ML20054F666
| ML20054F666 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/14/1982 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20054F667 | List: |
| References | |
| 4339N, NUDOCS 8206170201 | |
| Download: ML20054F666 (4) | |
Text
Commonwealth Edison
[
) One First Nation:I Ptra, Chicago, Illinois J Addr'ss Reply t;: Post Offica Box 767
\\
/ Chicago, Illinois 60690 Jun e 14, 1982 Mr. A. Schwencer, Chie f Licensing Branch #2 Division o f Licensing U.
S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Unit 1 Proposed Amendments to NPF-11 Appendix "A"
Technical Specifications NRC Docket No. 50-373
Dear Mr. Schwencer:
The purpose of this letter is to request the following expedited changes in Technical Specification's for LaSalle County Station Unit 1:
Change Reques t NPF-11/82-5 Incorporate the predicted lif t-o ff forces required to ccmplete Tables 4.6.1.5-1 and 4.6.1.5-2.
This change is required to ce submitted PRIOR TO FULL POWER by license NPF-ll Condition 2.C. (7) and, as such, NO FEE IS REQUIRED Change Request NPF-11/82-6 Revise fire detector tables to reflect additional detectors installed as a result of installation of the general sprinkler system provided for the diesel generator corridor.
The installa-tion of the general sprinkler system is required to be installed PRIOR TO INITI AL CRITICALITY by license NPF-11 Condition 2.C. (25).(b) and, as such, NO FEE IS REQUIRED.
Change Request NPF-ll/82-7 Reduce SRM Count Rate requirements.
This change is one Class III amendment.
These proposed changes are addressed in the Attachments.
These changes have received on-site and of f-site review and appro-val.
Attachment "B" lists the status o f Technical Specification Change Requests for LaSalle.
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A. Schwencer Jun e - 14, 1982 Pursuant to 10 CFR 170, these changes reflect 2 cases of NO FEE REQUIRED and one Class III amendment.
A remittance of $4,000.00 is, therefore, enclosed..
Please contact this office if there are any questions in this matter.
Three (3) signed originals and thirty-seven (37) copies of this transmittal and attachments are provided for your use.
Very truly yours, c./sy/st C. W. Schroeder Nuclear Licensing Administrator im Attachments cc:
NRC Resident Inspector - LaSalle SUBSCRIBED and SWORtj to before ce this 14/May of Om e _
1982 0F lO A.
Wb 1
No tary PJblic 4339N l
's L ASALLE COUNTY STATION UNIT 1 TECH SPEC CHANGE REQUEST'.NFF 51/82-5 9
- +
1 J
Subject:
Revis e Tables 4.6.1.5-1 an d 4.6.1.5-2 to Incorporate the Predicted Tendon Lif t 'Off p
Fo rce s.
Re ference (a):
License NPF-ll Condition 2.C. (7),
t
Background:
i During the last several months,.there have been. discussions between NRR staf f and Commonwealth Edison (and ~its. Architect Engineer, Sargent & Lundy) regarding the format and ' requirements o f Technical Specification 3/4.6.1.5, Primary Containment.
In order to avoid delay of the issuance of license NPF-ll, the licensee was forced to accept the requirements without further negotiation._
Oiscussion:
The tables provided have translated previously provided graphs into tabular format.
5
==
Conclusion:==
Commonwealth Edison finds no unreviewed safety question.
The tables provided satisfy the requirements of license NPF-J1 Condition 2.C.(7).
In the near future, Commonwealth Edison will desire to continue discussions with the NRC in order that the following concerns may be resolved:
1.
Specification 3.6.1.5a is inconsistent with Section 4.6.1.fa line 22 hence also is inconsistent with Section 7.1.2 of Reg.
~
Guide 1.35 Rev.
3.
Specification 3.6.1.5a requires ACTION on the basis of a single tendon whereas specification 4.6.1.5a uses more than one tendon as a c;iterion unless a single tendon force lies below the 90% lowe. !ini.t criterion.
A meaningful surveillance cannot ba a 2e with the Tech Spec as written because o f this ire.
is -ncy; the ACTION statement is not traceable to eith.!.ci ratation.
2.
Specification 3.6.1.5a line 6 references the design limit whereas specification 4.6.1.5a does not reference the design limit but an installation record and predicted tendon forces. at some subsequent inspection time.
This inconsistency also relates to Section 7 of Reg. Guide 1.35 Re v.
3.
The ACTION calling for shutdown is not justifiable from either interpretation.
. 3.
Specification 3.6.1.5a requires COLD SHUTDOWN whenever one tendon has a lift-o ff force less than predicted whereas Specification 3.6.1.5b requires COLD SHUTDOWN whenever one tendon drops below the 90% of predicted lower limit based upon 4.6.1.5a.
Again, the shutdown ACTION is contradictory and
. unwarranted; it is also not consistent with the April 12, 1979 telecon between NRC staff members, Edison representatives, and S&L engineers who agreed that a reporting ACTION was adequate.
4.
Section. 4.6.1.5a is not consistent with Section 3 of Reg. Guide 1.35 Rev. 3 which recognizes that the upper bound prediction is not critical from a safety point of view.
It also is contrary z,
i to the ~ NRC-Ceco telecon o f April 12, 1982 whose conclusion agreed with the new Reg. Guide.
5.
For LaSalle Unit 1, the first inspection is not coincident with the first year after initial tensioning, therefore, line 4 of Specification 4.6.1.5 must be corrected to the exis;ing condition o f 2 years elapsed time.
6.
Table 4.6.1.5-2 lists the predicted valves o f the first inspection which is 2 years after the initial tensioning.
Therefore, the calculated losses need a correction by log t/to where ta=2.
7.
The last sentence of Specification 4.6.1.5a must be changed to a reporting requirement to be consistent with Sections 7.1.3 and 7.1.4 o f Regulatory Guide 1.35 Rev.
3.
The claim that abnormal degradation of the containment structure exists an time a f
selected tendon has less than 90 percent of its predicted force just isn't true for all times, but only for latter periods of certain designs where structural margin is small.
4339N 1
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