ML19345F352

Forwards marked-up Responses to NRC 800203 Questions Re post-accident Sampling,Accident Monitoring Outside Containment & Noble Gas Effluent.Proposed Revisions Will Be Formally Documented in Future Amend to FSAR

ML19345F352
Person / Time
Site:	LaSalle
Issue date:	02/12/1981
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM LOD-81-40-18, NUDOCS 8102170328
Download: ML19345F352 (17)

Text

I I

i Commonwealth Edison Ons First National Plaza. Chicago. Ilhnois Address Reply to: Post Ofhce Box 767 Chicago, Ilknois 60690 February 12, 1981 Mr. B. J. Youngblood, Chief Licensing Branch 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

LaSalle County Station Units 1 and 2 Resolution of Effluent Treatment Systems Branch Questions NRC Docket Nos. 50-373/374 LOD 81-40-18

Dear Mr. Youngblood:

Attached for your review are supplemental materials submitted in response to questions posed by the Effluent Treatment Systems Branch at a meeting of February 3, 1981.

These questions relate to:

1. Post-Accident Sampling (NUREG-0737 Item II.B.3)

2. Accident Monitoring (NUREG-0737 Item II.F.1)

3. Primary Coolant Outside Containment (NUREG-0737 Item III.D.I.1)

4. Q321.20 In a follow-up discussion conducted on February 5, 1981 the quartions posed by the Staff relative to items 1,2 and 4 above were resolved. The appropriate sections of the LaSalle Cou1ty FSAR (Section L.20, L.29 and Q321.20) have been modified to reflect the changes agreed upon in that meeting. A copy of the proposed text revisions are attached.

Also discussed at this later meeting was the applicant's discussion presented in Section L.37 concerning Primary Coolant Leakage Outside Containment. This section has been revised to identify the LaSalle County Administrative Procedure (LAP-100-14) that is followed to perform the necessary leakage monitoring.

In addition clarification of the systems to be monitored is provided in the revision to Section L.37. A copy of the proposed text revisions are attached. It should be noted that a copy of the referenced procedure has previously been provided to facilitate the Staff review.

6 (

8102170 N

+.

Mr. B. J. Youngblood Page Two February 12, 1981 Related to the leakage monitoring program discussed in Section L.37, LaSalle County Station is committed to record all leakage as described in LAP-100-14. At the time Unit I reaches full power operation and before putting the unit into commercial service (approximately 6 months after fuel loading), Commonwealth Edison will submit to the NRC Staff a report of all recorded leakage and all preventative maintenance performed as the direct result of the evaluation of this leakage. The report will also identify general leakage criteria to be applied during the first fuel cycle as the basis for instituting corrective action in the form of preventative maintenance. It is acknowledged that exceedance of these criteria will result in the i ssuance of work orders to take appropriate remedial action as soon as practicable; i.e. at the next scheduled or forced outage of sufficient duration to perform the work. Prior to the start of the second fuel cycle the applicant will revise the general criteria to the extent necessary based on the experience gained during the first operating cycle on Unit 1. These revised criteria will be used as the basis for the long term leakage monitoring program on Units 1 and 2.

The proposed revisions to the FSAR provided as attachments to this letter will be formally documented in a future amendment to the FSAR. If you have any questions on these matters, please direct them to this office.

Very truly yours, L. O. DelGeorge Nuclear Licensing Administrator Attachment cc: NRC Resident Inspector-LSCS

O LSCS-FSAR iT 53 L.29 ADDITIONAL ACCIDENT MONITCRISG INSTRUMENTATION (II . F.1)

FUEL LOAD AND LOK POWER TEST REQUIREMENT:

Provide procedures for estimating noble gas, radiciodine, and particulate release rates if the existing effluent instrumentation goes off the scale.

This requirement shall be met before fuel loading. See , ,g 1;UREG o737 Section IE,f',1. , (

DATED REQUIF iMENT:

Install continuous indication in the control room of the following parameters;

a. Containment pressure from minus 5 psig to three times the design pressure.of concrete containments and four .

times the design pressure of steel containments; s

b. Containment water level in PWRs from (1) the bottom to the top of the containment sump, and (2) the bottom of the containment to a level equivalent to e 600,000 gallons of water; Containment water level in BWRs from the bottom to 5 <

feet above the normal water level of the suppression pool;

c. Containment atmosphure hydrogen concentration f rom 0 ,

to 10 volume percent;

d. Containment radiation up to 108 rad /hr;

e. Noble gas effluent from each potential release point ,

from normal concentrations to 105 pci/cc (Xe-13 3) .

