ML20044B147

Suppls 890601 Application for Amends to Licenses NPF-11 & & NPF-18,changing Wording of Tech Spec 3.6.1.8 to Allow One Valve to Be Open in Each Vent & Purge Sys Penetration Indefinitely & Adding cross-reference to Table 3.6.3-1

ML20044B147
Person / Time
Site:	LaSalle
Issue date:	07/11/1990
From:	Morgan W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20044B148	List: ML20044B147 ML20044B149
References
NUDOCS 9007170433
Download: ML20044B147 (3)

Text

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• ,' \ Commonwealth Edison

. . ' '- ' ) 1400 Opus Place c', '

7 Dorners Crove,Illin216 60515 r;

July 11, 1990 Office of Nuclear Reactor Regulation Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

LaSalle County Station Units 1 and 2 Supplement to the Proposed Amendment to facility Operating Licenses NPF-Il and NPF-18 Periodic Cycling of the Pneumatically Operated VQ Valves NRC Docket Nos. 50-373 and 50-374

Reference:

a) H.E. Morgan letter to T.E. Hurley, dated June 1, 1989 Gentlemen:

Reference (a) submitted Commonwealth Edison's request for an amendment to facility Operating Licenses NPF-il and NPF-18, Appendix A, Technical Specifications. The purpose of this amendment was to add the necessary statements to allow the periodic cycling of pneumatically operated VQ valves per the manufacturer's recommendation. ,

i Upon NRC review of this request a concern was expressed about a potential confilet with the requirements of another Technical Specification. ,

After discussion with the NRC on this subject, Commonwealth Edison agreed to l amend the submittal to address these concerns. The following attachments I provide the amended. submittal.  !

Attachment A contains background information and justification for the proposed change. Attachment B contains the proposed change to the j Technical Specifications. The proposed change has been reviewed and approved i by both On-Site and Off-Site Review 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.

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' i- . 'U.S. NRC July 11, 1990 i

.i Commonwealth Edison is notifying the State of Illinois of our supplemented application for amendment by transmitting a copy of this letter and its attachitients to the designated State Official.

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

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i Very truly yours, b b i H.E. Morgan  ;

Nuclear Licensing Administrator i

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Attachments: A) Background and Information B) Proposed Technical Specification Change  :

C) Evaluation of Significant Hazards Consideration (

cc: Senior Resident Inspector, LaSalle R. Pulsifer - Project Manager, NRR Office ot' Nuclear Facility Safety - IDNS j

Regional Administrator - Region III

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_lEMEICAL SPECIFICATION CHANGLREQUESI BACKGRQMND Reference (a), requested that Technical Specification 3.6.1.8 be amended to allow one primary containment vent and purge system (VQ) butterfly valve to be open in each associated primary containment penetration at any time. This change would allow periodic cycling of these valves to take place per the manufacturers recommendations as a preventative maintenance measure without entering the action statement for Technical Specification 3.6.1.8. Upon review of this request, NRC staff expressed agreement with the need for the

-change, however, they were concerned about a potential conflict with the requirements of Technical Specification 3.6.3 for primary containment

' isolation valves. The NRC staff indicated that the potential existed for the operators to overlook the requirements of Specification 3.6.1.8, while following the requirements fo- Specification 3.6.3, when a VQ valve was inoperable and open. After discussion with the NRC on this subject Commonwealth Edison agreed to amend the submittal to address these concerns.

DISCUSILOB

-Technical Specification 3.6.3 applies to inoperable primary containment isolation system (PCIS) valves. The intention of this specification is to ensure that all PCIS valves are maintained in an operable condition or if a valve is inoperable to ensure that the affected penetration is sealed closed by other means as outlined in the Technical Specification action requirements. Specification 3.6.1.8 applies only to VQ butterfly valves which are open. The purpose of this specificttion is to ensure that each of the primary containment penetrations for the VQ system are isolated except when the VQ system is in operation. Specification 3.6.1.8 is more restrictive than Specification 3.6.3 in that it requires a unit shutdown following a one hour time clock whenever one of the VQ valves is inoperable in the open position.

Under Specification 3.6.3 continuous operation is allowed providing that the affected penetration can be otherwise sealed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The proposed amendment changes the wording of the action statement for Specification 3.6.1.8 to allow one valve to be open in each VQ penetration indefinitely. A statement will be added to the bases for Specification 3.6.1.8 to indicate that during cycling of the VQ butterfly valves for preventive maintenance purposes, one valve will remain closed in each penetration at all times. In addition, to address NRC concerns, a

-cross-reference to Specification 3.6.1.8 will be added to Table 3.6.3-1 for the VQ butterfly valves. This change will help to ensure that the station operators are sensitive to the potential applicability of Specification 3.6.1.8 when a VQ butterfly valve is inoperable and open.

Additionally, this amendment request deletes Footnote "***" from Table 3.6.3-1 of the Unit 1 Technical Specifications. This footnote was inserted in Amendment 24 to the Unit 1 Technical Specifications and allowed waiver of certain refuel outage interval surveillance requirements during Cycle 1.

LaSalle Station Unit 1 is currently in Cycle 4, therefore this footnote is no longer required and should be deleted.

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