, the the TSTF TSTF and and thethe NRCNRC staffstaff met met on April on April 29, 29, 2008, 2008, and and April April 14, 14, 2009, 2009, to to develop develop an an alternative alternative approach approach to to address address the the issue issue identified in identified in IN IN 2005-24.
2005-24. The The agreed agreed uponupon solution solution is is to to retain retain the the primary primary containment containment atmospheric gaseous atmospheric gaseous radiation radiation monitor monitor in in the the LCO LCO listlist of of required required equipment, equipment, revise revise the the Page 2 Page of 6 2 of 6
ATTACHMENT 1 ATTACHMENT 1 Evaluation Evaluation of of Proposed Proposed Changes Changes specified safety function specified safety function of of the the gas gas monitor monitor to to specify specify the the required required instrument instrument sensitivity sensitivity level, level, to to revise the revise the Actions Actions requiring requiring additional additional monitoring, monitoring, and and provide provide lessless time time before before a a plant plant shutdown shutdown is required is required whenwhen the the primary primary containment containment atmospheric atmospheric gaseous gaseous radiation radiation monitor monitor is is the the only only operable monitor.
operable monitor.
4.0
4.0 TECHNICAL ANALYSIS
TECHNICAL ANALYSIS EGC has EGC has reviewed reviewed TSTF-514, TSTF-514, Revision Revision 3, 3, and and the the model model SE SE published published on on December December 17, 17, 2010, 2010, (75 FR 79048)
(75 FR 79048) as as part part of of the the CLlIP CLlIP Notice Notice of of Availability.
Availability. EGC EGC has has concluded concluded that that the the technical technical bases presented bases presented in in TSTF TSTF Traveler-514, Traveler-514, Revision Revision 3, 3, and and the the model model SE SE prepared prepared by by the the NRC NRC staff are staff are applicable applicable to to LaSalle LaSalle County County Station, Station, UnitsUnits 1 1 and and 2 2 (LSCS).
(LSCS).
General Design General Design Criterion Criterion (GDC)
(GDC) 30, 30, "Quality "Quality of of Reactor Reactor Coolant Coolant Pressure Pressure Boundary,"
Boundary," of of Appendix Appendix A A toto 10 10 CFR CFR Part Part 50,50, "General "General Design Design Criteria Criteria for for Nuclear Nuclear Power Power Plants,"
Plants," requires requires that means that means be be provided provided for for detecting detecting and, and, to to the the extent extent practical, practical, identifying identifying the the location location of of the the source of source of reactor reactor coolant coolant leakage.
leakage. An An evaluation evaluation against against the the GDC GDC 30 30 isis provided provided in in Section 3.1.2.4.1 Section 3.1.2.4.1 of of the the LSCS LSCS UFSAR.UFSAR.
As discussed in As discussed in Appendix Appendix B B of of the the LSCS LSCS UFSAR, UFSAR, LSCS LSCS is is committed committed to to NRC NRC Regulatory Regulatory Guide Guide (RG) 1.45, (RG) 1.45, "Reactor "Reactor Coolant Coolant Pressure Pressure Boundary Boundary Leakage Leakage Detection Detection Systems,"
Systems," Revision Revision O. O.
NRC RG NRC RG 1.45 1.45 describes describes methods methods acceptable acceptable to to the the NRCNRC to to assure assure thatthat leakage leakage detection detection and and collection systems collection systems provideprovide maximum maximum practical practical identification identification of of leaks leaks within within the the reactor reactor coolant coolant pressure boundary.
pressure boundary. The The LSCS LSCS RCS RCS leakage leakage detection detection systemssystems are are consistent consistent withwith thethe recommendations of recommendations of NRC NRC RG RG 1.45, 1.45, Revision Revision O. O.
The administrative means The administrative means of of monitoring monitoring include include diverse diverse alternative alternative mechanisms mechanisms from from which which appropriate indicators appropriate indicators may may be be selected selected based based on on plant plant conditions.
conditions. As As described described in in Section Section 5.2.5.2 of 5.2.5.2 of the the LSCS LSCS Updated Updated Final Final Safety Safety Analysis Analysis Report Report (UFSAR),
(UFSAR), "Leak "Leak Detection Detection Devices Devices Within Primary Within Primary Containment,"
Containment," EGC EGC utilizes utilizes the the following following diverse diverse methods methods to to detect detect unidentified unidentified leakage at leakage at LSCS:
LSCS: drywell drywell floor floor drain drain sump sump measurement, measurement, drywell drywell equipment equipment drain drain sump, sump, drywell drywell cooler drain cooler drain flow, flow, drywell drywell pressure, pressure, drywell drywell temperature, temperature, drywell drywell airair sampling, sampling, reactor reactor vessel vessel head closure head closure sealseal annulus annulus pressure, pressure, reactor reactor waterwater recirculation recirculation pump pump sealseal flow flow rate, rate, safety/relief safety/relief valve discharge valve discharge piping piping temperature, temperature, and and valve valve packing packing leakage.
leakage.
There There areare diverse diverse alternative alternative methods methods for for determining determining that that RCS RCS leakage leakage has has not not increased, increased, from which from which appropriate appropriate indicators indicators may may bebe selected selected based based on on plant plant conditions.
conditions. EGC EGC will will utilize utilize the following the following method method or or methods methods considering considering the the current current plantplant conditions conditions and and historical historical or or expected sources expected sources of of unidentified unidentified leakage:
leakage: drywell drywell floor floor drain drain sump sump measurement, measurement, drywell drywell equipment drain equipment drain sump, sump, drywell drywell cooler cooler drain drain flow, flow, drywell drywell pressure, pressure, drywell drywell temperature, temperature, drywelldrywell air sampling, air sampling, reactor reactor vessel vessel headhead closure closure seal seal annulus annulus pressure, pressure, reactor reactor water water recirculation recirculation pump seal pump seal flow flow rate, rate, safety/relief safety/relief valve valve discharge discharge piping piping temperature, temperature, valve valve packing packing leakage, leakage, component cooling component cooling water water system system outlet outlet temperatures, temperatures, component component cooling cooling water water system system makeup, reactor makeup, reactor recirculation recirculation system system pump pump seal seal pressure pressure and and temperature, temperature, reactorreactor recirculation recirculation system pump system pump motormotor cooler cooler temperatures, temperatures, drywell drywell cooling cooling fan fan outlet outlet temperatures, temperatures, reactor reactor building chiller building chiller amperage, amperage, and and control control rod rod drive drive system system flange flange temperatures.
temperatures. Actions Actions to to verify verify that these that these indications indications have have not not increased increased since since the the required required monitors monitors became became inoperable inoperable and and Page 3 Page 3 ofof 66
ATTACHMENT 1 ATTACHMENT 1 Evaluation Evaluation of of Proposed Proposed Changes Changes the analysis of the analysis of drywell drywell atmospheric atmospheric grab grab samples samples are are sufficient sufficient to to alert alert the the operating operating staff staff to to an an unexpected increase unexpected increase in in RCS RCS leakage.
leakage.