Provide capability to continuously cample and perform onsite /

analysis of the radionuclide and particulate effluent camples.

This instrumentation shall meet the qualification, redundancy, testability and other design requirements of the proposed revision to Regulatory Guide 1.97.

W ,)M44AY 9l 193L.

This4 requirement shall be met by 4;aswasq n gWW See ,

NUREG 0737 ' S ection Ef,1 L l

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d. calibrations via in situ electronic signal uhich simulates 105 R/hr, and calibration capability for lower ran3^ radiatica dose without disconnecting the detector fram the readout module using a calibrated source;

e. energy response of detector is linear 120% from 100 kev to 3 Mev. Energy response of detector installation in thin steel sleeves is linear i 20%

f rom 500 kev to 3 Mev, and logarithmic from 10 ' kev to 500 Kev with maximum attenuation less than a factor '

of 4.

f. Detectors are easily retrievable for replacement, maintenance, and located so as to minimize perscnnel exposure. It is viewed as poor practice to install these detectors uhere they are not easily retrievable for calibratica purpose, and where the rad protection concept of "as low as is reasonably achievable" (ALAFA) is not applied in the design. It is important that these detectors be maintained in the calibrated condition, otherwise paragraph 4.20 of IEEE-279 will be violated.

The Commonwealth Edison design provides the best combination of I detector placement for optinal viewing, case of retrieval for on-line calibration, response to wide range of energy levels (60 kev to 3 MeV) supplemented by sampling to determine what isotope is contributing what p32 entage of the measured dose. The attenuation contribu' ed by the steel sleeves is less than a factor of four. In any installation arrangement, detector readings should he supplemented by sampling to determine which isotopes are contributing to the rad dose readings in order to better assess the interval for potential release to the environment (i.e. , determining- half-life of is,oto@ present) .

l me tectorsb General Atomic, Model RD- k he installation

! of the system will be completed prior to full power operation.

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. /f. /;.!EM.) RADIOLOGICAL NOBLE GAS EFFLUENT MONITdRING Q g* 5/

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i TIbN ' VENT STACK MONITORING SYSTEM 'P

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y A General Atomic Nide Range Noble Gas Monitoring System f has been installed to samole the effluent stream which leaves the LSCS vent stack. Thi$monitorina system has a measurement range fo'r radioactive noble gas concen'trations of lx10-7 faci /cc to lx105 pCi/cc and is designed to meet Class le rec.uirem&nts.

It is also in the process of being qualified to IEEE 323-1974.

Arrangement details for '.his system are shown in Figure 11.5-1, sheets 1 and 2. This systen has the following characteristics:

a) Off-line sampling is provided using existing isokinetic j probe OD18-NOO1 (2 scfm) b) The sys tem has grab sample c,p'hility as reauired by tne "uR::Suse NUREG-0737. The syst em is provided with a grab sample station which is the one that will be used in the interim (if necessary), in # conjunction with the existing stack monitoring system. The interim sampling process is descri ed later in this subsection. (44 c) k Rt. _ _:b i m f

particulate and iodine sample,f' filters areM,d U

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_ " ' _ ' - ' } s grab samplese:- ' ; An Si eq-n m q '.c Sn e' 1 so top 1.c

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- , Pr m analysis e w_g :t in the laboratory. Special multiple 7M rytzd. filhas 88Ma ters are* emoloved MWA'h a _ilt during_ _ high-range c T? self contained radia tion and [e conditions.

a large 471ead 1hield to reduce personnel exposure.

C -- L J c, . s il ne particulate and iodine filters are mounted on a skid which is seoarated from the skid with the detectorsg%' -Yminimize Cnriti

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wyseg::::d readinp 4 the background detectorg and to more accurateli aessenesl the samole concentration.

u s a s.3 d) i) The detector which is used for both low ranae and background subtraction is:

General Atomic Model RD-52 (byNumber ODl8-N514)

Type: Plastic Phosphor R'ange: 1x10-7 f 1x10-1 faci /cc ii) The detector which is used for both mid and high range is:

General Atomiq.Model RD-72 (Mid Range-Tw Number ODlB-N515, High Range fN.; Number OD18-N516)

- IW Type: Cadmium Telluride Range: 3 da1.2x1.33 pCi/cc (Mid Ranga) 1.2xlg$5lx10 lx10- 5 faci /cc (High Range) e) The calibrnion of the detec tors W

'.h_be. conducted at least once per year.

f) The ste.ticn vent stack monitoring, sampling and readouts are powered from Essential Bus Division 1 (135 Y-1). J L. 2'}- 8

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-STANDBY GAS TREltTMENT VENT STACK MONITORING SYSTEM .p42,M.c, i T; . .

