ML20081C666
| ML20081C666 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/10/1995 |
| From: | Adensam E NRC (Affiliation Not Assigned) |
| To: | COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20081C672 | List: |
| References | |
| NUDOCS 9503170364 | |
| Download: ML20081C666 (9) | |
Text
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UNITED STATES OF AMERICA' i
NUCLEAR REGULATORY COMMISSION i
i In the Matter of
)
)
COMMONWEALTH EDISON COMPANY
)
Docket Nos. 50-373
)
50-374 (LaSalle County Station,
)
Units I and 2).
)
EXEMPTION i
I.
I Commonwealth Edison Company (Comed, the licensee) is the holder of i
Facility Operating License Nos. NPF-11 and NPF-18, which authorize operation of the LaSalle County Station, Units 1 and 2 (the facility), at a steady state I
power level not in excess of 3323 megawatts thermal. The facility consists of two boiling water reactors at the licensee's site located in LaSalle County, Illinois.
The licenses provide, among other things, that they are subject to all rules, regulations, and orders of the U. S. Nuclear Regulatory Commission (the Commission) now or hereafter in effect.
II.
i Section III.A.6(b) of Appendix J to 10 CFR Part 50 states the following in regard to performing Overall Integrated Containment Leakage Rate (Type A)
[
Tests (ILRT):
If two consecutive periodic Type A tests fail to meet the applicable acceptance criteria in III.A.5(b), notwithstanding the periodic retest schedule of III.D., a Type A test shall be performed at each plant' shutdown for refueling or app *oximately every 18 months, whichever occurs first, until two consecutive l
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-Type A tests meet the acceptance criteria in III.A.5(b), after which x
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time the retest schedule specified'in III.D. may be resumed.
The Type A tests performed during the first, third and fourth refueling b
outages for LaSalle County Station, Unit 2, were considered to be failures in the. "as-found" condition due to penalties incurred as a result of leakage measured in Type B and C local leak rate tests (LLRT).
Pursuant to Section III.A.6(b) of Appendix J, Type A testing was performed during the fifth efueling outag'e for LaSalle County Station, Unit 2, in December 1993.
That. Type A test satisfied the "as-found" acceptance criteria.Section III.A.6(b) of Appendix J requires an additional Type A test during the sixth.
refueling outage, currently scheduled for February 1995, in order to fulfil the condition of two consecutive successful tests prior to resuming the Type A test interval of Section III.D.
As an alternative to performing the required Type A test, the licensee has submitted a Corrective Action Plan to address excessive local leakage in accordance with the guidance provided in NRC Information Notice 85-71,
" Containment Integrated Leak Rate Tests," dated August 22, 1985. The Corrective Action Plan is in lieu of the increased test frequency required by Section III.A.6(b) and, therefore, an exemption from this requirement is needed.
Section III.D.1(a) of Appendix J requires "... a set of three Type A tests shall be performed, at approximately equal intervals during each 10-year service period. The third test of each set shall be conducted when the plant is shutdown for the 10-year plant inservice inspections." The last refueling outage for Unit 2 during the first 10-year inservice inspection period is the sixth refueling outage scheduled for February 1995.
Therefore, in addition to
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the requirements for additional testing specified in Section III.A.6(b), a Type A test is required during the upcoming Unit 2 refueling outage as a i
result of the periodic retest schedule contained in Section III.D.1(a). To address the short-term desire not to perform a Type A test during the sixth refueling outage for Unit 2 and avoid potential future problems, the licensee I
has requested an exemption from this requirement such that future Type A tests would not need to coincide with the end of 10-year inservice inspection periods.
The NRC may grant exemptions from the requirements of the regulations.
pursuant to 10 CFR 50.12, that (1) are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; and (2) present special circumstances. Section 50.12(a)(2) of 10 CFR Part 50 describes special circumstances as including cases that would not serve the underlying purpose of the rule or are not necessary to achieve the underlying purpose of the rule.
III.
i The underlying purpose of the requirements in Appendix J is to ensure that containment leakage remains below criteria established to limit the release of radioactive materials in the event of a design basis accident.
