ML20081D667
| ML20081D667 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/16/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20081D657 | List: |
| References | |
| GL-91-08, GL-91-8, GL-93-05, GL-93-5, NUDOCS 9503200355 | |
| Download: ML20081D667 (10) | |
Text
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UNITED STATES j
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j NUCLEAR REGULATORY COMMISSION t
WASHINGTON. D.C. 30666-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j
RELATED TO AMENDMENT NO.102 TO FACILITY OPERATING LICENSE NO. NPF-ll AND l
AMENDMENT NO. 87 TO FACILITY OPERATING LICENSE NO. NPF-18 COMMONWEALTH EDISON COMPANY l
l LASALLE COUNTY STATION. UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374 1.0 LNTRODUCTION By letter dated October 24, 1994, the Commonwealth Ediron Company (Comed, the licensee) requested changes to the Technical Specifications (TS) for the LaSalle County Station, Units 1 and 2, and exemptions from certain requirements of Appendix J to 10 CFR Part 50.
The propoud amendments restructure the primary containment and primary containment leakage TSs to reduce the repetition of those requirements contained in Appendix J to 10 CFR Part 50. The amendments also support the licensee's requested exemptions from Appendix J requirements related to the scheduling of containment integrated i
leakage rate tests. The staff has addressed the requested exemptions separately from the review of these amendments.
In addition to the i
restructuring and scheduling changes, the amendments incorporate the i
relocation of the list of primary containment isolation valves in accordance j
with Generic Letter 91-08 and a revision to the interval for functional i
testing of hydrogen recombiners in accordance with Generic Letter 93-05.
2.0 BACKGROUND
'f Section III.D.l(a) of Appendix J to 10 CFR Part 50 requires the performance of three Type A tests, overall integrated leakage rate tests (ILRTs),- at i
approximately equal intervals during each 10-year service period with the third test of each set being condacted when the plant is shutdown for the 10-year plant inservice inspections.
Section III.A.6(b) of Appendix J to 10 CFR Part 50 specifies additional requirements if two consecutive periodic Type A tests fail to meet the applicable acceptance criteria. The additional requirements entail performing Type A tests at each plant shutdown for refueling or eighteen month interval, whichever occurs first, until two consecutive Type A tests meet'the acceptance criteria, after which, the testing schedule of Section III.D may be resumed.
LaSalle County Station, Unit 2 experienced Type A tcut failures for the "as-found' condition at the first, third and fourth refueling outages as a result of penelties from local i
leak rate test (LLRT) (Type B and C) failures.
Pursuant to the requirements 4
of Section III.A.6(b), a Type A test was performed during the fifth refueling outage for Unit 2 and the results satisfied the applicable acceptance criteria.
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9503200355 950316 PDR ADOCK 05000373 P
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The licensee has requested exemptions from the requirements of Section j
III.A.6(b) of Appendix J in support of not performing a Type A test during the sixth refueling outage for Unit 2, scheduled for early 1995.
Specifically,
.the requested exemption is from the requirements of Section III.A.6(b) related I
to performing two consecutive successful tests prior to resuming the normal testing interval.
In addition, the licensee has requested an exemption from Section III.D.l(a) of Appendix J which requires a Type A test during the i
10-year inservice inspections because the sixth refueling outage is the last-refueling outage of the first 10-year plant inservice inspection period.
The licensee proposes to resume the testing interval of Section III.D based upon
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the successful test during the fifth refueling outage and the creation of a-corrective action plan for Type C test failures and decouple the Type A test schedule from the inservice inspection period. The results of this proposal would be that the next scheduled Type A test would be performed during the seventh refueling outage for Unit 2 (currently scheduled for late 1996) in accordance with a test interval of 40 i 10 months.
The staff is addressing the licensee's request for exemption from the above requirements of Appendix J as a separate action from this proposed TS amendment.
The proposed amendment can be divided into three distinct technical areas.