5.0 5.0 REGULATORY SAFETY REGULATORY SAFETY ANALYSIS ANALYSIS 5.1 5.1 No Significant No Significant Hazards Hazards Consideration Consideration Determination Determination Exelon Generation Company, Exelon Generation Company, LLC LLC (EGC)
(EGC) has has evaluated evaluated the the proposed proposed changes changes to to the the TS TS using using the criteria the criteria in in 1010 CFR CFR 50.9250.92 and and hashas determined determined that that the the proposed proposed changes changes do do not not involve involve a a significant hazards significant hazards consideration.
consideration. An An analysis analysis ofof the the issue issue ofof no no significant significant hazards hazards consideration is consideration is presented presented below:
below:
Description Description of of Amendment Amendment Request: Request: The The proposed proposed amendment amendment would would revise revise TS TS 3.4.7, 3.4.7, "RCS "RCS Leakage Detection Leakage Detection Instrumentation,"
Instrumentation," Conditions Conditions and and Required Required Actions Actions and and thethe licensing licensing basis basis for the for the drywell drywell atmospheric atmospheric gaseousgaseous radiation radiation monitor, monitor, asas well well as as make make associated associated TS TS Bases Bases changes for changes for TS TS 3.4.7.
3.4.7.
Basis for Basis for proposed proposed no no significant significant hazards hazards consideration consideration determination:
determination: As As required required by by 10 10 CFR CFR 50.91(a),
50.91(a), thethe EGCEGC analysis analysis of of the the issue issue ofof no no significant significant hazards hazards consideration consideration using using the the standards in standards in 1010 CFR CFR 50.92 50.92 is is presented presented below:below:
1.
- 1. Does Does thethe proposed proposed changechange involve involve a a significant significant increase increase in in the the probability probability or or consequences consequences of an of an accident accident previously previously evaluated?
evaluated?
Response: No Response: No The proposed change The proposed change clarifies clarifies thethe operability operability requirements requirements for for the the RCS RCS leakage leakage detection detection instrumentation and instrumentation and reduces reduces the the time time allowed allowed forfor the the plant plant to to operate operate when when the the only only TS-TS-required operable required operable Reactor Reactor Coolant Coolant System System (RCS)
(RCS) leakage leakage detection detection instrumentation instrumentation monitor is monitor is the the drywell drywell atmospheric atmospheric gaseous gaseous radiation radiation monitor.
monitor. The The monitoring monitoring of of RCS RCS leakage is leakage is not not aa precursor precursor to to any any accident accident previously previously evaluated.
evaluated. TheThe monitoring monitoring of of RCS RCS leakage is leakage is not not used used to to mitigate mitigate the the consequences consequences of of any any accident accident previously previously evaluated.
evaluated.
Therefore, itit is Therefore, is concluded concluded that that this this change change doesdoes not not involve involve a a significant significant increase increase in in the the probability or probability or consequences consequences of of anan accident accident previously previously evaluated.
evaluated.
2.
- 2. Does the Does the proposed proposed changechange create create the the possibility possibility ofof a a new new or or different different kind kind of of accident accident from from any accident previously any accident previously evaluated?
evaluated?
Response: No Response: No The proposed change The proposed change clarifies clarifies thethe operability operability requirements requirements for for the the RCS RCS leakage leakage detection detection instrumentation and instrumentation and reduces reduces the the time time allowed allowed forfor the the plant plant to to operate operate when when the the only only TS-TS-required operable required operable RCS RCS leakage leakage detection detection instrumentation instrumentation monitor monitor isis the the drywell drywell atmospheric gaseous atmospheric gaseous radiation radiation monitor.
monitor. The The proposed proposed change change doesdoes not not involve involve a a physical physical alteration of alteration of the the plant plant (Le.,
(Le., nono newnew oror different different type type of of equipment equipment willwill be be installed) installed) oror aa change in change in the the methods methods governing governing normal normal plant plant operation.
operation. Therefore, Therefore, itit is is concluded concluded thatthat Page 4 Page of 6 4 of 6
ATTACHMENT ATTACHMENT 1 1 Evaluation of Evaluation of Proposed Proposed Changes Changes the proposed change the proposed change does does notnot create create the the possibility possibility of of aa new new or or different different kind kind ofof accident accident from any from any previously previously evaluated.
evaluated.
3.
- 3. Does the Does the proposed proposed change change involve involve a a significant significant reduction reduction in in a a margin margin of of safety?
safety?
Response: No Response: No The proposed change The proposed change clarifies clarifies the the operability operability requirements requirements for for the the RCSRCS leakage leakage detection detection instrumentation and instrumentation and reduces reduces the the time time allowed allowed for for the the plant plant toto operate operate when when the the only only TS-TS-required operable required operable RCS RCS leakage leakage detection detection instrumentation instrumentation monitor monitor is is the the drywell drywell atmospheric gaseous atmospheric gaseous radiation radiation monitor.
monitor. Reducing Reducing the the amount amount of of time time thethe plant plant isis allowed allowed to operate to operate with with only only the the drywell drywell atmospheric atmospheric gaseous gaseous radiation radiation monitor monitor operable operable increases increases the margin the margin of of safety safety by by increasing increasing the the likelihood likelihood that that anan increase increase in in RCS RCS leakage leakage will will be be detected before detected before itit potentially potentially results results in in gross gross failure.
failure. Therefore, Therefore, it it is is concluded concluded that that thethe proposed change proposed change doesdoes not not involve involve a a significant significant reduction reduction in in aa margin margin of of safety.
safety.
Based upon the Based upon the above above analysis, analysis, EGC EGC concludes concludes that that thethe requested requested changechange does does not not involve a involve a significant significant hazards hazards consideration, consideration, as as setset forth forth in in 10 10 CFR CFR 50.92(c),
50.92(c), "Issuance "Issuance of of Amendment."
Amendment."
5.2 5.2 Applicable Regulatory Applicable Regulatory Requirements/Criteria Requirements/Criteria A description of A description of the the proposed proposed TS TS change change and and its its relationship relationship to to applicable applicable regulatory regulatory requirements were requirements were published published in in the the Federal Federal Register Register Notice Notice of of Availability Availability on on December December 17, 17, 2010 (75 2010 (75 FR FR 79048).
79048). EGC EGC has has reviewed reviewed the the NRC staffs model NRC staffs model SE SE referenced referenced in in the the CUIP CUIP Notice of Notice of Availability Availability andand concluded concluded that that the the regulatory regulatory evaluation evaluation section section is is applicable applicable to to LSCS.
LSCS.
General Design General Design Criterion Criterion (GDC)
(GDC) 30, 30, "Quality "Quality of of Reactor Reactor Coolant Coolant Pressure Pressure Boundary,"
Boundary," of of Appendix Appendix A A to to 10 10 CFR CFR Part Part 50, 50, "General "General DeSignDeSign Criteria Criteria for for Nuclear Nuclear PowerPower Plants,"
Plants," requires requires that means that means be be provided provided forfor detecting detecting and,and, to to the the extent extent practical, practical, identifying identifying the the location location of of the the source of source of reactor reactor coolant coolant leakage.
leakage. An An evaluation evaluation againstagainst the the GDCGDC 30 30 is is provided provided in in Section Section 3.1.2.4.1 of 3.1.2.4.1 of the the LSCS LSCS UFSAR.
