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Application for Amends to Licenses NPF-11 & NPF-18,extending Specific 18 Month TS Surveillance Requirements to Allow Surveillance Testing
	ML20082J926
Person / Time
Site:	LaSalle
Issue date:	04/11/1995
From:	Benes G; COMMONWEALTH EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082J932	List: ML20082J926; ML20082J934;
References
	NUDOCS 9504180502
	Download: ML20082J926 (9)
	v • d • e

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. Commonwealth litison Company'-

. 1400 Opus Place -

'.' thm ners Grove, 11.60515 s- .

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' April 11,1995

. U.S. Nuclear Regulatory Commission l Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

LaSalle County Nuclear Power Station Units 1 and 2 Application for Amendment to Facility Operating Licenses NPF-11 and NPF-18,

. Extension of Specific LaSalle Surveillance Intervals NRC Docket Nos. 50-373 and 50-374

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Pursuant to 10 CFR 50.90, Comed proposes to amend Facility Operating Licenses !

NPF-11 and NPF-18. The proposed change to the LaSalle Unit 1 and LaSalle Unit 2 _

Operating Licenses is temporary and allows a one-time extension of specific LaSalle Unit'l and LaSalle Unit 218 month Technical Specification Surveillance .

Requirements to allow surveillance testing to coincide with the LaSalle Unit 1 seventh refueling outage, LIR07. The original scheduled shutdown for L1R07.was September 30,1995. Shutdown for L1R07 is now scheduled for January 27,1996.

The proposed amendment request is subdivided as follows: ,

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1. Attachment A gives a description and safety analysis of the proposed changes.

2. Attachment B includes the proposed changes to the Facility Operating Licenses fcr LaSalle Units 1 and 2.

3. Attachment C describes Comed's evaluation performed in accordance with 10 CFR 50.92 (c), which confirms that no significant hazard' consideration is involved.

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4. Attachment D provides an Environmental Assessment Applicability Review.

5. Attachment E lists the surveillance requirements to be extended.

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6. Attachment F provides the justification for surveillance intervals - ;

requiring extension.

This proposed amendment has been reviewed and approved by Comed On-Site and Off-Site Review in accordance with Comed procedures.

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USNRC April 11,1995 Without approval of' this amendment request, LaSalle Unit 1 would require a surveillance outage of approximately 21 days to perform the surveillances for which this request for interval extension is being made. Planning for this surveillance outage would require an extensive amount oflead time by Comed. Therefore, it is requested that this Unit 1 and Unit 2 License / Technical Specification amendment request be approved by July 15,1995.

! To the best of my knowledge and belief, the statements contained above are true and correct. In some respect these statements are not based on my personal-knowledge, but obtained infor. nation furnished by other Commonwealth Edison employees, contractor employees, and consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.

Commonwealth Edison is notifying the State ofIllinois of this application 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.

==:======:q, VeTY tTUIY YOUTB*

OFFICIAL SEAL ::

MARY JO YACK l ,

mTAav euauC, STATE OF WNOISl ll ((2 '

ll uy couMisscN EXPmES:1 W9M ' , (/ / d i

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Gary . Benes Nuclear Licensing Administrator t

Subscribed and Sworn to before me on this .

// M day of l Anazi ,1995. '

f Thw or n+d Notafy Pdgli'c [)

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- 1 USNRC April 11,1995 .

Attachments:

A. Description and Safety Analysis of the Proposed Changes B. Marked-Up pages to the Facility Operating Licenses for LaSalle Unit 1 and LaSalle Unit 2 !

C. Evaluation of Significant Hazards Considerations I D. Environmental Assessment Applicability Review E. Surveillance Requirements to be Extended.

F. Justification for Surveillance Intervals Requiring Extension.

ec: J. B. Martin, Regional Administrator - RIII P. G. Brochman, Senior Resident Inspector - LSCS W. D. Reckley, Project Manager - NRR Office of Nuclear Facility Safety - IDNS l

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES ,

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Descrintion of the Proposed Chance This is an Operating License / Technical Specification amendment request to extend LaSalle Unit One surveillance intervals to accommodate the extension of the current seventh fuel cycle. The original scheduled shutdown for the seventh refuel outage

( (L1R07) was September 30,1995. Shutdown is now scheduled for January 27,1996 l with scheduled startup for the eighth fuel cycle on or before April 5,1996. The i

surveillance intervals being extended are 18 month intervals. i Description of the Current Operatina License / Technical Snecification i Reauirement l Technical Specification 4.0.2 limits surveillance interval extensions to 25% of the !

specified surveillance intervals. !