The first involves the restructuring of the primary containment integrity
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specification, TS 3/4.6.1, and primary containment leakage specification, i
TS 3/4.6.2, into a revised limiting condition for operation (LCO) and related surveillance requirements (SR). The resultant LCO and surveillances proposed by the licensee are similar to the content of NUREG-1433, Revision 0,
" Standard Technical Specifications, General Electric Plants, BWR/4." The second significant change proposed by the licensee is the relocation of Table 3.6.3-1, " Primary Containment Isolation Valves," from the TS to plant procedures and the Updated Final Safety Analysis Report (UFSAR) in accordance with Generic letter 91-08, " Removal of Component Lists from Technical Specifications." The third change involves a revision of the interval for functional testing of hydrogen recombiners from 6 months to 18 months in accordance with Generic Letter 93-05, "Line-Item Technical Specifications i
Improvements to Reduce Surveillance Requirements for Testing During Power
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Operation."
The change related to the relocation of the list of containment isolation valves as well as several aspects of the restructuring of the containment 1
integrity specification involve relocation of existing specifications to licensee controlled documents such as the UFSAR. The Commission's regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36.
However, the regulation does not specify the particular requirements to be included in a plant's TSs. The Commission has provided guidance for the contents of TSs in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"),
58 Federal Reaister 39132 (July 22,1993), in which the Commission indicated t
that compliance with the Final Policy Statement satisfies Section 182a of the Atomic Energy Act.
In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co. (Trojan Nuclear 1
4
. Plant), ALAB-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that " technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the
'ossibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether a particular matter is required to be included in the TSs, as follows:
(1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. As a result, existing TS requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retainea in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to licensee-controlled documents.
3.0 EVALUATION Primary Containment Intearity and leakaae Specifications The evaluation of the changes to the primary containment integrity and leakage specifications will be presented by providing a description and evaluation for the proposed disposition for each of the affected individual requirements contained in the existing specifications. lhe existing TS 3/4.6 contains details that are also found in Appendix J to 10 CFR Part 50.
The regulations require licensee compliance and can not be revised by the licensee.
The proposed changes include the statement "... in accordance with and at the frequency specified by 10 CFR 50, Appendix J, as modified by approved exemptions." Therefore, direct reference to Appendix J eliminates the need for repetitious and unnecessary details within the TS.
This is consistent with previous staff positions expressed in safety evaluations and the standard TSs and is considered to be administrative in nature.
Therefore, detailed discussions or rationale will not be provided for those items removed from the 15 based on the existence of similar requirements in Appendix J to 10 CFR Part 50.
LC0 3.6.1.1, Primary Containment Integrity, and the associated Applicability and Actions are not changed by the proposed revisions.
4 SR 4.6.1.1.a involves the performance of Type B tests after the closing of subject penetrations with the resultant leakage to be added to other Type B and C penetration leakages with the acceptance criteria for the combined leakage rate to be less than or equal to 0.60 L,.
The licensee proposes to delete this SR and states that the requirement is captured by the revised surveillance 4.6.1.1.b which requires testing "in accordance with and at the frequency specified by 10 CFR 50, Appendix J, as modified by approved exemptions." The acceptance criterion for.the Type B and C combined-leakage is retained in the proposed TS at the 0.60 L value. The staff finds that the requirements of the existing SR,4.6.1.1.a that are being deleted are repetitious of the requirements of Appendix J Section III, Leakage Testing Requirements. The change is, therefore, acceptable.
SR 4.6.1.1.b is renumbered and changed to reflect the relocation of Table 3.6.3-1, Primary Containment Isolation Valves. This change is addressed in a later section of this evaluation.
SRs 4.5.1.1.c, d, and e are unchanged.
LCO 3.6.1.2, Primary Containment Leakage, defines limiting leakage rates for: (a) overall containment leakage (L, (b) combined leakage for listed penetrations, (c) leakage t)hrough the main steam isolation valves, and (d) combined leakage throegh valves which are hydrostatically tested.
The licensee proposes to restructure the TS such that the current LCO regarding overall containment leakage is addressed by the revised 4.6.1.1.b which addresses testing in accordance with Appendix J.
The numerical value for L is included in a TS Definition for L. The combined leakage for pe,netrations, 0.60 L,, is captured by fhe revised surveillance 4.6.1.1.b.
The specific limits for main steam isolation valves and hydrostatically tested valves are relocated to 3/4.6.3, Primary Containment Isolation Valves, as a new SR 4.6.3.6.
The staff finds that the current requirements in LC0 3.6.1.2 are adequately addressed by the relocation of requirements within the TS as proposed by the licensee or are repetitious of the requirements explicitly provided in Appendix J.
This change is acceptable.
