ML20034B029
| ML20034B029 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/16/1990 |
| From: | Morgan W COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20034B030 | List: |
| References | |
| NUDOCS 9004250231 | |
| Download: ML20034B029 (7) | |
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Commonwealth Edison
) 1400 Opus Place j
i Donners Orove, Illinois 60515 April 16, 1990 Dr. Thomas E. Murley, Director ATIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
LaSalle County Station Units 1 and 2 Proposed Amendment to Technical Specification for Facility Operating License Nos. NPF-11 and NPF-18 HRC Docket Nos 50-373 and 50-374
Reference:
(a) See Attachment D
Dear Dr. Hurley:
Pursuant to 10 CFR 50.90, Commonwealth Edison Company (CECO) is j
hereby applying for an amendment to Facility Operating License Nos. NPF-11 and
'i NPF-18, Appendix A Technical Specifications.
The purpose of this; Technical
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l Specification change is to clarify the Testing Requirements for the Charcoal Absorber Beds and HEPA Filters of the Standby Gas Treatment.(VG) and'the Control Room (VC) Emergency Filtration System and Supply Filter unit.
Attachment A contains background information and justification for the proposed change. Attachment B contains the proposed changes to the 1
Technical Specifications. The proposed changes have been reviewed and approved by both On-Site and Off-Site Review: committees in accordance with Commonwealth Edison Company procedures. This amendment request has been evaluated in accordance with 10 CFR 50.92(c) and it was determined that no significant hazards consideration exists.
That evaluation is documented in Attachment C.
Attachment D lists other documents referenced in this subraittal.
i Commonwealth Edison is notifying the' State of Illinois of our.'
i-application for amendment by transmitting n copy of this letter to the l
designated State Official.
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0 9004250231 900416
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PDR ADOCK 05000373
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PDC l
a Dr..T.E. Murley April 16, 1990 Please direct any questions you may have regarding this matter'to.
this office.
Very truly yours, d 4d if%d1 W.E. brgan V
Nuclear Licensing Administrator Attachments cca R. Pulsif er - Project Manager, NRR A.B. Davis - Regional Administrator, RIII Senior Resident Inspector - LaSalle Office of Facility Safety - IDNS l
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AITAGRDlHI_A TECJIMICAL_SIECJE1 CATION CHANGE REQUESI LASALLE._ COUNTY STATION UNITS 1 AND__2 SACKGRQUND:
On May 26, 1989, it was determined that the Technical Specification requirements for laboratory testing of the Standby Gas Treatment System (VG) and Control Room (VC) charcoal adsorption beds had not been met during the testing of charcoal samples in 1985.- The Technical Specification requirements had been misinterpreted and consequently improperly incorporated into the station procedures. An investigation was conducted and the station issued-LER No. 89-019-00 (Reference k) to document the incident to ensure that all applicable Technical Specification and regulatory requirements were met. As part of the corrective actions for this event, CECO committed to revise.the LaSalle County Station Technical Specifications to clarify the testing j
requirements for the charcoal adsorption beds. This document fulfills that commitment.
D1S_C11SS10N:
Currently, the LaSalle Technical Specifications (Specifications 3/4.6.5.3 and 3/4.7.2) reference the requirements of Regulatory Guide 1.52, Revision 2, March 1978 (Reference e) for both the sampling requirements and' j
laboratory testing criteria.
Regulatory Guide 1.52' recommends the use of-industry standard ANSI N509-1976 (Reference d) to provide-design sampling and 4
testing requirements for the air cleaning units.- For laboratory testing
_l protocols, this standard refers to ANSI N510-1975 (Reference c) which in turn I
1 requires use of test procedure RDT M16-1T (Ref erence b).
An update of ANSI N510 in 1980 changed the laboratory testing requirements to ASTM D3803 (Reference f) which is currently the accepted industry standard for testing of i
charcoal adsorption beds.
i In NRC Information Notice 87-32 (Reference 1),.the NRC indicated that i
l certain deficiencies may exist in the testing methodology of the ASTM Standard i-and has recommended that certain revisions be made to the standard.
In Reference 1, Page 20, the NRC further states that the ASTM Standard is i
currently under revision to incorporate the NRC recommendations into the standard. As a result, the ASTM protocol is likely to remain the accepted industry standard for charcoal testing either in the current or revised form.
LaSalle County Station is proposing that the Technical Specifications be amended to refer directly to the laboratory testing protocols of the ASIM Standard.
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'l Also being proposed is that the acceptance criteria for these tests 7
be revised to be consistent with the proposed action levels contained in Table 1.
_(The Table was developsd with-input from NRU staff members.) The acceptance criteria' providei in the Table is the same as _ or more conservative than the requirements of Generic Letter No. 83-13 (Action Level I).
The table provides for remedial actions if the acceptance criteria -is not met._ Action' Levels I and.II ensure that the Technical Specification LCO action level l
(Action Level III), and thereby the dose calculation basis, is nni exceeded.