The Type A test is defined in 10 CFR Part 50, Appendix J, Section II.F, as a
" test intended to measure the primary reactor containment overall integrated leakage rate (1) after the containment has been completed and is ready for operation, and (2) at periodic intervals thereafter." Containment leakage is P
measured during the periodic testing required by Section III.D.l(a) and the additional testing requirements of Section III. A.6 if the measured leakage
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C.,
exceeds the established limits. The testing and other requirements contained.
j in Appendix J ensure that leakage from the containment structure and penetrations remain below the acceptance criteria.
The licensee conducted four ILRTs during the first 10-year service t
period for Unit 1.
For Unit 2, ILRTs were performed during the first, third, i
fourth, and fifth refueling outages.
The Type A test history for Unit 2-is l
that the measured leakage rates for Type B and C penetrations, when added to the measured results from the Type A test, resulted in an "as-found" integrated leakage rate above the acceptance criteria. These test failures were the direct result of leakage penalties from Type B and C LLRTs.
Leakage from specific containment penetrations that have been major contributors to the failure of the integrated leakage rate acceptance criteria for bnit 2 have been identified. These leakage paths include isolation valves associated with the drywell equipment and floor drain sumps, reactor water cleanup suction, transversing incore probe air purge supply, residual heat removal shutdown cooling return, hydrogen recombiners, and primary containment I
chilled water supply. The leakage associated with the reactor water cleanup suction penetration provided the overwhelming contribution of local leakage penalty that resulted in the unsuccessful test during the fourth refueling outage. Leakage through the various isolation valves has been attributed to causes such as the introduction of foreign materials, misapplication of valve types, insufficient seating, defective valve internals, and failure of valve i
motor operators.
Specific corrective actions have addressed the above contributors by improving foreign material exclusion controls, replacing and refurbishing valves, revising test procedures, and cleaning and lapping l
b i
. seating surfaces. Overall performance of the identified penetrations has improved significantly.
In addition to the specific corrective actions taken for the above isolation valves, the licensee's Corrective Action Plan includes programmatic changes to limit the leakage occurring from Type C penetrations.
These changes include development and implementation of an improved trending program to track penetration and valve leakage rate performance. The 3mproved trending will be designed to help determine any patterns or groups of valves that demonstrate either good or poor leakage behavior. Those penetrations determined to be susceptible to excessive leakage will also be subject to additional testing requirements beyond that routinely performed during refueling outages.
Identified penetrations will be subject to Type B or C testing during any non-refueling outage for which a unit is in cold shutdown for fourteen days or longer.
Poorly performing penetrations will also be reviewed for possible improvements in testing methods as well as possible repair, modification, or replacement of isolation devices.
As discussed in Information Notice 85-71, the staff has determined that:
"... if Type B and C leakage rates constitute an identified contributor to this failure of the "as-found" condition for the Type A test, the general purpose of maintaining a high degree of containment integrity might be better served through an improved maintenance and testing program for containment penetration boundaries and isolation valves.
In this situation, the licensee may submit a Corrective Action Plan with an alternative leakage test program proposal as an exemption request for NRC staff review.
If this submittal is approved by the NRC staff, the licensee may implement the corrective action and alternative leakage test program in lieu of the required increase in Type A test frequency incurred after the failure of two successive Type A tests."
.. ~
l The licensee's Corrective Action Plan describes the modification, testing and preventive maintenance programs implemented or planned to decrease the leakage from poorly performing isolation devices. The specific corrective actions performed to date and the programmatic changes associated with ensuring future performance of penetrations provide an equivalent degree of i
assurance that containment integrity will be maintained as that provided by an additional Type A test performed on the accelerated frequency specified by Section III.A.6(b) of Appendix J.
The NRC staff concludes that a return to the normal retest interval of Section III.D of Appendix J is justified and l
that the corrective actions taken and the creation of the Corrective Action Plan for local leak rate testing adequately address the underlying purpose.of the requirements of Appendix J.
In the absence of the additional testing requirements of Section i
III.A.6(b), a periodic retest schedule is specified in Section_III.D.1(a).
1 This retest schedule requires a minimum of three tests during a 10-year service period with the third test coinciding with the 10-year plant inservice inspections.