"4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 l percent of the specified surveillance interval." l The Surveillances listed in Attachment E, " Surveillance Requirements to be Extended", are all 18 month surveillance intervals. Technical Specification Table 1.1 defines a once per 18 month surveillance frequency as 550 days. The maximum interval, the last full day of which is termed the " Critical Date", is thus 687.5 days.

l The Technical Specification refuel Surveillance Requirements begin exceeding the l limits of specification 4.0.2 on January 19,1996. The LaSalle Unit 1 seventh refuel outage, LIR07, is scheduled to begin January 27,1996, with the unit reaching Cold l Shutdown by January 29,1996. All of the Technical Specifications listed in Attachment E will either have their surveillance intervals expire prior to the Unit 1 shutdown for refuel or the Technical Specification requirements wil1 be applicable during the refuel outage. Therefore,18 month surveillance intervals for the systems / components listed in Attachment E will be exceeded while the systems / components are still required to be Operable per Technical Specifications.

Technical Specification 4.0.3 requires the following:

"4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed.

The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the ks\nla\lasalle\ extents 1.wpf4 I

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ATTACHMENT A j DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES l l

l completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Surveillance Requirements do j not have to be performed on' inoperable equipment." ;

Per specification 4.0.3, the surveillances exceeding the' Critical Date result in the 1 associated Limiting Conditions for Operation not being met, thus requiring unit j shutdown. j Bases for the Current Requirement The Bases for Surveillance Requirements is provided by the introduction to Technical Specification Bases for section 4.0:

"Snecifications 4.0.1 through 4.0.5 establish the general requirements applicable I to Surveillance Requirements. These requirements are based on the i Surveillance Requirement stated in the Code of Federal Regulations,10 CFR 50.36(c)(3):

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" Surveillance requirements are requirements relating to test, calibration, I or inspection to assure that the necessary quality of systems and l components is maintained, that facility operation will be within safety i limits, and that the Limiting Conditions of Operation will be met."

l The Bases for surveillance interval extensions is as follows: )

" Specification 4.0.2 establishes the conditions under which the specified time interval for Surveillance Requirements may be extended. The specification 4 permits an allowable extension of the normal surveillance interval; to facilitate !

surveillance scheduling, and consideration of plant operating CONDITIONS, that I may not be suitable for conducting the surveillance, e.g., transient conditions or )

other ongoing surveillance or maintenance activities. The limit given in l Specification 4.0.2 is based on engineeringjudgement and the recognition that !

the most probable result of any particular surveillance being performed is the ,

verification of conformance with the Surveillance Requirements. These l provisions are sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval. It is not intended that the allowable ;

tolerance be used as a convenience to repeatedly schedule the performance of surveillances at the allowable tolerance limit."

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES l l

The Bases for specification 4.0.3 reflects that periodic surveillance tests and calibrations are depended on to demonstrate the continued system / component operability as required by the Limiting Conditions for Operation:

" Specification 4.0.3 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of I

Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation. Under the l i provisions of this specification, systems and components are assumed to be OPERABLE when Surveillance Requirements have been satisfactorily performed

within the specified time interval."

l i The specific surveillance interval of"once per 18 months" is generally established for i i certain surveillances based on the current length of fuel cycles.

! Equipment / components that are subject to setpoint drift are generally set l conservatively to allow for normal instrument drift over a refuel interval. Other ;

surveillances have the 18 month frequency to coincide with planned unit shutdowns !

due to the complexity or safety significance of performing the surveillance with the i reactor at power. The frequency of the remaining 18 month interval surveillances are !

based on industry experience, and/or low failure potential.

