ML20050B560
| ML20050B560 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/26/1982 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 3740N, NUDOCS 8204060046 | |
| Download: ML20050B560 (6) | |
Text
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AddrIss ftply to: Post Offica Box 767 Chicago, Illinois 60690 March 26, 1982 Mr. Darrell G. Eisenhut, Director Division o f Licensing U.S. Nuclear Regulatory Commission
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Washington, DC 20555 h '. w.MiD
Subject:
LaSalle County Station Uni,'-1 Comments on Draf t License
'*0 5 79O b '12 dated March 19, 1982 C'ttnm NRC Docket No. 50-373 I-
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Dear Mr. Eisenhut:
Cf The purpose of this letter is to provide Commonwealth Edison Company 's comments on the draf t license NPF-ll.
These comments fall into four major areas of concern, each of which is addressed in detail in appendices to this letter.
Appendix A:
These items duplicate current requirements o f the Technical Specifications or the Environmental Protection Plan.
Appendix 8:
These items have been completed and therefore are no longer required as conditions o f license.
Appendix C:
These items are statements that the licensee shall do anything that the staf f decides, based on reviews that the NRC has not yet completed.
Legal counsel has advised that, although the NRC has the authority to impose requirements (as is currently done with Bulletins, orders, etc. in operating plants),-open ended requirements to "do anything the staf f decides" are unrealistic, unnecessary, and make the license unclear.
Appendix D:
These are items in which the licensee has technical concerns or in which clarifications are required.
Many of these items have previously been discussed with Dr.
A. Bournia o f your s ta f f.
Due to the immediacy of LaSalle County Station Unit l's fuel load, your prompt attention to these items is appreciated.
As was agreed to by Mr. Harold Denton during the design control and I
II T204060046 820326 PDR ADOCK 05000373 A
l D. G. Eisenhut March 26, 1982 i
quality assurance meeting at LaSalle on November 12, 1981, i t i s important that the license be clear, simple, and not duplicate other 1
documents such as the Technical Specifications.
If there are any further questions in this matter, please contact Mr. Charles W. Schroeder, Nuclear Licensing Administrator.
Very truly yours, c. &~C i
Cordell Reed Vice-President j
Nuclear Operations j
1m cc:
NRC Resident Inspector - LSCS 3740N i
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s APPENDIX A These items duplicate current requirements o f the Technical Specifications or the Environmental Protection Plan.
2.C - Item'9 Surveillance o f Control Blade Tech Spec 6.6. A.1, page 6-21 requires a startup report to be submitted within 90 days following completion of plant startup (a f ter refuel outage).
2.C - Item 10 Stability Analysis Tech Specs 3.4.1.1 and 3.10.4 list all requirements o f operation with natural circulation ~.
2.C - Item 15(b)
Pressure Interlocks on Valves Interfacing at Low and High Pressure Tech Spec 4.4.3.2.2(a) requires this inspection.
(Note:
March 19 draft had this section marked out by hand).
2.C - Item 27(a)
Shift Technical Advisor Tech Spec 6.1.C.5 and Table 6.1-3 f ully address requirements for ST A and SCRE.
2.C - Item 28(c)
Independent Safety Engineering Group Tech Spec 6.1.C.5 f ully addresses the on-site independent safety engineering group.
2.E -
Protection o f the Environment The Environmental Protection Plan requires this notification.
APPENDIX 8 These items have been completed and are therefore no longer required.
i 2.C - ltem 17(a)
Additional Instrumentation and Control Concerns The licensee has addressed this information in 4
Amendment 60 to the FSAR.
2.C - Item 28(p)
Automatic Switchover of Reactor Core Isolation Cocling bystem Suction - Verifying Procedures and Moolfying Design The equipment to accomplish this has been installed.
Environmental qualification for this' is already covered under 2.C Item (7) o f i
the license.
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' 4 APPENDIX C These items are statements that the licensee shall do anything that the staf f decides, based on reviews that the NRC has not yet completed.