LaSalle, Unit 1, completed four tests during the first ten year interval with the last test coinciding with the 10-year plant inservice inspections. Due to expcriencing Type A test failures, Unit 2 has performed four tests during the first 10-year service period and without the requested exemptions would be required to perform a fifth Type A test during the sixth refueling outage. The sixth refueling outage for Unit 2 is the last refueling outage of the 10-year inservice inspection period 'and, therefore, the Type A test is required based on the requirements of Section III.D.l(a) as well as I
the previously discussed requirements of Section III.A.6(b).
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'Pursu' ant to Section.II.F of Appendix J, the intent of Type A' testing is.
1
"...to measure the primary reactor containment overall integrated leakage rate
... at periodic. intervals...." The licer.see has conducted a. total.of eight j
l ILRTs for LaSalle,' Units 1 and 2.
Tiie tests conclude'that the largest l
variations in the measured overall leak rates' result from the adjustments i!
I required to account for leakage from Type B and C penetrations.
Leakage from i:!
sources other than those covered by Type B and C testing, such.as the j
containment structure itself, have repeatedly been well below the acceptance-j criteria. The requested exemption from Section III.D.l(a) does not affect the i
performance of local leak rate testing which would be expected to detect the I
i most probable sources of containment leakage. As discussed above, the' licensee will not only continue routine Type B and C testing during each refueling outage, but will also attempt to minimize local leakage in i
accordance with their Corrective Action Plan.
I The proposed exemption from Section III.D.1(a) does not revise the i
expected Type A test interval of between thirty and fift.i months which is l
derived from the requirement to perform three tests in each ten year period at l
approximately equal intervals. For example, Unit 2 performed a Type A test
.l during the fifth refueling outage in December'1993 and, with the proposed exemption, will perform another Type A test during the seventh' refueling l
outage scheduled to begin in late 1996.. The licensee has only proposed to i
a exempt the requirement to perform'a Type A test during the 10-year plant l
?
inservice inspections. Given the continued performance of Type A testing at approximately equal intervals of forty months and the performance of Type B t
and C testing at the required intervals to identify the most probable sources
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ow
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0 of containment leakage, the NRC staff finds that performance of Type A tests coincident with 10-year plant inservice inspections is not necessary to achieve the underlying purpose of the rule.
On the bases of the above discussions related to Sections _III.A.6(b) and III.D.1(a) of Appendix J, the NRC staff finds that the' licensee has demonstrated that special circumstances are present as required by l
Further, the staff finds that providing a one-time exemption of the additional testing requirements of Section III.A.6(b) and an exemption from the requirement to perform a Type A test coincident with the first 10-year plant inservice inspections pursuant to Section III.D.l(a) will not present undue risk to the public health and safety. Although requested as a permanent exemption, the exemption from the requirements of Section III.D.1(a) of Appendix J related to the third test coinciding with the 10-year plant I
inservice inspections has been granted as a one-time exemption for the first 10-year inservice inspection interval.
The exemption is, in effect, limited to the Type A test planned for the current Unit 2 outage since Unit I has L
completed the required Type A tests during its first inservice inspection interval.
Future relationships between Appendix J and inservice inspection intervals can be addressed by anticipated changes to Appendix J or requests for exemptions from the current requirements.
IV.
Accordingly, the Commission has determined pursuant to 10 CFR 50.12, these exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.
Therefore, the Commission hereby grants an exemption from the additional
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testing requirements of Section III. A.6(b).of Appendix J to 10.CFR Part 50 to.
allow the licensee to resume the Type A test interval of Section III.D for 6
LaSalle, Unit 2, and' an exemption from~ the requirements of Section III.D.1(a) of Appendix J to allow the licensee to de-couple the Type A testing and the first.10-year plant inservice inspections for LaSalle, Unit 2.
Pursuant to 10 CFR 31.32, the Commitsion determined that the granting of this exemption will~ have no significant impact on the quality of the human environment (60 FR 13187).
FOR THE NUCLEAR REGULATORY COMMISSION
=
Elinor G. Adensam, Acting Director Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 10thday of March 1995 i
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.7590-01 L
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
COMMONWEALTH EDISON COMPANY
)
Docket Nos. 50-373
)
50-374 (LaSalle County Station,
)
Units 1 and 2)
)
EXEMPTION I.
Commonwealth Edison Company (Comed, the licensee) is the holder of i
facility Operating License Nos. NPF-II and NPF-18, which authorize operation of the LaSalle County Station, Units I and 2 (the facility), at a steady state power level not in excess of 3323 megawatts thermal. The facility consists of two boiling water reactors at the licensee's site located in LaSalle County, Illinois.
