ML19325E360

Forwards Addl Info Re Application for Amend to Licenses NPF-11 & NPF-18,revising Tech Specs to Conform W/Diesel Generator Test Schedule Recommendations,Per Generic Ltr 84-15

ML19325E360
Person / Time
Site:	LaSalle
Issue date:	10/26/1989
From:	Morgan W COMMONWEALTH EDISON CO.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML19325E361	List: ML19325E360 ML19325E365
References
0328T, 328T, GL-84-15, NUDOCS 8911060330
Download: ML19325E360 (4)

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[ 72 West Adams Street, Chicayo, Illific!sAdd[(iiMpWETOff~ci BoiT67~

. %/ : Chicago, Illinois 60690 0767 r

/ October 26, 1989 yn I Dr. Thomas E. Murley.. Director Office of Nuclear Reactor Regulation U.S; Nuc'vear Regulatory Commission Nashington, DC 20555 f

Subject:

LaSalle County Station Ur.its 1 and 2 Supplement to Application for Amendment to facility Operating Licenses NPF-11

' and NPF-18, Technical Specification -

Implementation of Generic Letter 84-15 Diesel Generator Recommendations NRC Docket Nos. 50-373 and 50-374 L

h References (a): H.E. Morgan letter to U.S NRC dated e

March 16, 1989, Application for.

l Amendment to FOL NPF-11 and NPF-18  ;

l (b): H.E.'Horgan letter to T.E. Hurley dated June 23, 1989, Supplement to Application for Amendment to FOL NPF-11 and NPF-18 h

Dertr Dr. Hurley:

l' Reference (a) submitted Commonwealth Edison's request for an l amendment to facility Operating Licenses NPF-11 and NPF-18, Appendix A, ,

L -Technical Specifications. The purpose of this amendment request was to revise  !

the Technical Specifications to conform with the diesel generator test ,

schedule recommendations given in NRC Generic Letter 84-15.  ;

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, Subsequent to this request, Ccmmonwealth Edison had become aware that

, ..the guidance in Generic Letter 84-15 could be extended to include changes to I the Technical Specification which would further increase the reliability of the diesel generators by eliminating unnecessary surveillance requirements. 1 These changes were submitted in Reference (b). i E911060330 s91026 } l PDR ADOCK 05C00373 4 P PNV j )

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v. Dr. T.E. Murley October 26, 1989 1

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.L Per your staff's recommendation, Com'nonwealth Edison is supplementing its originel amendment request to include additional changes which could

! further enhance diesel generator reliability.

The following attachments provide the supplement to the original proposed amendment request. Attachment A contains background information and justification for the proposed change. Attachment B contains the proposed '

changes to the Technical Specifications. The proposed Technical Specification L changes have been reviewed and approved by both On-Site and Off-Site Review in accordance with Commonwealth Edtson Company procedures.

He have reviewed this amendment in accordance with 10 CFR 50.92(c) and have determined that no significant hazards consideration exists. Our evaluation is documented in Attachment C.

Please direct any questions you may have regarding this matter to this office.

Very truly yours, Wayne . Morgan Nuclear Licensing Administrator Im l

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l Attachments cc: A.B. Davis - Regional Administrator, Region III Senior Resident Inspector - LaSalle County P.C. Shemanski - Project Manager, NRR Office'of Nuclear facility Safety - IDNS l

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1 SEEC1ELCA110N CHANGE RE@ESI  !

LASALLE_COURILSJATION UNITS 1 AND 2 1

l BACEGBQUND j On March 16, 1989, Commonwealth Edison submitted a request (Reference j (a)) to the NRC to upgrade the LaSalle Station Technical Specifications to i meet the-recommendations of Generic Letter 84-15. Subsequent to the LaSalle  !

. Station Technical Specification amendment request submittal, Commonwealth Edison became aware that the guidance in Generic Letter 84-15 could be extended to include changes to the. action statements for Specification 3/4.8.1.1 which could further enhance diesel generator reliability.

The AC sources specifica-  !

tion was rewritten to limit the number of diesel generator starts resulting ,

from application of the action statement requirements. Following review of l the second submittal (Fleference (b)), the NRC requested further changes which  !

are the subject of this documeret.

The amendments to the Technical Specifications proposed in Reference (b) were patterned after the Clinton Station Technical Specifications. As required by.the Clinton Station Technical Specification requirements, the demonstration of diesel generator operability is shown by starting and loading the diesel generator in accordance with Specifications 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5,-respectively. This differs from the current LaSalle Station ,

specifications which only requires the diesel generator to be started in accordance with 4.8.1.1.2.a.4. The NRC has requested that we amend our a submittal.to leave this aspect of the LaSalle specification unchanged.

DISCUS 112:

It is assumed _that the reason for testing all operable emergency diesel generators following a failure of one of the units to start or load, is to detect a generic' problem affecting other units. In accordance with the action requirements of the Technical Specifications, the diesel generators are ,

only started and not loaded. It is possible that generic failures of components, such as the generator or:the generator output breaker, could potentially remain undetected. This was the basis for adding the loading

. requirement (Specification 4.8.1.1.2.a.5) to the LaSalle Station action requi rt. ment s . Upon recommendations from the NRC Staff, the proposed amendment submitted in Reference (b) has been revised to remove the action requirement for. loading the diesel generators.

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All diesel generator failures are thoroughly investigated by the l station. Corrective action and action to prevent re-occurrence of a problem are taken as necessary to ensure the operability of.the diesel generators. To ensure that the testing conducted in accordance with the Technical Specification action requirements, following a diesel generator failure to J start or load is adequate; the station procedures will be revised to require that the station technical staff perform an evaluation of this testing, after i the root cause of the failure is discovered. This evaluation will:

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1. determine if the initial testing reo" ired by the Technical Specifications I was adequate to detect any potentiti generic failures in the other diesel gcnerator units; and

2. make recommendations for any additional testing necessary to ensure diesel  :

generator operability.

When feasible, additional testing recommended by the evaluation will be conducted. This testing may not require operation of the diesel generators.

Two additional Action statements have been added to this submittal to cover the following situations:

1. The Olvision 3 diesel generator and the opposite unit Division 2 diesel generator are inoperable. This statement directs the operator to apply the requirements of Actions d and g.

2. The Division 1 diesel generator and the Division 2 diesel generator of the opposite unit are inoperable. This statement directs the operator to apply the requirements of Actions b and g.

Also included in this submittal are some proposed ainendments to the Technical Specification Bases which provide additional guidance to the operators for application of the action statements.

In the original submittal to the NRC it was requested under Additional Administrative Changes (Attachment C, page 4, Paragraph 1, Reference (a)) that the footnote at the bottom of pages 3/4.8-1 and 3.4.8-la be deleteu from the Technical Specifications. This request was made in error and both items identified in Paragraph 1 must remain in the Technical Specifications. It is, therefore, requested that the paragraph referenced above be deleted from the original submittal.

SUltBPl The proposed changes to the Technical Specifications are contained in Attachment B of this document. The proposed amendments will help to improve diesel generator reliability by minimizing the number of diesel generator starts required by the Technical Specification actions statements. Based on the above discussion, it is requested that the Technical Specifications be amended to include the proposed amendments contained in Attachment B and that the original submittal (Reference (a)) be amended as indicated above.

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