As discussed in As discussed in Appendix Appendix B B ofof the the LSCS LSCS UFSAR, UFSAR, LSCS LSCS is is committed committed to to NRC NRC Regulatory Regulatory Guide Guide 1.45, "Reactor 1.45, "Reactor Coolant Coolant Pressure Pressure Boundary Boundary LeakageLeakage Detection Detection Systems,"
Systems," Revision Revision O. O. NRC NRC Regulatory Guide Regulatory Guide (RG)(RG) 1.45 1.45 describes describes methods methods acceptable acceptable to to the the NRC NRC to to assure assure thatthat leakage leakage detection and detection and collection collection systems systems provide provide maximum maximum practicalpractical identification identification of of leaks leaks within within thethe reactor coolant reactor coolant pressure pressure boundary.
boundary. The The LSCS LSCS RCS RCS leakage leakage detection detection systems systems are are consistent consistent with the with the recommendations recommendations of of NRC NRC RG RG 1.45, 1.45, Revision Revision O. O.
Page 5 Page 5 of of 66
ATTACHMENT ATTACHMENT 1 1 Evaluation of Evaluation of Proposed Proposed Changes Changes 6.0
6.0 ENVIRONMENTAL CONSIDERATION
ENVIRONMENTAL CONSIDERATION The proposed change The proposed change wouldwould change change a a requirement requirement with with respect respect to to installation installation or or use use of of a a facility facility component located component located within within the the restricted restricted area, area, as as defined defined in in 10 10 CFR CFR PartPart 20, 20, and and would would change change an inspection an inspection oror surveillance surveillance requirement.
requirement. However, However, thethe proposed proposed changechange does does not not involve involve (i)
(i) a a
significant hazards significant hazards consideration, consideration, (ii)
(ii) a a significant significant change change in in the the types types or or significant significant increase increase in in the amounts the amounts of of any any effluents effluents that that may may be be released released offsite, offsite, oror (iii)
(iii) aa significant significant increase increase inin individual or individual or cumulative cumulative occupational occupational radiation radiation exposure.
exposure. Accordingly, Accordingly, the the proposed proposed change change meets the meets the eligibility eligibility criterion criterion for for categorical categorical exclusion exclusion set set forth forth inin 1010 CFR CFR 51.22(c)(9).
51.22(c)(9). Therefore, Therefore, pursuant to pursuant to 10 10 CFR CFR 51.22(b),
51.22(b), nono environmental environmental impact impact statement statement or or environmental environmental assessment assessment need be need be prepared prepared in in connection connection with with the the proposed proposed change.
change.
7.0
7.0 REFERENCES
REFERENCES 7.1 7.1 TSTF-514 "Revise BWR TSTF-514 "Revise BWR Operability Operability Requirements Requirements and and Actions Actions for for RCS RCS Leakage Leakage Instrumentation," Revision Instrumentation," Revision 33 7.2 7.2 U.S. Nuclear U.S. Nuclear Regulatory Regulatory Commission Commission Model Model Safety Safety Evaluation Evaluation on on the the "Technical "Technical Specification Specification TaskTask Force Force (TSTF)
(TSTF) Change Change TSTF-514, TSTF-514, "Revised "Revised BWR BWR Operability Operability Requirements and Requirements and Actions Actions for for RCS RCS Leakage Leakage Instrumentation,"
Instrumentation," dated dated December December 7,2010 7,2010 Page 6 Page 6 of of 6 6
ATTACHMENT 2 ATTACHMENT 2 LASALLE COUNTY STATION LASALLE COUNTY STATION UNITS 1 UNITS 1 AND AND 22 Docket Nos.
Docket 50-373 and Nos. 50-373 and 50-374 50-374 License License Nos.
Nos. NPF-11 NPF-11 and NPF-18 and NPF-18 Markup Pages Markup Pages of of Existing Existing Technical Technical Specifications Specifications toto Show Show the the Proposed Proposed Changes Changes MARKUP OF MARKUP OF EXISTING EXISTING REVISED REVISED TSTS PAGES PAGES 3.4.7-2 3.4.7-2 New Condition New D Condition D
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation 3.4.7 3.4.7 ACTIONS ACTIONS CONDITION CONDITION REQUI RED REQUI RED ACTION ACTION COMPLETION TIME COMPLETION TIME C.
C. Drywell air Drywell air cooler cooler -- -- -- -- -- -- -- -- -- -- -- -- NOT NOT E E-- -- -- -- -- -- -- -- -- -- -- -- --
condensate condensate flowflow rate rate Not applicable when Not applicable when the the monitoring system monitoring system required drywell required drywell atmospheric atmospheric inoperable.
inoperable. monitoring system monitoring system is is inoperable.
C.1 C.1 Perform SR Perform SR 3.4.7.1.
3.4.7.1. Once per Once per 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> hours
.g.
.g. Requi red Requi red drywell drywell .g.1
.g.1 Restore required Restore required 30 days 30 days atmospheric monitoring atmospheric monitoring drywell atmospheric drywell atmospheric system inoperable.
system inoperable. monitoring system monitoring system to to OPERABLE status.
OPERABLE status.
Drywell ai Drywell ai rr cool cool er er condensate condensate flowflow rate rate .g.2
.g.2 Restore drywell Restore drywell air air 30 days 30 days monitoring system monitoring system cooler condensate cooler condensate inoperable.
inoperable. flow rate flow rate monitoring monitoring system to system to OPERABLE OPERABLE status.
status.
~. Required Action Required Action and and ~.1 Be in Be in MODE MODE 3. 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours associated Completion associated Completion Time of Time of Condition Condition A, A, ot met.
ot met.
~.2 Be in Be in MODE MODE 4. 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 36 hours All required leakage All required leakage 1 1 Enter LCO Enter LCO 3.0.3.
3.0.3. Immediately Immediately detection systems detection systems inoperable.
LaSalle 1 LaSalle 1 and and 22 3.4.7-2 3.4.7-2 Amendment No.
Amendment No. 171/157 171/157
New Condition New Condition D D
ATTACHMENT ATTACHMENT 3 3 LASALLE LASALLE COUNTY COUNTY STATION STATION UNITS UNITS 1 AND 2 1 AND 2 Docket Docket Nos.
Nos. 50-373 50-373 and and 50-374 50-374 License License Nos.