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A General Atomic Wide Range Noble Gas Monitoring ystem as been installed ,i the standby gas vent s, tack which is .,hg2rbpe m w sp.

inside the nation vent stack. ThN monitoring system has a measure-ment ragge for radioactive noble gas concentrations of lx10-7 pCi/cc to 1x10 pCi/cc and is designed to meet Class lE requirements. It is also in the process of being qualified to IEEE 323-1974.

Arrangements details for this system are shown in Figure 11.5-1, sheets 1 and 2. This system has the following characteristic,s:' l a) Off-line sampling is provided using new isokinetic probes OD18-N518 (0.06 scfm for high range sampling) and OD18-N519 (2 scfm for low range sampling) .

b) The system has grab sample capability as required by j;M S

• jA NUREG-0737. The system is provided with a grab sample station which is ij.Jentical to the one that will be used in the interim (if ngessary), in conjunction with the existing sta-tion vent stack monitoring system. The interim sampling process is described later in this subsection.

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k &= ~ 2 particulatc and iodine.sanpfeg & @ filters are %p{r,~+oO ed c/, ,Q *CMmiM " ' _ grab samples c- ' ' ;" '

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2 + y-^' D'- isotopic analysis m ip m t in the laboratory. Special multiple filters are empgypf glurirgg,~44 high-range radiation conditio,ns. TMc$d5N d.id6::r

.@ex dt:6 self contained and -nP a large 4 7~ leiad shield to reduce personnel exposure. Sn ~ ,- --Al ** ne par ticula te and iodine filters are mounted on a skid whic1 is separated from the skid with the detectorsy j . 1 '. to minimize v m:n b- -_ m-.

O readings sparthe background detectoro and to more accurately the sample concentration.

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a-a d) i) The detector which is used for both low rang and background substraction is; General Atomic Model RD-52 ( Number OD18-N511)

Type: Plastic Phosphor Range: 'lx10-7 9 x10-1 l

faci /CC y ii) The detector whi .:lf used for both mid-End high-range isa General Atomic ,Acc 1 RD-72 (Mid Range $'a[ Number OD18-N512) and Iligh Range- Number OD18-N513)

Type: Cadmium i'elluride Range: 1.2x10-3 $ 1.2x1.33 pCi/cc (Mid Range) 1x10-l U lx105jaci/cc (Ifigh Range)

,9 e) The calibration of the detectors 9&dWahlre conducted at least once per year.

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{j llV f) The SGTS vent stack nonitorino,samplina and reddouts are k1 vowered from Essential Bus Division 2 (13 6X'-2 ) .

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/y'[/i'he existing F oTS monitors shown in FigureJ ~-y retained JJ O ~'#*/.$Ie low

' ) rang

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m_s h v concentrations; rang ~e of 10 '4g 0-1 jacy'cc.

-'.ij' This system uses existing probe ODIS-N452 12 SCFM) and the samnlinc..

process is described in subsystem 11.5.2 2.2. This sytem has D M P detectors which view the 'carticula:e and iodine filters,.c- - 0 4,++ ~-

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.-6a'sdia noble gas,co W <W(.w'$n'7C on &>.,,tra tion ."~im #de W)M

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i ITEM STATION VENT STACK SGTS VENT STACK s1' gif3.'p ,' , DESCRIPTION JWLL,65JZ3 *MN940RW"-9tf3

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' ,, .2/V a) On-Line or Off-Line Off-Line s L'f Off-Line d J~

b) Grab Sa:aple Provided Provided Capability c) Particulate & Yes Yes Iodine Filters Shielded (Iligh Range) d) Detector Type Low Range Plastic Phosphor Plastic Phosphor High Range Cadmium Telluride Cadmium Telluride e) Calibration Once per Year Once per Year Frequency O f) Pcwer Supply ESS 1 BUS 135 Y-1 ESS2 BUS 136,Y-2 g) Redundancy of No Yes Off-Line Low Range Continuous Particulate &

! Iodine Monitoring

! h) Grab Sample Comes Yes Yes From Same Isokinetic Sample Probe i) Automatically Yes Yes subtracts backaround radiation M W

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-* For each of the above systems, the energy deo sndence .;Wrbc-determined during calibra tion. The monitoring systems, therefore, require only one level of radioactiye gas for each detec tor. Kr-85 and XE-133 at concentrations of 10 /.2Ci/cc and 1000 Ci/cc, will be injected into the monitor for cal 2.bration purposes /_. Then each decada response will be verified using a set of Cs-137 sources.