The licenses provide, among other things, that they are subject to all rules, regulations, and orders of the U. S. Nuclear Regulatory Commission (the Commission) now or hereafter in effect.
II.
i Section III.A.6(b) of Appendix J to_10 CFR Part 50 states the following in regard to performing Overall Integrated Containment Leakage Rate (Type A)
Tests (ILRT):
If two consecutive periodic Type A tests fail to meet the applicable acceptance criteria in III.A.5(b), notwithstanding the i
periodic retest schedule of III.D., a Type A test shall be j
performed at each plant shutdown for refueling or approximately i
every 18 m;nths, whichever occurs first, until two consecutive i
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.2-i Type A tests meet the acceptance criteria in III.A.5(b), after which time the. retest schedule specified in III.D. may be resumed..
The Type A tests performed during the first, third and fourth refueling outages for LaSalle County Station, Unit 2, were considered to be failures in 5
the "as-found" condition due to penalties incurred as a result of leakage.
measured in Type B and C local leak rate tests (LLRT).
Pursuant to Section III.A.6(b) of Appendix J, Type A testing was performed during the fifth refueling outage for LaSalle County Station, Unit 2, in December 1993.
That Type A test satisfied the "as-found" acceptance criteria..Section III.A.6(b) of Appendix J requires an additional Type A test during the sixth
}
refueling outage, currently scheduled for February 1995, in order to fulfil j
the condition'of two consecutive successful tests prior to resuming the Type A l
test interval of Section 111.D.
As an alternative to performing the required Type A test, the licensee has submitted a Corrective Action Plan to address excessive local leakage in accordance with the guidance provided in NRC Information Notice 85-71, l
" Containment Integrated Leak Rate Tests," dated August 22, 1985.
The Corrective Action Plan is in lieu of the increased test frequency required by Section III.A.6(b) and, therefore, an exemption from this requirement is needed.
Section III.D.l(a) of Appendix J requires "... a set of three Type A-tests shall be performed, at approximately equal intervals during each 10-year service period. The third test of each set shall be conducted when the plant is shutdown for the 10-year plant inservice inspections." The last refueling outage for Unit 2 during the first 10-year inservice inspection period is the sixth refueling outage scheduled for February 1995. Therefore, in addition to
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the requirements for additional testing specified in Section III.A.6(b), a Type A test is required during the upcoming Unit 2 refueling outage as a result of the periodic retest schedule contained in Section III.D.1(a). To address the short-term desire not to perform a Type A test during the sixth refueling outage for Unit 2 and avoid potential' future problems, the licensee has requested an exemption from this requirement such that future Type A tests would not need to coincide with the end of 10-year inservice inspection periods.
The NRC may grant exemptions from the requirements of the regulations, pursuant to 10 CFR 50.12, that (1) are authorized by law, will not present an ~
undue risk to the public health and safety, and are consistent with the common defense and security; and (2) present special circumstances. Section i
SD.12(a)(2) of 10 CFR Part 50 describes special circumstances as including cases that would not serve the underlying purpose of the rule or are not necessary to achieve the underlying purpose of the rule.
1 III.
The underlying purpose of the requirements in Appendix J is to ensure that containment leakage remains below criteria established to limit the
)
release of radioactive materials in the event of a design basis accident.
The Type A test is defined in 10 CFR Part 50, Appendix J, Section II.F, as a I
" test intended to measure the primary reactor containment overall integrated leakage rate (1) after the containment has been completed and is ready for operation, and (2) at periodic intervals thereafter." Containment leakage is i
measured during the periodic testing required by Section III.D.1(a) and the 1
additional testing requirements of Section III.A.6 if the measured leakage
.4 i; -
i exceeds the established limits. The testing and other requirements contained in Appendix J ensure that leakage from the containment structure and penetrations remain below the acceptance criteria.
t The licensee conducted four ILRTs during the first 10-year service period 'for Unit 1.
For Unit 2, ILRTs were performed during the first, third, fourth, and fifth refueling outages.
The Type A test history for Unit 2 is that the measured leakage rates for Type B and C penetrations, when added to the measured results from the Type A test, resulted in an "as-found" integrated leakage rate above the acceptance criteria.
