ML20058G490
| ML20058G490 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/05/1990 |
| From: | Morgan W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-01, GL-88-1, NUDOCS 9011130226 | |
| Download: ML20058G490 (4) | |
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. Downsrs Grove, Illinois 60515 L
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November 5,1990 1
g U.S. Nuclear Regulatory Commission J
Attn: Document Control Desk y
- Washington, D.C. 20555 i
Subject:
LaSalle County Station Units 1 and 2 Response to NRC Request for Additional Information Concerning the Review of Response to Generic Letter 88 01 NRC Docket NpJip-311pnd 50 374
Reference:
(a)
R.M. Pulsifer (NRC) letter to T.J. Kovach (CECO) dated August 22,1990.
(b)
P.C. Shemenaki letter to T.J. Kovach dated May 1,1989, LaSalle County Station Units a
1 and 2, Generic Letter 88-01, l
Request for AdditionalInformation".
(c)
M.H. Richter letar to U.S. NRC dated L
June 30,1989, "LaSalle County Station Units 1 and 2 Response to Request for Additional Information, Generic Letter 88-01".
Dsar' Sir:
. Reference (a) stated that the NRC review of LaSalle County Station's-g" response to Generic Letter 88 01 was found to be acceptable with some exceptions. LaSalle Station was requested to review these exceptions and to notify.
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~ the staff of actions taken to address them. The following attachmeni,'rovides the requested information.-
- Please direct any questions you may have to this office.
Very truly yours, ka
,4 W. ; Morgan g3 Nuclear Licenisng Administrator g
. Attachment-
... w WM:Imw i0' ZNLD145-40
.cc:. A.B. Davis - Regional Administrator, Rlli
)
Senior Resident inspector - LSCS l
Robert Pulsifer - Project Manager, NRR
([(l 9011130226 9o11oS g
g PDR ADOCK 05o0o373 P
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AITACBMENI Based on the NRC Safety Evaluation (Reference a) LaSalle County Station's response to the following safety evaluation exceptions which requested to propose amendments to the Technical Specifications, are as follows:
LIEM_(1)
Include a statement in the surveillance or administrative controls section that includes the following: "The Inservice inspection program for piping identified in NRC Generic Letter 88 01 shall be performed in accordance with the NRC staff xsitions on schedule, methods, personnel, and sample expansion includec in Generic Letter 88 01 or in accordance with alternate measures approved by the NRC staff."
Besponse A statement will be included in Technical Specification 4.0.5 that states the following: "The Inservice inspection program for piping identified in NRC Generic Letter 88 01 shall be performed in accordance with the NRC staff positions on schedule, methods, personnel, and sample expansion included in generic Letter 88 01 or in accordance with alternate measures approved by the NRC staff "
- IIEMj2) include an additional Limiting Condition for Operation (LCO) that specifies reactor coolant system leakage shall be limited to a 2 gpm increase in unidentified leakage within any 24-hour period.
Besponse An additional limiting condition for operation (LCO) will be added to Technical Specification 3.4.3.2 that specifies reactor coolant leakage shall be limited to a 2 gpm increase in unidentified leakage within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
IIEMJ3) include a surveillance requirement that primary containment sump flow rate will be monitored at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, it should be noted that the aosition in GL 88 01 on leak rate monitoring was modified to permit eakage measurements based on sump flow instruments to be taken every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> instead of every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Besponse This item recommends addition of a requirement to the Technical Specifications to monitor the primary containment sump flow rate at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The LaSalle County Station "shiftly" surveillance interval is defined in Table 1.1 of the Technical Specifications as "at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." At the present time there are no Technical Specification l
surveillance requirements which require an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time interval. As a result the station does not have any administrative controls in place to ensure that such a surveillance requirement is met. Technical Specification 4.4.3.2 currently contains a surveillance requirement to monitor the primary containment sump flow rate at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Normally the Technical Specification "shiftly" surveillance requirements are performed three times daily (once during each shift 11:00p.-7:00am; 7:00am 3:00am; 3:00pm-11:00pm). Therefore, this surveillance requirement as current y written is considered by the station to be adequate and to meet the intent of the recommendation in Generic Letter 88-01.