At the time of pre-opera tional testing, an energy response curve will be run using at least five solid sources of different gamma ener<Jy level s .

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, E'U a c h o f the 43ue, systems has a microprocessor ';hich utilizes digital processi.ng techniques to anulyze the data from the wide range detectors and the digital processing performs background unhtravtion and filtering using readings f rom the low range gas channel . *

..' All monitor readouts of gas concentration and accumulated dose release are provided for each system in the Technical Support Center and the Control Room, continuously during an accident.

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,v. Interim Sampling g pability b Because it is exp(ected that delive-Q of the GA wide-range monitors

,C..:e whRt not be made uhtil April 1981, [.i.b.+eern_7 LSOG.-wi.M implement aninterimsamplinjgprocedure. Ponding installation of the W @ O. N f General Atomics mcynitors, m-t e lowing in,terim . capability is to be used, if necessar . The u.~.$im't-O P,"?T stack monitor with a range of 10-7 10-2 pC/cc will be used in conjunction with a %d grab sgmple cart,which is capable of handlina g ab samples to 10+ pC/cc concentration. Also, the cM ; f - 15 .11 dofSGTS<>'d up ,

monitor with a range of 10-4 to 10+2 ftC/cc for high range noble gas will be used in conjnaction with an identical grab sample cart.

~C.$4Lw.et The in rim sampMn g process Mahl involve 7 capturing a unTiltered .

j sample within a por;able shielded cask. This portab1'e cask n S N W moved to areas of ,109 background radiation for samplp analysis.hl3-M

% rts in the cask tNd be opened to allow for radioaotigty analysis of the sample.

by isotopic analysis,YP Q h isotopgontent

'-'h ofa t%Esample/wif. be determined qualitative and y quantitative measurement of tha radionuclides present in the mix. Decay corrections ui tim

'"L _ made to accountikforciuukhin decay from samoling& time to counting Stamg&s(.aj z$g?.Y~g.j

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The grab sample cart is a 250-pound shielded device for capturing a volume $ gas for c.nalypis dA another location. Thecarthas/fourwheels and is designed to be easily pulled '

'^

along the floor by it9 handle.

Manual valves allow 4 ' ' -

through,4 the cart, ti. r ccwie a volume sample within the cart for analysis. Small ports can be opened in the side shielding to allow for sample analysis minimizing personnel ' exposure. /

E. r1ane Re1 ease Ce1cu1ation Plant release rates are calculated from the isotopic analysis in accordance with the following expression:

Curies Flow (cfm)

• 2.83x104 cc/ft 3 {

Curies /Sec = cc of sample

• e 60 Sec h"Mg min.

where, curie /cc of sample is determined from the isotopic analysis asbeingthefsum of the concentrationsof the measured radionuclides, and the flow is the stack effluent flow rate.

Subsequent plant release rates may be calculated from the effluent monitor readings in accordance with the following expression:

r re dings (CPM)x Cude/Sec xF/M where Curies /Sec = m n cpm curies /Sec is the ratio of the release rate calculated from the isotopic cpm L. ZS-lZ.

L SC5- F5ag nyecomsor si analysis above to the monitor reading when the isotopic analysis sample was taken. The ratio of F/Fi is the ratio of the effluent flow to the ef#1uant flow when the isetopic analysis was taken.

The isotopic analysis of the grab sam'>le will establish the correlation between effluent monitor zaading and plant release rate, f.Radiciodine J and Particulate Effluent Monitoring CP The sampling media 1.I h analyzed in the counting room at LSCS.

Charcoal cartridges will be reverse-blown with air to purge inter-ferring noble gases. In addition, silver-zeolite cartridces are to be used to further reduce noble gas interference. .

. . . s 'b Analysis for lodine N W performed using portable cauipment such as an Eberline portable stable assay meter (SN1-2 )^ or a gam;na spectrometer multichannel analyzer system with a germanium detector.