Nos. NPF-11 NPF-11 andand NPF-18 NPF-18 Markup Markup Pages Pages of of Existing Existing Technical Technical Specifications Bases to Specifications Bases to Show the Proposed Show the Proposed Change Change MARKUP MARKUP OF OF EXISTING EXISTING TS TS BASES PAGES BASES PAGES B
B 3.4.7-1 3.4.7-1 B
B 3.4.7-2 3.4.7-2 B
B 3.4.7-3 3.4.7-3 B
B 3.4.7-4 3.4.7-4 B
B 3.4.7-5 3.4.7-5 B
B 3.4.7-7 3.4.7-7
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation B 3.4.7 B 3.4.7 B 3.4 B 3.4 REACTOR COOLANT REACTOR COOLANT SYSTEM SYSTEM (RCS)
(RCS)
B 3.4.7 B 3.4.7 RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation BASES BASES BACKGROUND BACKGROUND GDC 30 GDC 30 of of 1010 CFR CFR 50, 50, Appendix Appendix A A (Ref.
(Ref. 1),
1), requires requires means means for for detecting and, to detecting and, to the the extent extent practical, practical, identifying identifying the the location of location of the the source source ofof RCS RCS LEAKAGE.
LEAKAGE. Regulatory Regulatory Guide Guide (Ref. 2)
(Ref. 2) describes describes acceptable acceptable methods methods for for selecting selecting leakage leakage detection systems.
detection systems.
Limits on LEAKAGE Limits on LEAKAGE from from the the reactor reactor coolant coolant pressure pressure boundary boundary (RCPB) are (RCPB) are required required so so that that appropriate appropriate action action can can bebe taken taken the integrity before the before integrity of of the the RCPB RCPB isis impaired impaired (Ref.
(Ref. 2).
2).
Leakage detection Leakage detection systems systems for for the the RCS RCS are are provided provided toto alert alert the operators the operators when when leakage leakage rates rates above above normal normal background background levels are levels are detected detected andand also also toto supply supply quantitative quantitative measurement of measurement of rates.
rates. TheThe Bases Bases for for LCO LCO 3.4.5, 3.4.5, "RCS "RCS Operational LEAKAGE,"
Operational LEAKAGE," iscuss iscuss thethe limits limits on on RCS RCS LEAKAGE LEAKAGE rates.
rates.
Systems for separating Systems for separating thethe LEAKAGE LEAKAGE ofof an an identified identified source source from an from an unidentified unidentified source source are are necessary necessary toto provide provide prompt prompt and quantitative and quantitative information information to to the the operators operators toto permit permit them them to take to take immediate immediate corrective corrective action.
action.
LEAKAGE from LEAKAGE from the the RCPB RCPB inside inside the the drywell drywell is is detected detected by by atat least one of least one of three three independently independently monitored monitored variables, variables, such such as as air cooler drywell air drywell cooler condensate condensate flow flow rate, rate, sump sump flow flow rate, rate, andand drywell gaseous drywell gaseous and and particulate particulate radioactivity radioactivity levels.
levels. The The primary means primary means of of quantifying quantifying LEAKAGE LEAKAGE inin the the drywell drywell is is the the drywell floor drywell floor drain drain sump sump flow flow monitoring monitoring system.
system.
The drywell floor The drywell floor drain drain sump sump flow flow monitoring monitoring system system monitors monitors the LEAKAGE the LEAKAGE collected collected in in the the floor floor drain drain sump.
sump. This This unidentified LEAKAGE unidentified LEAKAGE consists consists of of LEAKAGE LEAKAGE from from control control rod rod drives, valve drives, valve flanges flanges oror packings, packings, floor floor drains, drains, thethe closed closed cooling water cooling water subsystems, subsystems, and and drywell drywell air air cooling cooling unit unit condensate drains, condensate drains, andand any any LEAKAGE LEAKAGE not not collected collected in in the the drywell equipment drywell equipment drain drain sump.
sump. The The drywell drywell floor floor drain drain sump sump has aa weir has weir level level transmitter transmitter that that supplies supplies floor floor drain drain sump sump fill-up rate fill-up rate flow flow indication indication in in the the main main control control room.
room. The The drywell floor drywell floor drain drain sump sump flow flow monitoring monitoring system system contains contains an an additional method additional method ofof measuring measuring drywell drywell floor floor drain drain sump sump flow flow the use through the through use ofof aa magnetic magnetic flow flow meter.
meter. TheThe flow flow meter meter is is installed on installed on the the piping piping that that runs runs parallel parallel toto the the sump sump pump pump piping. When piping. When in in use, use, the the magnetic magnetic flow flow meter meter measures measures aa (continued)
(continued)
LaSalle 1 LaSalle 1 and and 22 B 3.4.7-1 B 3.4.7-1 Revision Revision ~
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation B 3.4.7 B 3.4.7 BASES BASES BACKGROUND BACKGROUND continuous flow in continuous flow the line in the line andand will will display display aa flow flow rate rate in in (continued)
(continued) the control the control room.
room.
The floor drain The floor drain sump sump has has level level switches switches that that start start and and stop stop the sump the sump pumps pumps when when required.
required. The The sump sump pump pump which which isis selected Lead selected Lead starts starts onon aa high high level level in the sump.
in the sump. TheThe other other pump starts, pump starts, and and aa control control room room alarm alarm isis annunciated, annunciated, if if thethe sump level sump level reaches reaches thethe high-high high-high level.
level. The The pumps pumps stop stop when when low level low level is is reached reached in the sump.
in the sump. A A timer timer starts starts each each time time the first the first sump sump pump pump starts.
starts. A A second second timer timer starts starts when when thethe pump is pump is stopped.
stopped. If If the the pump pump takes takes longer longer than than aa given given time time to pump to pump down down the the sump, sump, or or ifif the the pump pump starts starts too too soon soon after after the previous the previous pumpdown, pumpdown, an an alarm alarm is is sounded sounded in in the the control control room indicating room indicating aa higher higher than than normal normal sump sump fill-up fill-up rate.
rate.
A flow monitor A flow monitor in in the the discharge discharge line line of of the the drywell drywell floor floor drain sump drain sump pumps pumps provides provides flow flow input input to to aa flow flow totalizer, totalizer, which is which is indicated indicated in the control in the control room.
room. TheThe magnetic magnetic flow flow indication also meter indication meter also provides provides an an input input toto the the flow flow totalizer. The totalizer. The totalizer totalizer inputs inputs cancan be be swapped swapped using using hand hand switches located switches located in the Auxiliary in the Auxiliary Electric Electric Equipment Equipment Room Room andand the Reactor the Reactor Building.
Building. Both Both monitors monitors cannot cannot be be used used simultaneously. The simultaneously. The flow flow totalizer totalizer can can bebe used used toto quantify quantify the amount the amount of of inputs.
inputs.