4 The existing Actions associated with various components of LC0 3.6.1.2 are to restore conditions to within the LC0 requirements.
This option is implicit for all LCOs. Therefore, this provision is-unnecessary and omitting these actions is purely editorial. Since the LCO's are adequately addressed, as discussed above, and since the existing Actions do not contribute any additional requirements, the staff finds their deletion acceptable.
SR 4.6.1.2.a dictates the normal Type A test interval of 40 i 10 months with the third test of each set being conducted during the i
shutdown for the 10-year plant inservice inspections. This
m o-f requirement is generally repetitious of the requirements of Section III.D.l(a) which requires three Type A tests, at approximately equal intervals, during each 10-year service period with the third test of each set performed during the 10-year plant inservice inspections.
The only detail that the existing TS provides beyond repeating the Appendix J requirements is that the approximately equal interval is defined as 40 1 10 months. The licensee has stated that this-interval will be placed in the UFSAR and controlled in accordance with 10 CFR 50.59, Changes, Tests and Experiments. This detail is not considered to be a significant refinement of the requirements given in Appendix J and is supported by the numerous licensing amendments issued to extend the Type A test interval beyond 50.
months. The staff finds that the Type A testing interval is adequately controlled by the wording contained in Appendix J, the inclusion of the 40 i 10 month interval in the UFSAR and control of any changes to that stated interval band in accordance with 10 CFR 50.59.
SR 4.6.1.2.b provides requirements for additional testing in the event of one or consecutive failures of Type A tests.
The wording contained in the TS is repetitious of the requirements of Sections III.A.6(a) and (b) of Appendix J.
This requirement is captured by the revised TS 4.6.1.1.b which states that testing shall be performed in accordance with and at the frequency specified by Appendix J, as modified oy approved exemptions. The staff finds that the revised TS 4.6.1.1.b, with references to Appendix J and approved exemptions, adequately defines the requirements for additional testing following Type A test failures.
SR 4.6.1.2.c require; the verification of the accuracy of each Type A test by the performance of a supplemental test. The requirement and criteria are repetitious of Section III.A.3(b) of Appendix J.
Therefore, removal of the TS requirement is considered to be administrative or editorial in nature. The revised SR 4.6.1.1.b requiring testing in accordance with Appendix J, as modified by approved exemptions and the specific requirements of Appendix J Section III.A.3(b), adequately control the accuracy provisions of the deleted TS.
SR 4.6.1.2.d requires Type B and C testing at intervals of no greater than 24 months except for tests involving air locks, main steam isolation valves, valves pressurized with seal fluids, and hydrostatically tested lines. These exceptions are addressed by other TS requirements (items 4.6.1.2.e-h) and previous exemptions from Appendix J.
This existing TS requirement is repetitious of Section III.D.2(a) of Appendix J and the proposed deletion is, therefore, considered to be administrative in nature.
SR 4.6.1.2.e specifies that, " Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3."
The l
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exception for the testing of air locks is specified in proposed SR i
4.6.1.1.b as an exception to Appendix J.
The specific requirements for the primary containment air lock for each unit are currently, r
and will remain, as specification 3/4.6.1.3, Primary Containment Air 1
Locks. Also, the Definition of Primary Containment Integrity refers to specification 3.6.1.3.
Therefore, the air lock testing and j
operability requirements are retained in TSs and are not affected by this proposed amendment. The staff finds the proposed change acceptable.
Current SR 4.6.1.2.f requires special frequency requirements for leak rate-testing for main steam lines through the isolation valves.
The existing LC0 3.6.1.2.c, provides special acceptance criteria of "less than er equal to 100 scf per hour for all four main steam lines through the isolation valves when tested at 25.0 psig." The i
LC0 is modified by footnote *, that states this is an " exemption to Appendix J of 10 CFR Part 50."
This testing requirement, frequency, i
and acceptance criteria are relocated to specification 3/4.6.3, Primary Containment Isolation Valves, as proposed SR 4.6.3.6.a.
This assures that the exemption concerning the main steam lines through the isolation valves is clearly separated from Type B and C combined leakage rate. The revised SR 4.6.1.1.b also reflects the current exemption of air locks and the main steam isolation valves from testing in accordance with Appendix J.
The main steam line leakage through the isolation valves is excluded from the Type B and C combined leakage rate, because the main steam line leakage through the isolation valves is separately accounted for in the loss-of-coolant accident (LOCA) analysis for the. dose consequences.