These test failures were the direct result of leakage penalties from Type B and C LLRTs.
Leakage from specific containment penetrations that have been major contributors to the failure of the integrated leakage rate acceptance criteria for Unit 2 have been identified.
These leakage paths include isolation valves associated with the drywell equipment and floor drain sumps, reactor water cleanup suction, transversing incore probe air purge supply, residual heat removal shutdown cooling return, hydrogen recombiners, and primary containment chilled water supply. The leakage associated with the reactor water cleanup suction penetration provided the overwhelming contribution of local leakage penalty that resulted in the unsuccessful test during the fourth refueling outage.
Leakage through the various isolation valves has been attributed to causes such as the introduction of foreign materials, misapplication of valve types, insufficient seating, defective valve internals, and failure of valve j
motor operators.
Specific corrective actions have addressed the above contributors by improving foreign material exclusion controls, replacing and refurbishing valves, revising test procedures, and cleaning and lapping t
7
'CL seating surfaces. Overall performance of the identified penetrations has improved significantly.
In addition to the specific corrective actions taken for the a'ove-isolation valves, the licensee's Corrective Action Plan includes programmatic i
changes to limit the leakage occurring from Type C penetrations. These changes include development and implementation of an improved trending program to track penetration and valve leakage rate performance. The improved trending will be designed to help determine any patterns or groups of valves that demonstrate either good or poor leakage behavior.
Those penetrations determined to be susceptible to excessive leakage will also be subject to additional testing requirements beyond that routinely performed during refueling outages.
Identified penetrations will be subject to Type B or C testing during any non-refueling outage for which a unit is in cold shutdown for fourteen days or longer.
Poorly performing penetrations will also be reviewed for possible improvements in testing methods as well as possible repair, modification, or replacement of isolation devices.
As discussed in Information Notice 85-71, the staff has determined that:
"... if Type B and C leakage rates constitute an identified contributor to this failure of the "as-found" condition for the Type A test, the general purpose of maintaining a high degree of containment integrity might be better served through an improved maintenance and testing program for containment penetration boundaries and isolation valves.
In this situation, the licensee may submit a Corrective Action Plan with an alternative leakage test program proposal as an exemption request.for NRC staff review.
If this submittal is approved by the NRC staff, the licensee may implement the corrective action and alternative leakage test program in lieu of the required increase in Type A test frequency incurred after the failure of two successive Type A tests."
u
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6-The licensee's Corrective Action Plan describes the modification, _
testing and preventive maintenance programs implemented or planned to decrease the leakage from poorly performing isolation devices. The specific corrective actions performed to date and the programnatic changes associated with ensuring future performance of penetrations provide an equivalent degree of assurance that containment integrity will be maintained as that provided by an additional Type A test performed on the accelerated frequency specified by i
Section III. A.6(b) of Appendix J.
The NRC staff concludes that a return to i
I the normal retest interval of Section III.D of Appendix J is. justified and l
that the corrective actions taken and the creation of the Corrective Action Plan for local leak rate testing adequately address the underlying purpose of the requirements of Appendix J.
In the absence of the additional testing requirements of Section III.A.6(b), a periodic retest schedule is specified in Section III.D.1(a).
This retest schedule requires a minimum of three tests during a 10-year service period with the third test coinciding with the 10-year plant inservice inspections.
LaSalle, Unit 1, completed four tests during the first ten year interval with the last test coinciding with the 10-year plant inservice I
inspections. Due to experiencing Type A test failures, Unit 2 has performed four tests during the first 10-year service period and without the requested exemptions would be required to perform a fifth Type A test during the sixth refueling outage. The sixth refueling outage for Unit 2 is the last refueling outage of the 10-year inservice inspection period and, therefore, the Type A test is required based on the requirements of Section III.D.l(a) as well as the previously discussed requirements of Section III.A.6(b).
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Pursuant to Section II.F of Appendix J, the intent of Type A testing is
"...to measure the primary reactor containment overall integrated leakage rate
... at periodic intervals...." The licensee has corducted a total of eight t
ILRTs for LaSalle, Units 1 and 2.
The tests conclude that the largest f
variations in the measured overall leak rates result from the adjustments required to account for leakage from Type B and C penetrations.