These provisions provide the flexibility to plan and prepare for remedial action before entering an LCO. Commonwealth Edison Company will incorporate these action levels into the station procedures following approval of this amendment.
Additionally, LaSalle County Station is proposing that references to the auxiliary electric equipment room (AEER)' emergency filtration system and a
the control room supply recirculating charcoal filter, " odor eater", be removed from the Technical specifications for the following reasons.
AEER_ Emergency _E11tration..flyatem - GDC 19 provides the general requirements.for the control room design and for maintenance of the control room environment. GDC 19 requires that a control room be provided from which the plant can be operated and maintained in a safe condition under normal and abnormal conditions. Measures are required.to ensure the habitability of the control room under accident conditions. At LaSalle Station the outside air supply for the AEER air conditioning system comes from the VC system minimum outside air inlet damper. When the VC emergency filtration system runs, it supplies air to both the VC and AEER system. Although the AEER and Control Room share the same air supply I
systems, the Control Room envelope and the AEER envelope are independent l
and are in physically separated areas inside the plant.
GDC 19 further requires that equipment be provided in areas-outside of the control room to provide for the capability of a remote shutdown of the unit.
Since the AEER is not required to be occupied for safe plant operation, except in-the case of a remote shutdown, the habitability requirements of GDC 19 are not applicable to the AEER.
On Piping and Instrumentation Diagram (P&ID) M-1443-1 the " Control Room l
and Auxiliary Electric Equipment Room Emergency Filteration System" is referred to as the " Control Room HVAC Emergency Make-up Air Filter Unit".
In this description no reference to the AEER is made, therefore to avoid confusion to the station operators it is being proposed that the Technical Specification nomenclature be revised to delete any reference to the AEER. This will then coincide with the station P&ID's.
ContIQLBoomlerir&ulatingJharsonLEilt.er - A current calculation (Reference n) of the design-basis post accident radiological doses in the plant's main control room has shown that the radiological doses calculated were all within applicable regulatory criteria.
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v Since it has been shown in this calculation that the recirculating charcoal. filter is not required to maintain control room habitability under accident conditions, it is proposed that the references to this filter be removed from the Technical Specifications.
SIMt%RY This submittal proposes that the Technical Specification be amended:
- 1) to reference the current industry standards for laboratory testing of charcoal adsorption bed samples;
- 2) to revise and clarify-the acceptance criteria for laboratory tests of the charcoal adsorption bed samples; q
- 3) to eliminate the references in the Technical Specifications to the AEER-emergency filtration system; 1
- 4) to eliminate the references in the Technical Specifications.to the control j
room recirculating charcoal filter (" odor eater"); and-1 i
- 5) to revise the Technical Specifications nomenclature " Control Room and Auxiliary Electric Equipment Room Emergency Filteration System" by deleteing any reference to the AEER.
This will then concide with the nomenclature referenced in the station P&ID's.
" Control Room HVAC I
Emergency Make-up air filter unit".
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a TABLE 1 PROPOSED LABORATORY TESTIN8 CRITERIA-FOR CHARCOAL ADSORDER' BED SAMPLES 1
I m 6 4 T DENETRATION I'
l l-STANDBY GAS I
CONTROL ROOM i
r I
i TREATPENT -
1 EMERGENCY FILTRATION l I
l nr :u (a= arn) l BYSTEM (2" BED) 1-1 1
1.
l.
ACTION LEVEL I procedural Initial Action Level L 8.175 %.
L 2. 8 %
(Refer to Notes 1 through 4)
ACTION LEVEL II Procedural Action Level L 8. 4 %
L 8. 8 %
(Refer to Note 5)
ACTION LEVEL III Technical Specification LCO L 8. 5 %_
_ L 18. 8 %
Action Level (Refer to Note 6) l DOSE ANALYSIE BASIB
- 1. 8 %
18.8 %
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1.
If the periodic surveillance testing results are less than Action Level-I penetration criteria'for the filter of interest, no action is required.-
L 2.
If the periodic surveillance t'esting results are between Action Levels-I III penetration criteria, test another charcoal bed sample and. verify and the results within 45 days of receiving the initial test results.
3.
If any of the retest results are less than the Action Level I penetration criteria, no further action is required.
4.
If the results of the second test are between Action Levels.I and II penetration criteria:
replace the charcoal bed or test another sample and verify _the results a.
are less than Level I penetration criteria within 92 days of receiving i
the previous test results.
b.
if the results of the testing. in note 4a. are still between Action Levels I and II the testing specified in l note 4a maybe repeated once.
5.
If any of the charcoal bed retest results are between the Action Levels II and III criteria, replace the charcoal adsorption bed within 31 days 6.
If any of the test sample results (initial or. retest) are confirmed to be greater than or equal to the Action Level III penetration criteria. declare the system to be inoperable in accordance with the applicable technical specifications and follow the appropriate action statement and reporting y
requiremants.
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