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AMENDMENT 55 QUESTION 321.20

" Increased Range of Radiation Monitors - Moble Gas Effluent (2.1.8.b Section 1.A and 1.B; Action Plan ll.F.1.a & f).

"It is not clear from the description provided if the increased range monitors are on RE-OD18N001 (station vent) and on RE-OD18N952 (SGTS) as shown on Figure 11.5-1(1) of the FSAR or if they will be in addition to these noble gas ,

station (Units Nos. 1 and 2) monitors. With two shared release points, two high range monitors are required, but only one monitor has been described. Provide additional information on:

1. the type of monitors (inline or offline);

2. method for background radiation correction;

3. capability to obtain radiation readings at least every 15 minutes during an accident; and

4. source of power for the noble gas detectors.

"What provisions have been included with the automatic grab samplers to minimize occupational exposures and to dir.seminate laboratory analyses results to the Technical Support Center and the control room?

" Provide a commitment to install and calibrate the high range monitors prior to the fuel loading date."

RESPONSE .

g [* ge'*h'Y p.

f l The Standby Gas reatment Efflupd t wid range noble-gas monitor ci/1..ush OD18-N518 and I

samples from t' Ielements in time ef f nt line: L OD18-N519. The station-vent-stack wide-range noble-gas monitorM samples from, element ODl8-NOOl in t.e station vent stack. The above mentioned elements are shown on Fig: ll.5-1 (1) of the FSAR.

1) Both he standby-gas nt stack monitor,t( are off-line' JuifeW y

2) Background subtractio/t in bothrpt dbf -gasa and 3vent stack monitorX ir,ordvi'ded by.pgIletectors mounted on the same skid ash,(mid- and high-range detectors.

The subtraction takes place in the RM-J}0 microprocessor

='i,n1 ,cd i msctic_,p M W .

3) Both the standby gas ,d vent stack monitors provide continuous indicatinn# both local 4and in the control room,gt noble gas activi 3 ) l Q 52L,20 -1. /

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4) The stg$dby gas _nonitor is powered from essential bus #p^ c.as the station w+ise vent stack monitor is powered from essential bus 13 5 Y- 1(C'35S D JV M-In order to minimize occupational exposures associated with the automatic grab samplers, additional shielding is provided at each of the,wi,de range monitoring skids.

L&

The41 mplementa tion da te rikZ,?k - ~ - < a--JA January 1, 1982.

Additional in forma tion is included in Section L29 of Appendix L.

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- LSCS-FSAR AMEND.tiENT a5

d. the chemical analysis panel; mD *D ^3'

e. an independent HVAC system; W3 W' "' #

f. a waste system for the HRSS to prevent wholesale contamination of secondary systems cutside the primary containment;

g. pumps to provide drywell sump samples to the liquid sampling panel;

h. valves and piping for the new system; *

i. an independent communication system to the control room; and,

j. controls for the entire system.

The actual sampling panels, the .HVAC system and controls are -

installed at elevation 687 feet 6 inches (upper basement level) and the waste equipment (e.g. , waste pumps, waste tank, etc.) are installed at elevation 663 feet 0 inch (basement level) . The upper basement campling room has shielded access independent from the reactor building proper and will allow removal of post-accident samples without excessive exposure to personnel.

(-

Liquid sampling Subsystem The HRSS liquid sampling panel is capable of sampling;

a. reactor coolant from the discharge side of the recirculation pump in the B recirculation loop;

b. reactor coolant from the discharge side of the residual heat removal heat exchangers ( A and B) ;

c. reactor coolant from the discharge side of- the cleanup nonregenarative heat exchangers before entering the reactor water cleanup demineralizers;

/ q d. reactor coolant from the discharge side of the g reactor water cicanup demineralizers (A, B, and C) ;

~

e. water from the drywell equipment drain sump;

f. water from the drywell floor drain sump; and ht H 5e.s dg.r,,,piater from the ILRSS ank.

. 315) -

In addition to taking the above; mp es for either onsite or offsite analysis the HRSS liquid sample panel is' capable of stripping disolved gases _from a pressurized sample and routing the gases- and the dogassed and depressurized 4 sample to the adjacent chemical analysis panel. The chemi,.ga1 gnalysis panel (7 ( has in-line ph, conductivity, and oxygen analyzers Ionandgaschoromatographscapturesample" bites"2by' met]nd"o#*for tar, lioni,d f alit samples .

