ML20072C538
| ML20072C538 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/02/1983 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Diggs R NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| 6110N, NUDOCS 8303080470 | |
| Download: ML20072C538 (2) | |
Text
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N Commonwealth Edison
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) One First Nationit Ptiza. Chicago. Illinois t
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Addr:ss R: ply to: Post Office Box 767
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/ ' Chicago. Illinois 60690 j
March 2, 1983 Ms. Reba M. Diggs Facilities Program Coordinator License Fee Management Branch Office of Administrator U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
LaSalle County Station Unit 1 Amendment.12, NPF-ll NRC Docket No. 50-374 References (a):
Ms. R. M. Diggs to L. O. DelGeorge dated January 28, 1983.
(b):
C. W. Schroeder letter to A. Schwencer dated November 18, 1982.
(c):
C.
W. Schroeder letter to A. Schwencer dated December 7, 1982.
Dear Ms. Diggs:
The purpose of this letter is to discuss Commonwealth Edison Company ('s position regarding the $1,200.00 fee imposed by Reference (a) enclosed).
Commonwealth Edison Company does not believe that a
$1,200.00 fee is appropriate in this case.
At'46 FR 58486, December 2, 1981, 10 CFR 50.44(c) was revised, effective January 4, 1982.
The NRC issued license NPF-11 on April 17, 1982, or over three months later than the effective date of the revised rule.
The license NPF-ll, Condition 2.C.(2) clearly states:
"The Technical Scecifications contained in Appendix A...and the Environmental Prutection contained in Appendix B are hereby incor-parated in the license.
The licensee shall operate the' facility in accordance with the Technical Specifications..."
Technical Specification 3.10.5 provided the NRC's offical authorization to suspend the inerting requirements as follows:
"The provisions of Specification 3.6.6.2 may be suspended during the performance of the startup test program until either the required 100% of RATED THERMAL POWER trip test have been completed or the reactor has operated for 120 Effective Full Power Days."
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R. M. Diggs March 2, 1983 Reference (b), enclosed, stated:
"The purpose of this letter is to assure-that, in licensing LaSalle County-Station, it was and continues to be the NRC position that the LaSalle County Station Technical Specifications regarding inerting are governing and were issued-as specific exceptions and exemptions to the requirements..."
During a telecon on November 20, 1982 between C.
W.
Schroeder of Commonwealth Edison and Dr. A. Bournia, et al, of the NRC, the NRC stated their position that it wa; necessary for Commonwealth Edison Company to specifically request an exemption from the requirements of 10 CFR 50.44.
Reference (c), enclosed, was then submitted to:
"specifically request an exemption from the requirements of 10 CFR 50.44 to allow LaSalle County Station Unit 1 to operate within the provisions of its Technical Specification..."
lhis was done to remove any doubt in the future that when the NRC issued the Technical Specifications with a provision to suspend inerting during the startup test program until the 100% trip test or 120 effective full power days, it was clearly what they meant to do.
Commonwealth Edison Company did not request an amendment to our license to provide this clarification of intent by the NRC.
The NRC, on their own initiative, modified license NPF-ll with Amendment 12.
Based upon the above information, Commonwealth Edison Company does not believe that a $1,200.00 fee is appropriate in this case.
It is respectfully requested that the NRC review the circumstances under which Amendment 12 to License NPF-ll was issued.
If there are any further questions in this matter, please contact this office.
Very truly yours, W
shiss C. W. Schroeder Nuclear Licensing Administrator i
1m Enclosures cc:
Dr. A. Bournia NRC Resident Inspector - LSCS 6110N
r g#"44 UNITED STATES g o 3 E1 y
NUCLEAR REGULATORY COMMisslON I
o WASHINGTON, D.C. 20655 r,
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January 28, 1983 Docket No. 50-373 Commonwealth Edison Company ATTN: Mr. Louis 0. DelGeorge Director of Nuclear Licensing Post Office Box 767 Chicago, Illinois 60690 Gentlemen:
On December 20, 1982, the staff of the Division of Licensing (DL) issued Amendment No. 12 to Facility Operating License No. NPF-ll for your La Salle
. County Station Unit No. 1.