Leakage from sources other than those covered by Type B and C testing, such as the containment structure itself, have repeatedly been well below the acceptance criteria. The requested exemption from Section III.D.1(a) does not affect the performance of local leak rate testing which would be expected to detect the most probable sources of containment leakage. As discussed above, the i
licensee will not only continue routine Type B and C testing during each refueling outage, but will also attempt to minimize local leakage in l
accordance with their Corrective Action Plan.
t The proposed exemption from Section III.D.I(a) does not revise the expected Type A test interval of between thirty and fifty months which is derived from the requirement to perfcrm three tests in each ten year period at
{
l approximately equal intervals. For example, Unit 2 performed a Type A test t
during the fifth refueling outage in December 1993 and, with the proposed exemption, will perform another Type A test during the seventh refueling outage scheduled to begin in late 1996. The licensee has only proposed to i
exempt the requirement to perform a Type A test during the 10-year plant inservice inspections. Given the continued performance of Type A testing at approximately equal intervals of forty months and the performance of Type B and C testing at the required intervals to identify the most probable sources
l l
of containment leakage, the NRC staff finds that performance of Type A tests coincident with 10-year plant inservice inspections is'not necessary to achieve the underlying purpose of the rule.
On the bases of the above discussions related to Sections III.A.6(b) and III.D.1(a) of Appendix J, the NRC staff finds that the licensee has demonstrated that special circumstances are present as required by i
Further, the staff finds that providing a one-time exemption of the additional testing requirements of Section III.A.6(b) and an exemption from the requirement to perform a Type A test coincident with the first 10-year plant inservice inspections pursuant to Section.III.D.l(a) will not present undue risk to the public health and safety. Although requested as a permanent exemption, the exemption from the requirements of Section III.D.l(a) of Appendix J related to the third test coinciding with the 10-year plant inservice inspections has been granted as a one-time exemption for the first 10-year inservice inspection interval.
The exemption is, in effect, limited to the Type A test planned for the current Unit 2 outage since Unit I has completed the required Type A tests during its first inservice inspection l
interval.
Future relationships between Appendix J and inservice inspection intervals can be addressed by anticipated changes to Appendix J or requests for exemptions from the current requirements.
IV.
Accordingly, the Commission has determined pursuant to 10 CFR 50.12, these exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.
Therefore, the Commission hereby grants an exemption from the additional
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i testing requirements of Section III.A.6(b) of Appendix J to 10 CFR Part 50 to e
allow the licensee to resume the Type A test interval of Section III.D for i
i LaSalle, Unit 2, and an exemption from the requirements of Section III.D.1(a) l of Appendix J to allow the licensee to de-couple the Type A testing and the first 10-year plant inservice inspections for LaSalle, Unit 2.
t Pursuant to 10 CFR 31.32, the Commission determined that the granting of this exemption will have no significant impact on the quality of the human environment (60 FR 13187).
FOR THE NUCLEAR REGULATORY COMMISSION t
<===
Elinor G. Adensam, Acting Director Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 10thday of March 1995 i
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l testing requirements of Section III.A.6(b) of Appendix J to 10 CFR Part 50 to s
allow the licensee to resume the Type A test interval of Section III.D for F
LaSalle, Unit 2, and an exemption from the requirements of Section III.D.l(a)
L of Appendix J to allow the licensee to de-couple the Type A testing and the i
first 10-year plant inservice inspections for LaSalle, Unit 2.
Pursuant to 10 CFR 31.32, the Commission determined that the granting of this exemption will have no significant impact on.the quality of the human environment (60 FR 13187).
FOR THE NUCLEAR REGULATORY COMMISSION Original signed by:
i Elinor G. Adensam, Acting Director Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 1001 day of March 1995 1
- See previous concurrence is receive a[ctipy of this document. indicate in the box:
"C" " Copy without enclosures "E" " Copy with enclosures "u" = No copy 0FFICE LA:NDIfT-2l4-PM:PDIII-2 l[
BC:SCSB OGC l PD:PDIII-2lE (A)T:08PWI I
NAME
( foore' W. Reckley:lm R. Barrett C. Marco R. Capra %c, E. A1Vnsam DATE 03/(i /95 03/
!/95 02/17/95*
02/28/95*
OJ/o1/95 03/("/95 1
0FFICIAL RECORD COPY
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