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, ITEM (4)
For LaSalle County Station Unit 1, include an LCO on operability of sump monitoring instruments. Since you plant has IGSCC weld category E weldments, Generic Letter 88-01 provides an allowed outage time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for repairing the drywell floor drain sump monitoring system, or an orderly shutdown should be initiate As an attemative, the staff recommends that when the drywell sump monitoring system is inoperable, the operator should use a demonstrated manual method for determining leak rate, such as measuring the time to manually pump the sump at a fixed interval (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />). The staff considers manual measurement a viable sump monitoring method without hardship to the operator; therefore, this method could be added to the appropriate LCO section. With the manual method operable, the outage time for the drywell sump monitoring system could be extended to 30 days. However, if the sump pump and drywell sump monitoring systems are inoperable concurrently, then either system has to be repaired within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or an orderly shutdown should be initiated.
Response
On June 30,1989 Commonwealth Edison provided additionalinformation (Reference c) conceming NRC Generic Letter 88-01 as requested in an NRC letter dated May 1,1969 (Reference b). At that time it was identified that LaSalle Unit 1 had two category E weldments. Since the time of that submittal further inspection of the weldments in question has resulted in a change of classification.
During the third refueling outage for Unit 1 in the Spring of 1990, Weld Numbers RR 1005-27A and RR-1001-10 were reinspected using the General Electric automated " SMART" Ultrasonic Testing (UT) System. The indications which had previously been classified as category E IGSCC were redefined to be " root and f.D. Geometry. This rede inition is attributed o
to the additional machining of the weld crown on these two welds which resulted in a smoother scanning surface for the UT system. The " SMART" UT system was able to characterize the indications more accurately on the smoother surface. As a result Weld Numbers RR-1005-27A and RR-1001-10 nave been reclassified from category E to category B.
Since LaSalle Station Unit 1 no longer has any weldments classified as category E, the additionalleak detection monitoring requirements provided in Generic Letter 88-01 for plants with category E weldments, no longer apply. No further action is required for this item.
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n IIEM_(5)
Commonwealth Edison needs to address the RWCU :>iping outboard of the isolation valves in the ISI pr ram..lf the piping is witlin the scope of GL - 88-01, you will need to mod the program to include the identity of the welds as well as plans for mi igation and inspections. A minimum of 10%
of the RWCU system plaing outboard of the isolation valves should be inspected at each refue ing outage, if cracks are found, the licensee should discuss sample expansion and mitigation methods with the NRC staff.
For SE def' lencies related to welds, categorization of welds, and.
qualification of personnel, these deficiencies shall be corrected in the ISI program. Since you areviously submitted integrated IGSCC inspection alans, our safety eva uation precludes the necessity for you to submit IGSCO inspection plans for each future outage. However, if flaws are-
. found that do not meet the criteria of Section XI of the ASME Code for continued operation without evaluation, NRC approval of flow evaluations or repairs in accordance with IWB 3640 and IWB 4130 is required before-resumption of operation. Note that weld overly repair is considered as a non Code repair, which requires NRC approval.
Besponse
' An evaluation by the LaSalle Station Technical Staff Inservice Inspection (ISI)/ Inservice Testing (IST) Group has determined that neither the Unit 1-or Unit 2 Reactor Water Cleanup System (RWCU) contain any Austenitic Stainless Steel. Therefore, the RWCU system does not fall within the
. scope of NRC Generic Letter 88-01 and no further actions is required.
The technical s acification amendments identified in items 1 and 2 will be prepared for submittal to the N RC by April 1,1991. Items 3,4 and 5 require no further action.
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