The staff's approval of this exemption is documented in NUREG-0519,
" Safety Evaluation Report Related to the Operation of LaSalle County Station, Units 1 and 2."
To maintain this-exemption, proposed SR 4.6.3.6.a is modified by a footnote. Therefore, the approved exemption regarding the leakage test requirements for main steam lines through the isolation valves is maintained as worded in proposed SR 4.6.3.6.a.
The staff finds that the revised SR 4.6.3.6 properly maintains the requirements of the existing TS LC0 and SR, R
and that there are no resultant changes-in requirements.
The proposed change is acceptable.
SR 4.6.1.2.g concerning special testing requirements to be met for I
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leakage from isolation valves that are sealed with fluid from a seal system, is consistent with Appendix J section III.C.3. Therefore, since proposed SR 4.6.1.1.b requires testing and test frequency in accordance with 10 CFR 50, Appendix J, and approved exemptions, the requirements are maintained and the changes are considered administrative or editorial in nature. The staff finds the changes acceptable.
SR 4.6.1.2.h requires special frequency requirements for leak rate testing for ECCS and RCIC containment isolation valves in
hydrostatically tested lines which penetrate the primary containment. The existing LCO 3.6.1.2.d, provides special acceptance criteria as follows:
"A combined leakage rate of less than ar equal to I gpm times the total number of ECCS and RCIC containment isolation valves in hydrostatically tested lines which penetrate the primary containment, when tested at 1.10 P,, 43.6 psig." This testing requirement, frequency, and acceptance criteria are relocated to specification 3/4.6.3, Primary Containment Isolation Valves as proposed SR 4.6.3.6.b.
This assures that the special surveillance frequency and acceptance criteria concerning ECCS and RCIC containment isolation valves in hydrostatically tested lines remain clearly separated from Type B and C combined leakage rate. The staff's approval of the exclusion of these valves when determining the combined leakage rate for all penetrations and' valves as specified in Paragraph III.C.3 of Appendix J was documented in NUREG-0519.
To maintain this exemption, proposed SR 4.6.3.6.b is modified by a footnote. The relocation of the requirements has no net effect on the testing or acceptable leakage through the effected valves. The staff finds the change acceptable.
SR 4.6.1.2.1 provides a statement that the provisions of TS 4.0.2 (maximum allowable extension of 25 percent for specified surveillance intervals) do not apply to the 24 month intervals associated with Type B and C testing or the 40 i 10 month interval for Type A testing. The licensee proposes to maintain a similar statement, "The provisions of Specification 4.0.2 are not applicable to the frequencies specified by 10 CFR 50, Appendix J," as a footnote to revised SR 4.6.1.1.b.
The staff finds it acceptable to include this footnote as a means to avoid confusion regarding the applicability of the 25 percent extension to the Appendix J defined intervals.
SR 4.6.2.1.d governs the conduct of drywell-to-suppression chamber bypass leakage tests. The licensee's proposed changes reflect the deletion of those requirements which the TSs state may be discontinued in the event certain criteria are satisfied. Given the criteria for discontinuing the testing of existing SR 3.6.2.d.2 were satisfied, the licensee's proposed changes are editorial in that no changes in current testing requirements or acceptance criteria have been requested.
The result of the changes is enhanced clarity by the deletion of outdated requirements that were only applicable during the early years of plant operation.
The staff finds the changes acceptable.
SR 4.6.4.3 requires that " vacuum breaker header flanges which have been broken shall be leak tested after remaking by Type B test at 39.6 psig per Specification 4.6.1.2.d."
The licensee proposes to delete this TS SR because the flanges are within the primary containment penetration boundary for vacuum bru ker penetrations and, therefore, subject to the requirements of ppendix J Section
.c 9-l III.D.2 which states "... If opened foH owing a Type A or B test,-
containment penetrations subject to Type B testing shall be Type B tested prior to returning the reactor to an operating mode requiring containment integrity." The revised SR 4.6.1.1.b requiring testing in accordance with Appendix J as modified by approved exemptions and the specific requirements of Appendix J Section III.D adequately control the performance of Type B testing following restoration of the vacuum breaker header flanges. The staff finds.the change acceptable.
