ML20070U649
| ML20070U649 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/01/1991 |
| From: | Piet P COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20070U651 | List: |
| References | |
| GL-88-01, GL-88-1, NUDOCS 9104090230 | |
| Download: ML20070U649 (5) | |
Text
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l Ctmm:nwesith Edisen 10 CFR 50.90 1400 Opus Pisco i
Downers Grove. Illinois 60515 April 1, 1991 i
I U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
Subject:
LaSalle County Station Units 1 and 2 Application for Amendment to factitty Operating Licenses NPF-11 and NPF-18, Appendix A, Technical Specifications incorporating the requirements of Generic Letter 88-01.
i NRC_DocheLNosu50-371and_50:3M
References:
(See Attached Sheet)
Gentlemen:
pursuant to 10 CFR 50.90, Commonwealth Edison (CECO) proposes to amend Appendix A, Technical Specifications., of factitty Operating Licenses NPF-11 and NPF-18.
The proposed amendment incorporates into the Technical Specifications the requirenents of Genede Letter 88-01, which concerns IGSCC in BWR austenitic stainless steel piping, these revisions will enhance the existing rer:eirements for the early detection of high energy piping failures.
This proposed amendment request is subdivided as follows:
1.
Attachment A gives a description and safety analysis of the proposed changes in this amendment.
2.
Attachment B includes the marked-up Technical Specifications pages with the requested changes indicated.
3.
Attachment C describes CECO's evaluation performed in accordance with 10 CFR 50.92 (c), which confirms that no significant hazards consideration is involved.
4.
Attachment D provides the Environmental Assessment.
This proposed amendment has been reviewed and approved by CECO On-Site and Off-Site Review in accordance with Commonwealth Edison procedures, o\\
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U.S. Nuclear Regulatory Commission April 1, 1991 To the best of my knowledge and belief, the information contained within is true and correct, in some respect these statements are not based on my personal knowledge, but obtained information furnished by other Comnonwealth Edison employees, contract _or employees, and consultants.
Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
Comnonwealth Edison is notifying the State of Illinois of this applicaticin for amendment by transmitting a copy of this letter and its attachments to the designated state official.
Please direct any questions you may have concerning this submittal to this office.
Very truly yours, lN '
d Peter L. Piet Nuclear Licensing Administrator Attachments:
A. Description of Safety Anelysis of the Proposed Changes B. Marked-up Technical Specification Pages C. Evaluation of Significant Hazards Considerations D. Environmental Assessment cc: A.B. Davis - Regional Administrator, RIII Senior Resident Inspector - LSCS John Hickman - NRR, Project Manager Office of Nuclear facility Safety - IDNS PLP:Imw ZNLD841/3 t 9
Signed before me on this day
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-v,=+~e-RLEERENCES (a)
NRC Generic Letter 88-01 dated January 25, 1988, "NRC Position on IGSCC in BHR Austenitic Steinless " Steel Piping",
(b)
H.E. Morgan letter to USNRC dated July 29, 1988, "LaSalle County Station Units 1 and 2, Response to Generic Letter 88-01."
(c)
P.C. Shemanski letter to T.J. Kovach dated May 1, 1989, "LaSalle County Station Units I and 2, Generic letter 88-01 Response, Request for Additional Information."
(d)
M.H. Richter letter to USNRC dated June 30, 1989, "LaSalle Coun.y Station Units 1 and 2 Request for Additional Information te veneric Letter 88-01."
(e)
R.M. Pulsifer letter to T.J. Kovach dated August 22, 1990,
" Review of Response to Generic Letter 88-01, LaSalle County Station, Units I and 2."
(f)
H.E. Morgan letter to USNRC dated November 5, 1990, "LaSalle County Station Units 1 and 2 Response to NRC Request for Additional Information Concerning the Review of Response to Generic Letter 88-01."
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AHACHMENLA DESCRIE110N _AND..SAFEILANRYSIS_0f _ PROPOSED. CHANGES _IO_ APPENDIX A._
I E C H NI CAL S E EC l f 1C A110N S _0LfAC I LIILORE RAl l NG. L I C E N S ESlPfdL AN D _NEf -J 8 DESCRIEIl0N Generic Letter 88-01, (Reference (a)), presented the NRC Staff position on issues related to Intergranular Stress Corrosion Cracking (IGSCC) near weldments in BWR piping.
The generic letter requested that licensees provide responses regarding the implementation of these staff positions.
In July 1988, LaSalle County Station provided its initial response to Generic letter 88-01.
This submittal was followed by a series of requests from the NRC for additional information and supplemental responses by Ceco (References (b)-(e)).
In Reference (f), LaSalle County Station committed to submit a request for Technical Specification amendments required by the Generic Letter.
BASESl0LER0EOSED_ CHANGES To satisfy the requirements of Generic Letter 88-01, LaSalle County Station proposes two (2) amendments to the Technical Specifications.
The first of these amendments is the addition of Section 4.0.5.f to the Technical Specifications, which states:
lne inservice inspection program for piping idenMfied 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.
CECO has endorsed the NRC Staff positions presented in the generic letter by including the above paragraph in the LaSalle County Technical Specifications.
The inservice inspection program at LaSalle County is currently in full compliance with these positions. UFSAR Sections 3.9.6 and 5.2.4.1 currently require the inservice inspection program to conform with the recommendations of Generic Letter 88-01.
Incorporation of the above paragraph into Technical Specification 4.0.5 provides a formal endorsement of the staff positions.
This amendment is administrative in nature and has no impact cn plant safety.
The second amendment proposes to satisfy the requirements of Generic Letter 88-01 by establishing a new limiting condition for operation (LCO) and action requirement for the reactor cSolant system operational leakage limits (Technical Specification 3/4.3.2).
The new LC0 (Section 3.4.3.2.e) places a 2 gpm limit on the increase in unidentified leakage over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
The requirements for detection of unidentified Icakage are covered in UFSAR Sections 5.2.1 and 5.2.5.5.1.
The limit for unidentified leakage (5 gpm) established in the UFSAR is conservative and is intended to allow time for corrective actions to take place before any process barriers can be significantly compromised.
This new value for unidentified leakage (> 2 gpm increase) will provide an earlier indication of pressure boundary leatage than would otherwise be available with the single absolute limit of 5 gpm.
The action requirements allow a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period to identify the source of any such chhnges prior to commenting an orderly shutdown of the unit.
The action requirement will be stated as follows:
INLD841/5
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With any reactor coolant system leakage greater than the limit in e above, identify the source of leakage within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOT SHUTDOHN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOHN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Leakage detection systems for the reactor coolant system are provided to alert the operator when leakage rates above normal levels are detected.
This additional restriction will enhance the ability for early detection of small flaws in the reactor coolant pressure boundary, thereby reducing the potential for e significant failure of the pressure boundary. CECO anticipates that the proposed amendment will have a positive impact on plant safety and introduces no new safety concerns.
SUMMARY
The preceding sec;1ons and Reference (f) have addressed all the concerns of Generic Letter 88-01.
The proposed amendments to the Unit 1 and Unit 2 Technical Specifications do not constitute a change to the facility or the operation of the facility as described in the UFSAR.
These revisions do not adversely affect any of the accident initiators or initial assumptions used in the plant accident analyses.
It is CECO's expectation that the amendments to Technical Specification 3.4.3.2 will increase the margin of safety for the plant due to the implementation of increased restrictions and controls required by Generic Letter 88-01.
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