! Description of the Need for Amending the Operating License / Technical j- Specification F

LaSalle System Engineering Nuclear Group reviewed the operating cycle and the fuel

consumption. They recognized that LaSalle Unit I would not have reached coast i down at the originally scheduled outage start date of September 30,- 1995. The

, System Engineering Nuclear Group made the recommendation to push the outage start date to a later time.

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Several factors were taken into consideration in coming up with a proposed January 27,1996 start date. These factors included:

Amount of fuel remaining.

Coast down duration / power level.

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Overhaul Committee requirements (looking at other station availabilities).

Replacement Power Costs.

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Starting an outage around holidays and associated personnel effects.

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In-processing of workers to support the outage.

The requested extension goes beyond the start of L1R07 due to the following considerations

Equipment / components required to be Operable during shutdown or refuel j conditions.

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Scheduling maintenance /surveillances on common or Unit 1 equipmeid required to be Operable per Unit 2 Technical Specifications.

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Scheduling of maintenance /surveillances on equipment throughout the planned outage.

Allowing an additional 15 days for unknown changes to outage duration.

Therefore, LaSalle Unit i requests an extension of the 18 month surveillance intervals to no later than April 5,1996.

The same allowance for surveillance interval extension is also requested for LaSalle Unit 2, based on Unit 1 or common systems required to be Operable per Unit 2 Technical Specifications.

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Description of the Amended Operating License /rechnical Specification Requirement LaSalle County Station proposes to modify the Unit 1 and Unit 2 Technical Specifications by adding License Condition 2.C.(35) to Facility Operating License NPF-11 as follows:

2.C.(35) Surveillance Interval Extension The performance interval for those surveillance requirements identified in the licensee's request for surveillance interval extension dated April 11,1995, shall be extended to April 5,1996, to coincide with the Unit 1 seventh refueling outage schedule. The extended interval shall not exceed a total of 25.1 months for 18 month surveillances.

LaSalle County Station proposes to modify the Unit 2 Technical Specifications by adding License Condition 2.C.(19) to Facility Operating License NPF-18 as follows:

2.C.(19) Surveillance Interval Extension The performance interval for those surveillance requirements identified in the licensee's request for surveillance interval extension dated April l 11,1995, shall be extended to April 5,1996, to coincide with the Unit 1 l seventh refueling outage schedule. The extended interval shall not l exceed a total of 25.1 months for 18 month surveillances.

l l Bases for the Amended. Operating License / Technical Specification Request l

The proposed change to the Unit 1 and Unit 2 Operating Licenses is temporary and allows a one-time extension of specific Unit 1 and Unit 218 month Technical

Specification Surveillance Requirements for Unit 1 cycle 7 to allow surveillance l testing to coincide with the Unit 1 seventh refueling outage, L1R07. All of the l Technical Specifications listed in Attachment E will either have their surveillance intervals expire prior to the Unit 1 shutdown for refuel or the Technical Specification requirements will be applicable during the refuel outage. Therefore, the surveillance interval extension is requested until the estimated end of the refuel outage, which is April 5,1995. The maximum surveillance interval increase during which the plant equipment is required to be Operable will be approximately 2.52 months. The interval increase will have a minimum effect or no effect on the reliability established by surveillance testing performed at normal intervals.

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Technical Specification'4.0.2 is an administrative control that ensures that surveillance tests are performed periodically and defines a reasonable extension period for such testing. The limit of 1.25 times the surveillance interval is based on the following from Technical Specification Bases for Specification 4.0.2: I "The limit given in Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements.

These provisions are sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval."

LaSalle County Station has concluded that the reliability defined by' the normal surveillance intervals (e.g., daily, monthly, quarterly) will not be significantly reduced by the proposed refuel interval extension. This conclusion is supported by the justifications for the extension ofindividual surveillance requirements in Attachment F.

Schedule Without approval of this amendment request, LaSalle Unit 1 would require a l surveillance outage of approximately 21 days to perform the surveillances for which this request for interval extension is being made. Planning for this surveillance l outage would require an extensive amount oflead time by Comed. Therefore, it is requested that this Unit 1 and Unit 2 License / Technical Specification amendment request be approved by July 15,1995, with an implementation time of 30 days.

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ML20082J926

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