The drywell air The drywell air monitoring monitoring systems systems continuously continuously monitor monitor the the drywell atmosphere drywell atmosphere for for airborne airborne particulate particulate and and gaseous gaseous radioactivity. A radioactivity. A sudden sudden increase increase of of radioactivity, radioactivity, whichwhich may be may be attributed attributed to to RCPB RCPB steam steam or or reactor reactor water water LEAKAGE, LEAKAGE, is is annunciated in annunciated in the the control control room.room. TheThe drywell drywell atmosphere atmosphere particulate and particulate and gaseous gaseous radioactivity radioactivity monitoring monitoring systems systems are are not capable not capable of quantifying leakage of quantifying leakage rates, rates, but but are are sensitive sensitive enough to enough to indicate indicate increased increased LEAKAGE LEAKAGE rates rates ofof 11 gpm gpm within within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
1 hour. Larger Larger changes changes in in LEAKAGE LEAKAGE rates rates are are detected detected in in proportionally shorter proportionally shorter times times (Ref.
(Ref. 3).
3).
Condensate from the Condensate from the drywell drywell coolers coolers is is routed routed toto the the drywell drywell floor drain floor drain sump sump and and isis monitored monitored by by aa flow flow transmitter transmitter that that provides indication provides indication and and alarms alarms in in the the control control room.
room. This This drywell air drywell air cooler cooler condensate condensate flow flow rate rate monitoring monitoring system system serves as serves as an an added added indicator, indicator, but but not not quantifier, quantifier, of of RCS RCS unidentified LEAKAGE.
unidentified LEAKAGE.
APPLICABLE APPLICABLE A threat of A threat of significant significant compromise compromise to to the the RCPB RCPB exists exists ifif thethe SAFETY ANALYSES SAFETY ANALYSES barrier contains barrier contains aa crack crack that that is is large large enough enough to to propagate propagate (continued)
(continued)
LaSalle 1 LaSalle 1 and and 2 2 B 3.4.7-2 B 3.4.7-2 Revision Revision ~
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation B 3.4.7 B 3.4.7 BASES BASES APPLICABLE APPLICABLE rapidly. LEAKAGE rapidly. LEAKAGE rate rate limits limits are are set set low low enough enough to to detect detect SAFETY ANALYSES SAFETY ANALYSES the LEAKAGE emitted the LEAKAGE emitted fromfrom aa single single crack crack in in the the RCPB RCPB (Refs.
(Refs. 44 (continued)
(continued) an i).
an i). EachEach of of the the leakage leakage detection detection systeffis systeffis inside inside thethe drywell is drywell is designed designed withwith thethe capability capability of of detecting detecting LEAKAGE LEAKAGE less than less than the the established established LEAKAGELEAKAGE rate rate liffiits liffiits and and providing providing appropriate alarffi appropriate alarffi of of excess excess LEAKAGE LEAKAGE inin the the control control rOOffi.
rOOffi. A A control room control room alarm alarm allows allows the the operators operators to to evaluate evaluate thethe significance of significance of the the indicated indicated LEAKAGE LEAKAGE and, and, if if necessary, necessary, shut down shut down the the reactor reactor for for further further investigation investigation and and corrective action.
corrective action. The The allowed allowed LEAKAGE LEAKAGE rates rates are are well well below~
the rates the rates predicted predicted for for critical critical crack crack sizes sizes (Ref.
(Ref. -K-K 55 Therefore, these Therefore, these actions actions provide provide adequate adequate response response before before aa significant break significant break in in the the RCPB RCPB cancan occur.
occur.
RCS leakage RCS leakage detection detection instrumentation instrumentation satisfies satisfies Criterion Criterion 11 of 10 CFR of 10 CFR 50.36(c)(2)(ii).
50.36(c)(2)(ii).
LCD LCD The drywell floor The drywell floor drain drain SUffiP SUffiP flow flow ffionitoring ffionitoring systeffi systeffi is is required to required to quantify quantify the the unidentified unidentified LEAKAGE LEAKAGE froffi froffi the the RCS.
RCS.
Thus, for Thus, for the the systeffi systeffi toto bebe considered considered OPERABLE, OPERABLE, the the floor floor drain SUffiP drain SUffiP fillup fillup rate rate ffionitor ffionitor oror the the ffiagnetic ffiagnetic flow flow ffieter ffieter portion of portion of the the systeffi systeffi ffiUSt ffiUSt bebe OPERABLE.
OPERABLE. The The other other ffionitoring systeffis ffionitoring systeffis provide provide earlyearly alarffis alarffis to to the the operators operators so so closer exaffiination closer exaffiination of of other other detection detection systeffis systeffis will will be be ffiade ffiade to deterffiine to deterffiine the the extent extent of of any any corrective corrective action action that that ffiay ffiay be be required. With required. With the the leakage leakage detection detection systeffis systeffis inoperable, inoperable, ffionitoring for ffionitoring for LEAKAGE LEAKAGE in in the the RCPB RCPB is is degraded.
degraded.
APPLICABI LITY APPLICABI LITY In MODES In MODES 1, 1, 2, 2, and and 3,3, leakage leakage detection detection systems systems are are required required to be OPERABLE to be OPERABLE to to support support LCD LCD 3.4.5.
3.4.5. This This Applicability Applicability is is consistent with consistent with that that forfor LCD LCD 3.4.5.
3.4.5.
ACTIONS ACTIONS With the drywell With the drywell floor floor drain drain sump sump flow flow monitoring monitoring system system inoperable, no inoperable, no other other formform of of sampling sampling cancan provide provide thethe equivalent information equivalent information to to quantify quantify leakage.
leakage. However, However, the the drywell atmospheric drywell atmospheric activity activity monitor monitor andand the the drywell drywell air air cooler condensate cooler condensate flow flow rate rate monitor monitor will will provide provide indications indications of changes of changes in in leakage.
leakage.
(continued)
(continued)
LaSalle 1 LaSalle 1 and and 2 2 B 3.4.7-3 B 3.4.7-3 Revision 22 Revision 22
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation 3.4.7 B 3.4.7 B
BASES BASES ACTIONS ACTIONS With the drywell With the drywell floor floor drain drain sump sump flow flow monitoring monitoring system system (continued)
(continued) inoperable, but inoperable, but with with RCS RCS unidentified unidentified and and total total LEAKAGE LEAKAGE being determined being determined every every 1212 hours0.014 days <br />0.337 hours <br />0.002 weeks <br />4.61166e-4 months <br /> hours (SR (SR 3.4.5.1),
3.4.5.1), operation operation may may continue for continue for 3030 days.
days. TheThe 30 30 day day Completion Completion Time Time ofof Required Action Required Action A.l A.l is is acceptable, acceptable, based based on on operating operating experience, considering experience, considering thethe multiple multiple forms forms of of leakage leakage detection that detection that are are still still available.
available.
With both With both gaseous gaseous and and particulate particulate drywell drywell atmospheric atmospheric monitoring channels inoperable monitoring channels inoperable (i (i .e., the required
.e., the required drywell drywell atmospheric monitoring atmospheric monitoring system),
system), grab grab samples samples ofof the the drywell drywell shall be atmosphere shall atmosphere be taken taken and and analyzed analyzed to to provide provide periodic periodic leakage information.
leakage information. Provided Provided aa sample sample isis obtained obtained and and analyzed every analyzed every 1212 hours0.014 days <br />0.337 hours <br />0.002 weeks <br />4.61166e-4 months <br />, hours, the the plant plant may may continue continue operation operation since at since at least least one one other other form form ofof drywell drywell leakage leakage detection detection (i .e.,
(i air cooler
.e., air cooler condensate condensate flow flow rate rate monitor) monitor) isis available.
available.