SR 4.6.6.1.d requires the measurement of the -leakage rate associated with the drywell and suppression chamber hydrogen recombiner systems. The TS leakage testing is allowed to be performed as part of a Type A ILRT test or by measuring the leakage rate of the system outside the containment isolation valves. The drywell and suppression chamber hydrogen recombiner systems are designed to be part of the primary containment during an accident.
Therefore, Appendix J requires the system to either be open to the primary containment during a Type A test, or accounted for by a separate leak rate test that is included in the overall integrated leakage test. The staff finds that the requirements of the existing SR 4.6.6.1.d that are being deleted, are repetitious of the requirements of Appendix J.
The deletion of the SR from the TS is acceptable.
Relocation of Primary Containment Isolation Valve Table In accordance with the guidance provided by Generic letter 91-08, " Removal of Component Lists from Technical Specifications," the licensee has proposed to relocate Table 3.6.3-1, " Primary Containment Isolation Valves," from the TSs to Administrative Procedure and the UFSAR.
Various editorial changes are also necessitated by the removal of the table (the disposition of table footnotes and various references to the table throughout the TSs). A revier of the licensee's disposition of the existing footnotes to Table 3.6.3-1 found that the comments were either adequately addressed by other specifications, retained in section 3.6.3, Primary Containment Isolation Valves, or could be deleted without affecting the existing requirements.
Likewise, the editorial changes to address the reference to the table in various specifications were found to not to have any effect on the actual requirements contained in those specifications.
The staff's review of the proposed change determined that the relocation of Table 3.6.3-1 does not eliminate the requirements for the licensee to ensure containment isolation valves are capable of performing their safety function.
Although Table 3.6.3-1 is relocated from the TSs to an Administrative Procedure and the UFSAR, the licensee must continue to evaluate changes in accordance with 10 CFR 50.59. Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or
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malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would i
be required prior to _ implementation of the change. NRC inspection and i
enforcement programs also enable the staff to monitor facility changes and licensee adherence to UFSAR commitments and to take any remedial action that may be appropriate.
The staff's review concluded that 10 CFR 50.36 does not require the list of primary containment isolation valves to be retained in TSs. ' Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure operability of the isolation valves, are retained. However, the staff determined that the inclusion of list of isolation valves is an operational detail related to the licensee's safety analyses that are adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the table, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
The staff has concluded, therefore, that relocation of Table 3.6.3-1 is acceptable because: (1) the inclusion of the table in TSs is not specifically required by 10 CFR 50.36 or other regulations; (2) the list of isolation valves has been relocated to an Administrative Procedure and the UFSAR, changes to the valves are adequately controlled by 10 CFR 50.59, and their inclusion in the TS is not required to avert an immediate threat to the public health and safety; and (3) changes that are deemed to involve an unreviewed safety question, will require prior NRC approval in accordance with 10 CFR 50.59(c).
Extension of Hydroaen Recombiner Functional Test Interval The NRC has completed a comprehensive examination of SRs in the TSs that require testing during power operation. The evaluation is documented in NUREG-1366, " Improvements to Technical Specification Surveillance Requirements," dated December 1992.
The staff found that while the majority of testing at power is important, safety can be improved, equipment degradation decreased, and an unnecessary burden on personnel resources eliminated by relaxing a small fraction of the TS testing intervals. Based on the results of the evaluations documented in NUREG-1366, the NRC issued Generic 1.etter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation," dated September 27, 1993.
Section 8.5 of NUREG-1366, discusses the recommended change in the functional test interval for hydrogen recombiners from once per six months to once per refueling interval. The staff based this recommendation on system redundancies included in plant designs for post-accident hydrogen control and the apparent high reliability of hydrogen recombiner systems.
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o C The licensee proposed change to SR 4.6.6.1.b to change to the interval for performance of the hydrogen recombiner system functional test from six (6) months to eighteen (18) months is consistent with the recommendation in NUREG-1366.
In addition to the studies referenced in NUREG-1366, the licensee stated that the plant specific history for the recombiners at LaSalle are consistent with the generic reliabilities found by the staff.
Based upon the findings contained in NUREG-1366 and the plant specific evaluation performed by the licensee, the staff finds the proposed change to the hydrogen recombiner functional test interval from six months to eighteen months to be acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.
The NRC staff has determined 1
that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (60 FR 498). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR SI.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
i The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, i
and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
W. Reckley, NRR Date: March 16, 1995 I