%5atic valves operated as part of the sampling / analysis cycle controlled by the instrument.y An analysis for boron concentration if n co. . J .g u ~:.o At .e :ac. u,x..&A.--J A p W*-dgetk Ad'**^+b r h p

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LSCS-FSAR AMENDMENT $6 M[

09*D D A sampling Procram Frequency 6oa 0 -- -

Actual frequency of sampling shall be determined by station vanagement, however, as a minimum the first sample can be taken '

within an hour from the time a decision is made to take a sample, at least one sample per day for the next 7 days, and at least one sample per week thereafter.

The time interval between taking a sample and receipt by plant j management of the results of analysis is less than three hours. l/

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AMENDMENT 55 3!'

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OUESTION 321.22 eu W - u . eb k o

" Post Accident Sampling (2.1.8.a; Action Plan II.B.3).

" Indicate that the new systems for reactor water sam-pling dur-ing an accident will be accessible to the labor-atory and counting facilities. We require that the containment atmosphere be sampled and analyzed, in addi-tion to the direct instrumentation subsystem. Provide the sample location. ,

] " Provide a commitment to install and calibrate the post accident sampling equipment prior to the fuel loading date."

RESPONSE

The High Radiation Sampling Station is accessible by person-

. nel of the laboratory and counting facilities by way of i

the auxiliary building stairs located near column ~15 and row N. To transfer the radioactive samples from the upper basement floor to the ground floor, a portable, battery-powered gantry crane is used to lift the liquid and air sample carts, j',

that contain the radioactive samples, through a hatch locat-ed in the ground floor at column 15 and row R.

The containment atmosphere can be sampled at the same point.

The High Radiation Sampling System (HRSS) chares the same sample location with the post-LOCA Containment Monitoring System-B. Either drywell air or suppression pool air can be sampled by the HRSS by using the shut-off valves for the post-LOCA Containment Monitoring System-B. The controls for these valves are located in the control room.

Item II.B.3 of Appendix L describes the post-accident sample system and provides a commitment to install and have the

system operational prior to full power operation.

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.. J LSCS-FSAR AMENDMENT 54 JANUARY 1981

(

L.37 PRIMARY COCLANT SOURCES OUTSIDE CCNTAINMENT (III.D.l.1) [

i FULL POWER LICENSE RECUIREMENT:

Reduce leakage from systems outside containment that would or i could contain highly radioactive fluids during a serious transient or accident to as-low-as-practical levels, measure  ;

actual leak rate and establish a program to maintain leakage at  !

as-low-as practical levels and monitor leak rates.

This requirement shall be met before issuance of a full-power ,

license. See NUREG-0578, Section 2.1.6a (Ref. 4) , and letters of September 27 (Ref. 23) and November 9, 1979 (Ref. 24) .

POSITION: r A program has been developed to monitor leakage from systems outside the containment which could ce used to transport highly i radioactive fluids in a post-accident condition. This program r includes the following features: .

a. A combination of general inspections and detailed i system walkdown of liquid systems. These inspections ,

,~ are done with the system operating at approximately '

' expected pressure in a normal or test mode.

b. Systems containing gases are to be tested by use of I tracer gases (DOP , freon, or helium) , by pressure decay testing, or by metered makeup tests. j

c. An aggressive maintenance program is used to assign  !

high priorities to leakage related work requests. '

Essentially all leakage on concerned systems will be covered.  ;

d. Systems lists have been provided to the NRC for .

review detailing specific methods used to test l systems, the systems involved, and frequency of testing.

e. Leakage-related work requests are to be reviewed' to l evaluate possible modifications to keep leakage "as low as practical."

This program is to be initiated prior to fuel load; however, some $

of the f ".spections cannot be completed until af ter start up, due to the plant conditions required.

4 1

I L.37-1 f

LSCS-FSAR t

Inserr to L.37 This test is described in LaSalle Station Procedure LAP-100-14.

In addition to this testing program, system leakage tests will be performed on the LPCS, HPCS, RHR and RCIC as part of the 10CFR50, Appendix J leakage testing program. The systems will be pressurized with water to a hydrostatic pressure of 1.1 times the peak LOCA pressure in the containment, the leakages from the entire system measured and compared with the acceptance criteria established for post-LOCA leakage. The frequency of the test is established by the Appendix requirements associated with Type C testing. The valves subject to this test that form the containment boundary are identified in Table 6.2-21 by reference to Notes 29 and 39.

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