The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> The 12 hour interval interval provides provides periodic periodic information information that that is is adequate to adequate to detect detect LEAKAGE.
LEAKAGE.
With the required With the required drywell drywell air air cooler cooler condensate condensate flow flow rate rate monitoring system monitoring system inoperable, inoperable, SR SR 3.4.7.1 3.4.7.1 isis performed performed every every 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> hours to to provide provide periodic periodic information information of of activity activity in the in the drywell at drywell at aa more more frequent frequent interval interval than than the the routine routine Frequency of Frequency of SR SR 3.4.7.1.
3.4.7.1. The The 8 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> hour interval interval provides provides periodic information periodic information thatthat is is adequate adequate to to detect detect LEAKAGE LEAKAGE and and recognizes that recognizes that other other forms forms of of leakage leakage detection detection areare available. However, available. However, this this Required Required Action Action is is modified modified by by aa Note that Note that allows allows this this action action to to be be not not applicable applicable if if the the required drywell required drywell atmospheric atmospheric monitoring monitoring system system is is inoperable. Consistent inoperable. Consistent with with SR SR 3.0.1, 3.0.1, Surveillances Surveillances are are not not required toto bebe performed performed onon inoperable inoperable equipment.
equipment.
Gd required Gd With both the With both the gaseous gaseous and and particulate particulate drywell drywell atmospheric atmospheric monitor channels monitor channels and and the the drywell drywell airair cooler cooler condensate condensate flowflow rate monitor rate monitor inoperable, inoperable, thethe only only means means ofof detecting detecting LEAKAGE LEAKAGE is the is the drywell drywell floor floor drain drain sump sump flow flow monitor.
monitor. This This (continued)
(continued) and 22 LaSalle 11 and LaSalle B 3.4.7-4 B 3.4.7-4 Revision ft Revision ft
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation 3.4.7 B 3.4.7 B
BASES BASES ACTIONS ACTIONS If any If any Required Required Action Action ofof Condition Condition A, A, B,B, C, C, r-D r-D met within the met within the associated associated Completion Completion Time, Time, the the plant plant must must be be brought to brought to aa MODE MODE inin which which the the LCO LCO does does not not apply.
apply. To To achieve this achieve this status, status, thethe plant plant must must be be brought brought to to at at least least MODE 3 MODE 3 within within 1212 hours0.014 days <br />0.337 hours <br />0.002 weeks <br />4.61166e-4 months <br /> hours and and to to MODE MODE 44 within within 3636 hours0.0421 days <br />1.01 hours <br />0.00601 weeks <br />0.00138 months <br />.
hours. TheThe allowed Completion allowed Completion Times Times are are reasonable, reasonable, based based on on operating operating experience, to experience, to reach reach the the required required plant plant conditions conditions in in anan orderly manner orderly manner and and without without challenging challenging plant plant systems.
systems.
With all With all required required monitors monitors inoperable, inoperable, no no required required automatic automatic means of monitoring means of monitoring LEAKAGE LEAKAGE are are available, available, and and immediate immediate plant shutdown plant shutdown inin accordance accordance with with LCO LCO 3.0.3 3.0.3 is is required.
required.
SURVEILLANCE SURVEILLANCE The Surveillances are The Surveillances are modified modified by by aa Note Note toto indicate indicate that that REQUIREMENTS REQUIREMENTS when aa channel when channel isis placed placed in in an an inoperable inoperable status status solely solely forfor performance of performance of required required Surveillances, Surveillances, entry entry into into associated associated Conditions and Conditions and Required Required Actions Actions may may be be delayed delayed forfor up up toto 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br />, provided hours, provided the the other other required required instrumentation instrumentation (the (the drywell sump drywell sump flow flow monitoring monitoring system, system, drywell drywell atmospheric atmospheric monitori ng monitori ng channel, channel, oror the the drywell drywell ai ai rr cool cool er er condensate condensate flow monitoring flow monitoring system, system, as applicable) is as applicable) is OPERABLE.
OPERABLE. Upon Upon (continued)
(continued)
LaSalle 1 LaSalle 1 and and 2 2 B 3.4.7-5 B 3.4.7-5 Revision Revision .f-9.
.f-9.
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation B 3.4.7 B 3.4.7 BASES BASES SURVEI LLANCE SURVEI LLANCE SR SR 3.4.7.3 3.4.7.3 (continued)
(continued)
REQUIREMENTS REQUIREMENTS drywell. The Frequency drywell. The Frequency of of 24 24 months months is is aa typical typical refueling refueling cycle and cycle and considers considers channel channel reliability.
reliability. Operating Operating experience has experience has proven this Frequency proven this Frequency is is acceptable.
acceptable.
REFERENCES REFERENCES 1.
30.
2.
- 2. Regulatory Guide Regulatory Guide 1.45 1.45 3.
3.
4-:-
4-:- GEAP-5620, "Failure GEAP-5620, "Failure Behavior Behavior in in ASTM ASTM A106B A106B Pipes Pipes Containing Axial Through-Wall Containing Axial Through-Wall Flaws,"
Flaws," April April 1968.
1968.
NUREG-75/067, "Investigation NUREG-75/067, "Investigation and and Evaluation Evaluation ofof Cracking Austenitic Stainless in Austenitic Cracking in Stainless SteelSteel Piping Piping of of Boiling Water Boiling Water Reactor Plants," October Reactor Plants," October 1975.
1975.
UFSAR, Section UFSAR, Section 5.2.5.5.2.
5.2.5.5.2. UFSAR ,, S
..rEL.-----,1166 .. UFSAR
..rEL.-----, Sec Ion 52511 ect't'Ion .. .. .. .. .. II 52511 LaSalle 1 LaSalle 1 and and 2 2 B 3.4.7-7 B 3.4.7-7 Revision G-Revision G-
Bases Insert TS Bases TS Insert No.1 No.1 This LCO This LCO requires requires instruments instruments of of diverse diverse monitoring monitoring principles principles to to be be OPERABLE OPERABLE to to provide provide confidence confidence that that small small amounts amounts of of unidentified unidentified LEAKAGE LEAKAGE are are detected detected in in time time toto allow allow actions actions to to place the place the plant plant in in a a safe safe condition, condition, when when RCS RCS LEAKAGE LEAKAGE indicates indicates possiblepossible RCPB RCPB degradation.
degradation.
The LCO The LCO requires requires three three instruments instruments to to be be OPERABLE.