This amendment authorized an exemption from the primary containment inerting requirements of 10 CFR 50.44 which was requested by letters dated November 18 and December 7,1982.
Fees pursuant to 10 CFR 170.22 were not remitted with your request.
The DL staff has determined that this request involved a consideration that was administrative in nature. Therefore, a Class II fee of $1,200 is appli-cable and should be remitted to our office.
Sincerely,
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Reba M.
1 Facilities Program Coordinator License Fee Management Branch Office of Administration g _.0 3 d
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T M Addr.;;ss Riply 12: Post Offica Box 767 Chicago, Illinois 60690 December 7, 1982 Mr. A. Schwence r, Chie f Licensing Branch #2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Unit 1 Request for Exemption from 10 CFR 50.44 NRC Docket No. 50-373 References (a):
Generic Letter 82-17, Inconsistency Between Requirements of 10 CFR 50.54(t) and Standard Technical Specifications for Performing Audits of Emergency Preparedness Programs.
(b):
Generic Letter 82-23, Inconsistency Between Requirements of 10 CFR 73.40(d) and Standard Technical Specifications for Performing Audits of Safeguards Contingency Plans (Security Plan).
(c):
10 CFR 50.44 Standards for Combustible Gas Control System in Light Water Cooled Power Reactors, Section 50.44. (c). (3). (1).
(d):
LaSalle County Station Technical Specification 3.6.6.2, Drywell and Suppression Chamber Oxygen Concentration.
l (e):
LaSallc County Station Technical Specification 3.10.5, Special Test Execption Oxygen Concen tratio n.
( f):
C.
W. Schroeder letter to A. Schwencer dated l
l November 18,1982, " Requirement s fo r Ine rting Primary Containment. "
l
Dear Mr. Schwencer :
The NRC has recently issued References (a) and (b) which indicate inconsistencies between the Standard Technical l
Specifications and specific audit requirements per 10 CFR.
The NRC l
has indicated that, notwithstanding the Technical Specifications issued by the NRC, the 10 CFR requirements must also be met because the Technical Specifications in these two cases were not meant as exceptions or exemptions.
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.o A. Schwencer December 7, 1982 Reference (c) states, in part, that " Effective May 4, 1982 or 6 months a f ter initial criticality, whichever is later, an inerted atmosphere shall be provided for each boiling light-water nuclear power reactor with a Mark I or Mark II type containment..."
Reference (d) requires that drywell and suppression chamber atmosphere oxygen concentration shall be less than 4% by volume during the time period from within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 15% rated thermal power to within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing the thermal power to less than 15% rated thermal power.
Reference (e) grants a special test exception that Reference (d) requirements may be suspended during the performance of the startup test program until either the required 100% rated thermal power trip test has been completed or the reactor has operated for 120 Ef fective Full Power Days.
Reference (f) stated Commonwealth Edison Company's position that the LaSalle County Station Technical Specifications were governing and constituted specific exceptions and exemptions to the requirements of Reference (c).
During a telecon on November 30, 1982, between C. W. Schroeder of Commonwealth Edison and Dr. A. Bournia, et al, of the NRC, the NRC stated their position that it was necessary for Commonwealth Edison Company to specifically request an exemption in writing from the NRC to the requirements of Reference (c).
Th e purpose of this letter is to specifically request an exemption from the requirements of 10 CFR 50.44 to allow LaSalle County Station Unit I to operate within the provisions of its Technical Specifications (References (d) and (e)).
As you are aware, LaSalle County Station Unit 1 perf ormed its initial critical on June 21, 1982.
Therefore, NRC approval of this exemption is required by December 20, 1982 to avoid potential negative impact on the startup test program.
The requirements of Reference (c) were predicated on the basis that the initial startup test program for new boiling water reactors is expected to be completed within approximately six months following initial criticality.
In the case of LaSalle County Station Unit 1, there have been several reasons for the extension of the initial startup test program beyond six months.
These include:
1.