Legal counsel has advised that, although the NRC has the authority to impose requirements (as is currently done with Bulletins, orders, etc. in operating plants), open ended requirements to "do ahything the staf f decides" are unrealistic, unnecessary, and make the license unclear.
Finally, provision-ing the LaSalle operations based on possible untimely reviews by the staf f is not acceptable.
2.C - Item 4(b)
Masonry Walls In a telecon with Dr. Bournia, et al, o f your staf f on March 24, 1982, it was indicated that the. staff would not complete its review on LaSalle masonry wall information for another 2-3 months.
It was also indicated that the testing that Clinton Station is performing (scheduled for completion in September, 1982) may apply to LaSalle.
In order to consider completed any changes that your review might require, it is imperative that your staf f complete all aspects of their review as scheduled.
2.C - Item 8.b Review o f Fuel Lif tof f It is not acceptable to condition the LaSalle license based on a review which your staf f has not done.
2.C - Item 11.b Scram Discharge Volume It is not acceptable to condition the LaSalle license based on a review which your staf f has 4
not completed.
2.C - Item 28(j)
Instrumentation for Detection of Inadequate Core cooling It is not acceptable to condition the LaSalle license based on a raview which your staf f has not completed.
APPENDIX D These are items on which the licensee has technical concerns or on which clarifications are required.
2:.C - Item 7(a)
Environmental Qualifications Commonwealth Edison Company has previously notified your staf f that we cannot meet the June 30, 1982, l
date.
Discussions with Mr. Eisenhut have indicated that this date will be revised.
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APPENDIX D (Cont'd) 2.C - Item 10 Stability Analyses Discussions with Dr. Bournia of your staff have indicated that this item will be revised to clarify that natural circulation is permitted in accordance with the Technical Specifications for the Startup Test Program.
2.C - Item 19(a)
Reliability of Diesel Generators Commonwealth Edison Company's position is that the heavy duty turbocharger will be installed prior to startup af ter the first refueling outage aft 6r qualified equipment becomes available.
Although qualification programs have been promised, there is no certainty that qualified equipment will be available prior to the first refuel outage.
2.C - Item 19(b)
Direct Current Prelube Pump During discussions with Dr. Bournia, et al, o f your staf f on March 24, 1982, it was acknow-ledged that your review in this area was still in progress, and an acceptable fix was not completely finalized.
Your s taf f agreed to modify this item by adding the potential for other acceptable fixes.
Commonwealth Edison still maintains that lubrication of the upper head may endanger the operation of the diesels and should not be cone.
2.C - Item 2D Direct Current Power Systems The March 19, 1982, draft had a handwritten change to make the last line read "..... panels at least once per eight hour shift."
Commonwealth Edison j
concurs with this change.
l 2.C - Item 28(b)(1)
NSSS Vendor Review o f Procedures l
It is requested that the sentence read
".....and the General Electric recommenda-tions have been addressed."
General Electric recommendations from their review of Rev. O of these procedures have been incorporated.
Comments on later revisions will be fully incorporated prior to performing the tests.
All comments, although listed for incorpor n-tion in future revisions, have not been incorporated in an attempt to reduce the number of revisions necessary.
When another revision l
is made (at least prior to the test), these l
comments will be incorporated.
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. APPENDIX D (Cont'd) 2.C - Item 28(k)
Assurance of Proper Engineered Safety Features Functioning The March 19, 1982, draft had a handwritten change to make this item read:
" Prior to fuel load, the licensee shall confirm that all engineered safety features systems required by Technical Specifications are aligned in accoraance with approved mechanical and electrical checklists."
Commonwealth Edison concurs with this change.
2.C - Item 28(m)
Modification o f ADS Logic Commonwealth Edison has noted that the BWR Owners Group has determined that this change is not adequate.
C.
W.
Schroeder letter to A._Schwencer dated March 9, 1982, provided you with interim information on this subject.
2.C - Item 28(q)
Upgrade Emergency Support Facilities It is our understanding that changes are in progress to allow a greater time frame for completion o f SPDS.
When this occurs, Commonwealth Edison wants to have the flexibility to meet the required implementation for the rest of the industry.
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