The drywell floor The drywell floor drain drain sump sump monitoring monitoring systemsystem is is required required to to quantify quantify the the unidentified unidentified LEAKAGE LEAKAGE rate from rate from thethe RCS.RCS. Thus, Thus, for for the the system system to to be be considered considered OPERABLE, OPERABLE, either either the the flow flow monitoring monitoring or the or the sump sump levellevel monitoring monitoring portionportion of of the the system system mustmust be be OPERABLE OPERABLE and and capable capable of of determining the determining the leakage leakage rate. rate. TheThe identification identification of of anan increase increase in in unidentified unidentified LEAKAGE LEAKAGE will will be be delayed by delayed by the the time time required required for for the the unidentified unidentified LEAKAGE LEAKAGE to to travel travel to to the the drywell drywell floor floor drain drain sump and sump and it it may may take take longer longer thanthan oneone hour hour to to detect detect a a11 gpm gpm increase increase in in unidentified unidentified LEAKAGE, LEAKAGE, depending on depending on the the origin origin and and magnitude magnitude of of the the LEAKAGE.
LEAKAGE. This This sensitivity sensitivity is is acceptable acceptable for for containment sump containment sump monitor monitor OPERABILITY.
The reactor The reactor coolant coolant contains contains radioactivity radioactivity that, that, when when released released to to the the primary primary containment, containment, can can bebe detected detected by by the the gaseous gaseous or or particulate particulate primary primary containment containment atmospheric atmospheric radioactivity radioactivity monitor.
monitor.
Only one Only one ofof the the twotwo detectors detectors is is required required to to be be OPERABLE.
OPERABLE. Radioactivity Radioactivity detection detection systems systems are are included for included for monitoring monitoring both both particulate particulate and and gaseous gaseous activities activities because because of of their their sensitivities sensitivities andand rapid responses rapid responses to to RCS RCS LEAKAGE, LEAKAGE, but but have have recognized recognized limitations.
limitations. Reactor Reactor coolant coolant radioactivity radioactivity levels will levels will be be low low during during initial initial reactor reactor startup startup and and for for aa few few weeks weeks thereafter, thereafter, untiluntil activated activated corrosion products corrosion products have have beenbeen formed formed and and fission fission products products appear appear from from fuel fuel element element cladding cladding contamination or contamination or cladding cladding defects.
defects. If If there there are are few few fuel fuel element element cladding cladding defectsdefects andand low low levels levels ofof activation products, activation products, it it may may not not be be possible possible forfor the the gaseous gaseous or or particulate particulate primary primary containment containment atmospheric radioactivity atmospheric radioactivity monitorsmonitors to to detect detect a a1 1 gpm gpm increase increase within within 1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> hour during during normal normal operation. However, operation. However, the the gaseous gaseous or or particulate particulate containment containment primaryprimary atmospheric atmospheric radioactivity radioactivity monitor is monitor is OPERABLE OPERABLE when when itit is is capable capable of of detecting detecting a a11 gpm gpm increase increase in in unidentified unidentified LEAKAGE LEAKAGE within 1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> hour given given an an RCS RCS activity activity equivalent equivalent to to that that assumed assumed in in the the design design calculations calculations for for the the monitors (Reference monitors (Reference 6). 6).
An increase in An increase in humidity humidity of of the the drywell drywell atmosphere atmosphere could could indicate indicate the the release release of of water water vapor vapor to to the the drywell. Drywell drywell. Drywell air air cooler cooler condensate condensate flow flow rate rate isis instrumented instrumented to to detect detect whenwhen there there isis an an increase above increase above the the normal normal value value by by 11 gpm.
gpm. The The time time required required to to detect detect a a1 1 gpm gpm increase increase above above the normal the normal valuevalue varies varies basedbased on on environmental environmental and and system system conditions conditions and and maymay take take longer longer than than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
1 hour. This This sensitivity sensitivity is is acceptable acceptable for for drywell drywell air air cooler cooler condensate condensate flow flow rate rate monitor monitor OPERABILITY.
The LCO is The LCO is satisfied satisfied when when monitors monitors of of diverse diverse measurement measurement means means are are available.
available. Thus,Thus, the the drywell floor drywell floor drain drain sump sump monitoring monitoring system, system, in in combination combination with with a a gaseous gaseous or or particulate particulate primary primary containment atmospheric containment atmospheric radioactivity radioactivity monitor monitor and and a a drywell drywell containment containment air air cooler cooler condensate condensate flow rate flow rate monitoring monitoring system, system, provides provides an an acceptable acceptable minimum.
minimum.
TS Bases TS Bases Insert Insert No.2 No.2 0.1. 0.2.
0.1. 0.2. 0.3.1.
0.3.1. and 0.3.2 and 0.3.2 With the drywell With the drywell floor floor drain drain sump sump monitoring monitoring system system and and thethe drywell drywell airair cooler cooler condensate condensate flow flow rate monitoring rate monitoring system system inoperable, inoperable, the the only only means means of of detecting detecting LEAKAGE LEAKAGE is is the the primary primary containment atmospheric containment atmospheric gaseousgaseous radiation radiation monitor.
monitor. A A Note Note clarifies clarifies this this applicability applicability of of the the Condition. The Condition. The primary primary containment containment atmospheric atmospheric gaseous gaseous radiation radiation monitor monitor typically typically cannot cannot detect a detect a1 1 gpm gpm leak leak within within one one hour hour when when RCSRCS activity activity isis low.
low. InIn addition, addition, thisthis configuration configuration does does not provide not provide thethe required required diverse diverse means means of of leakage leakage detection.
detection. Indirect Indirect methods methods of of monitoring monitoring RCS RCS leakage must leakage must be be implemented.
implemented. Grab Grab samples samples of of the the primary primary containment containment atmosphere atmosphere must must be be taken and taken and analyzed analyzed and and monitoring monitoring of of RCS RCS leakage leakage by by administrative administrative means means must must bebe performed performed every 12 every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hours toto provide provide alternate alternate periodic periodic information.
information.
Administrative Administrative means means of of monitoring monitoring RCSRCS leakage leakage include include monitoring monitoring and and trending trending parameters parameters that that may indicate may indicate an an increase increase in in RCS RCS leakage.
leakage. There There areare diverse diverse alternative alternative mechanisms mechanisms from from which which appropriate indicators appropriate indicators may may be be selected selected based based on on plant plant conditions.
conditions. It It is is not not necessary necessary to to utilize utilize all all of these of these methods, methods, but but a a method method or or methods methods should should be be selected selected considering considering the the current current plant plant conditions and conditions and historical historical or or expected expected sources sources of of unidentified unidentified leakage.
leakage. The The administrative administrative methods methods are drywell are drywell floor floor drain drain sump sump measurement, measurement, drywel/
drywel/ equipment equipment drain drain sump, sump, drywell drywell cooler cooler drain drain flow, drywell flow, drywell pressure, pressure, drywell drywell temperature, temperature, drywell drywell airair sampling, sampling, reactor reactor vessel vessel headhead closure closure seal seal annulus pressure, annulus pressure, reactor reactor water water recirculation recirculation pump pump sealseal flow flow rate, rate, safety/relief safety/relief valve valve discharge discharge piping temperature, piping temperature, valve valve packing packing leakage, leakage, component component coolingcooling water water system system outlet outlet temperatures, temperatures, component cooling component cooling water water system system makeup, makeup, reactor reactor recirculation recirculation system system pump pump seal seal pressure pressure and and temperature, reactor temperature, reactor recirculation recirculation system system pump pump motor motor cooler cooler temperatures, temperatures, drywell drywell cooling cooling fanfan outlet temperatures, outlet temperatures, reactorreactor building building chiller chiller amperage, amperage, and and control control rod rod drive drive system system flange flange temperatures. These temperatures. These indications, indications, coupled coupled with with the the atmospheric atmospheric grab grab samples, samples, are are sufficient sufficient to to alert the alert the operating operating staff staff toto an an unexpected unexpected increase increase in in unidentified unidentified LEAKAGE.