NRC delay in granting permission to exceed 5% power due to investigation of allegations.
2.
Inclusion of an extensive Safety Relief Valve test program.
3.
Redirection of Commonwealth Edison resources to address allegations, as required by the NRC.
4.
Current problems with the 1A recirc loop discharge valve, which may require an extensive outage for valve repair.
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O A. Schwencer December 7, 1982 It should be noted that the current wording of reference (e) addresses any notential concern that the utility may delay testing for the sole purpose of power generation.
The limit of 120 effective full power days is currently deemed sufficient for startup test procedures.
If there are any questions in this matter, please contact this office.
Enclosed for your use are one (1) signed original and forty (40) copies of this letter.
Very truly yours,
,z/7/s 2.
C. W. Schroeder Nuclear Licensing Administrator 1m cc:
NRC Resident Inspector - LSCS P.
P. Steptoe - IL&B 5528N d
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N Commonwealth Edison
[ O 7 Address Reply to: Post Office Box 767 O ) one First Naticnal Plan. Chicago, Illinois (x,
f Chicago, lilinois 60690 Novembe r 18, 1982 Mr. A. Schwence r, Chie f Licensing Branch #2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Unit 1 Requirement for Inerting Primary Containment NRC Do cket No. 50-373 i
References (a):
Generic Le tter 82-17, Inconsistency Between Requirements of 10 CFR 50.54(t) and Standard Technical Specifications for Performing Audits of Emergency Preparedness Programs.
(b):
Generic Le tter 82-23, Inconsistency Between Requirements o f 10 CFR 73.40(d) and Standard Technical Specifications for Performing Audits of Safeguards Contingency Plans (Security Plan).
i (c):
10 CFR 50.44 Standards for Combustible Gas Control System in Light Water Cooled Powe r Reactors, Section 50.4 4. (c). (3). (1).
(d):
LaSalle County Station Technical Specification 3.6.6.2, Drywell and Suppression Chamber Oxygen Concentration.
(e):
LaSalle County Station Technical Specification 3.10.5, Special Test Execption Oxygen Concen tratio n.
i j
Dear Mr. Schwencer:
i The NRC has recently issued References (a) and (b) which i
indicate inconsistencies between the Standard Technical Specifications end specific audit requirements per 10 CFR.
The NRC has indicated that, notwithstanding the Technical Specifications issued by the NRC, the 10 CFR requirements must also be met because the Technical Specifications in these two cases were not meant as exceptions or exemptions.
l l
Reference (c) states, in part, that " Effective May 4, 1982 or 6 months after initial criticality, whichever is later, an inerted i
otmosphere shall be providad for each boiling light-water nuclear power i
roactor with a Mark I or Mark II type containment..."
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e A. Schwencer November 18, 1982 Re ference (d) requires that drywell and suppression chamber atmosphere oxygen concentration shall be less than 4% by volume during the time period from within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 15% rated thermal power to within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing the thermal power to less than 15% rated thermal power.
Reference (e) grants a special test exception' that Reference (d) requirements may be suspended during the performance of the startup test program until either the required 100% rated thermal power trip test has been completed or the reactor has operated for 120 Ef fective Full Power Days.
_Th's purpose of this letter is to assure that, in licensing LaSalle County Station, it was and continues to be the NRC position that the LaSalle County Station Technical Specifications regarding dnerting are governino and were issued as specific exceptions and axemptions to the requirements of Reference (c).
As you are aware, LaSalle County Station Unit 1 performed its initial critical on June 21, 1962.
Unless the NRC staff notifies Commonwealth Edison to the contrary, it is Commonwealth Edison Company 's intention to perform inerting in accordance with license NPF-ll and the attendant Technical Specifications.
If there are any questions in this matter, please contact this of fice.
Enclosed for your use are one (1) signed original and forty (40) copies of this letter.
Ve ry truly yours, lifl 8/32 C. W. Schroeder Nuclear Licensing Administrator 1m cc:
NRC Resident Inspector - LSCS P. P. Steptoe - IL&B 5454N
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