LEAKAGE.
The 12 The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hour interval interval isis sufficient sufficient toto detect detect increasing increasing RCS RCS leakage.
leakage. The The Required Required ActionAction provides provides 7 days to 7 days to restore restore another another RCS RCS leakage leakage monitor monitor to to OPERABLE OPERABLE status status to to regain regain the the intended intended leakage detection leakage detection diversity.
diversity. The The 7 7 day day Completion Completion Time Time ensures ensures that that thethe plant plant will will not not bebe operated in operated in aa degraded degraded configuration configuration forfor a a lengthy lengthy time time period.
period.
ATTACHMENT 4 ATTACHMENT 4 LASALLE COUNTY LASALLE COUNTY STATION STATION UNITS 1 UNITS 1 AND AND 22 Docket Nos.
Docket Nos. 50-373 50-373 and and 50-374 50-374 License Nos.
License Nos. NPF-11 NPF-11 and and NPF-18 NPF-18 Revised Technical Revised Technical Specifications Specifications (Clean)
(Clean) Pages Pages REVISED TS REVISED TS PAGES PAGES 3.4.7-2 3.4.7-2 3.4.7-3 3.4.7-3 3.4.7-4 3.4.7-4
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation 3.4.7 3.4.7 ACTIONS ACTIONS CONDITION CONDITION REQU II RED REQU RED ACTI ACTI ON ON COMPLETION TIME COMPLETION TIME C.
C. Drywell air Drywell air cooler cooler -- -- -- -- -- -- -- -- -- -- -- -- NOTE NOTE -- -- -- -- -- -- -- -- -- -- -- --
condensate condensate flow flow rate rate Not applicable when Not applicable when the the monitoring system monitoring system required drywell required drywell atmospheric atmospheric inoperable.
inoperable. monitoring system monitoring system is is inoperable.
C.1 C.1 Perform SR Perform SR 3.4.7.1.
3.4.7.1. Once per Once per 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> hours
-- -- -- -- -- -- -- -- -- -NOTE-
-NOTE- -- -- -- -- -- -- -- -- --
-- 0.1 0.1 Analyze Analyze grab grab samples samples Once per Once per Only applicable when Only applicable when the the of the of the primary primary 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours primary containment primary containment containment containment atmospheric gaseous atmospheric gaseous atmosphere.
atmosphere.
radiation monitor radiation monitor is is the the only OPERABLE only OPERABLE monitor. monitor. AND AND 0.2 0.2 Monitor Monitor RCS RCS LEAKAGE LEAKAGE Once Once perper D.
D. Drywell Drywell floor floor drain drain by administrative by administrative 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours sump monitoring sump monitoring means.
means.
inoperable system inoperable system AND AND 0.3.1 0.3.1 Restore drywell Restore drywell floor floor 77 days days Drywell Drywell air air cooler cooler drain drain sump sump monitoring monitoring condensate flow condensate flow rate rate system to system to OPERABLE OPERABLE monitoring system monitoring system status.
status.
OR OR 0.3.2 0.3.2 Restore Restore drywell drywell air air 77 days days cooler condensate cooler condensate flow rate flow monitoring rate monitoring system to system to OPERABLE OPERABLE status.
status.
(continued)
(continued)
LaSalle 1 LaSalle 1 and and 22 3.4.7-2 3.4.7-2 Amendment No.
Amendment No.
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation 3.4.7 3.4.7 ACTIONS ACTIONS CONDITION CONDITION REQUIRED ACTION REQUIRED ACTION COMPLETION TIME COMPLETION TIME E.
E. Required drywell Required drywell E.1 E.1 Restore required Restore required 30 days 30 days atmospheric monitoring atmospheric monitoring drywell atmospheri cc drywell atmospheri system inoperable.
system inoperable. monitoring system monitoring system to to OPERABLE status.
OPERABLE status.
Drywell air Drywell air cooler cooler condensate flow rate condensate flow rate E.2 E.2 Restore drywell Restore drywell air air 30 days 30 days monitoring system monitoring system cooler condensate cooler condensate inoperable.
inoperable. flow rate flow rate monitoring monitoring system to system to OPERABLE OPERABLE status.
status.
F.
F. Required Action Required Action and and F.1 F.1 Be in Be in MODE MODE 3.
- 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours associated Completion associated Completion Time of Time of Condition Condition A,A, AND AND B, C, B, C, 0, or E 0, or E not not met.
met.
F.2 F.2 Be in Be in MODE MODE 4.
- 4. hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 36 G.
G. All required leakage All required leakage G.1 G.1 Enter LCO Enter LCO 3.0.3.
3.0.3. Immediately Immediately detection systems detection systems inoperable.
LaSalle 1 LaSalle 1 and and 22 3.4.7-3 3.4.7-3 Amendment No.
Amendment No.
RCS Leakage RCS Leakage Detection Detection Instrumentation Instrumentation 3.4.7 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS
-- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- NOT NOT E E-- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- --
When aa channel When channel is is placedplaced in in an an inoperable inoperable status status solely solely for for performance performance of of required Surveillances, required Surveillances, entry entry into into associatedassociated Conditions Conditions and and RequiredRequired Actions Actions may be may be delayed delayed for for up up to to 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> hours provided provided the the other other required required leakage leakage detection detection instrumentation is instrumentation is OPERABLE.
SURVEI LLANCE SURVEI LLANCE FREQUENCY FREQUENCY SR SR 3.4.7.1 3.4.7.1 Perform CHANNEL Perform CHANNEL CHECK CHECK of of required required drywell drywell In accordance In accordance atmospheric atmospheric monitoring monitoring system. system. with with the the Surveillance Surveillance Frequency Frequency Control Program Control Program SR SR 3.4.7.2 3.4.7.2 Perform CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST TEST of of required required In accordance In accordance leakage leakage detection detection instrumentation. instrumentation. with with the the Surveillance Surveillance Frequency Frequency Control Program Control Program SR SR 3.4.7.3 3.4.7.3 Perform CHANNEL Perform CHANNEL CALIBRATION CALIBRATION of of required required In accordance In accordance leakage leakage detection detection instrumentation. instrumentation. with with the the Surveillance Surveillance Frequency Frequency Control Program Control Program LaSalle 1 LaSalle 1 and and 2 2 3.4.7-4 3.4.7-4 Amendment No.
Amendment No.