ML20082Q738
| ML20082Q738 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/07/1983 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 7759N, NUDOCS 8312120321 | |
| Download: ML20082Q738 (4) | |
Text
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Commonwe:lth Edison One First National PITra. Chicigo. Illinois Address Reply to Post Office Box 767 Chicago. Illinois 60690 December 7, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Unit 2 Request for Exemption from 10 CFR 50.44 NRC Docket No. 50-374 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 82-33, 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.
(e):
LaSalle County Station Technical Specification l
3.10.5, Special Test Exception Oxygen Concentration.
(f):
C. W. Schroeder letter to A. Schwencer dated December 7, 1982, " Request for Exemption from 10 CFR 50.44".
(g):
D. G. Eisenhut letter to L. O. DelGeorge dated December 20, 1982, " Amendment No.
12 to Facility Operating License No.
NPF-ll LaSalle County Station, Unit 1".
t l
(h):
C. W. Schroeder letter to A. Schwencer l
dated March 18, 1983, "LaSalle County Station Unit 2, Potential License Conditions".
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H. R. Denton-December 7, 1983 (1):
B. Rybak letter to H. R. Denton dated November 21, 1983, "LaSalle County Station Unit 1, Request for Emergency Change to NPF-ll, Appendix A, Technical Specifloations Regarding Reactor Feedwater Inboard Check Valves Type C Test.
Dear Mr. Denton:
The NRC has issued References (a) and (b) which indicate incon-
'sistencies between the Standard Technical Specifications and 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.
Reference (c) states, in part, that " Effective May 4, 1982 or 6 months after initial criticality, whichever is later, an inerted atmosphere shall be provided for each colling light-water nuclear power reactor with a Mark I or Mark II type containment...".
atmosphere oxygen co(ncentration shall be less than 4% volume during the Reference d) requires that drywell and suppression chamber-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 i
been completed or the reactor has operated for 120 Effective Full Power Days.
Reference (f) requested an exemption from the requirements to 10 I
CFR 50.44 to allow LaSalle County Station Unit 1 to operate within the provisions of its Technical Specifications (Reference (d) and (e)).
Reference (g) granted the regested exemption in Amendment No. 12 to NPF-ll.
During the Technical Specification review process for LaSalle Unit 2, a request was made by the LaSalle County Station to have a similar Qxemption granted by means of a footnote in the Technical Specification (Reference (e)).
This request was not granted and therefore the incon-sistency addressed in reference (f) remained in place for LaSalle Unit 2.
In-March, 1983 an official exemption was requested in reference (h) for Unit 2.
l
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-H.- R. Denton 3-December 7, 1983 On December 5, 1983, C. W. Schroeder was notified that the requested 10 CFR 50.44 exemption for Unit 2 would require additional Unit 2 specific justification.
The purpose of th!s letter is to specifically request an exemption from the requirements of 10 CFR 50.44 to allow LaSalle County Station Unit 2 to operate within the provisions of its Techical Specifications-(References (d) and (e).
The requirements of Reference (c) were predicated on the basis that the initial startup test program for new boiling water reactors is 9xpected-to be completed'within approximately six months following initial criticality.
In the case of LaSalle County Station Unit 2, there are several reasons for the extension of the initial startup test program beyond six months.
These include:
1.
The Unit 1 Startup Test Program projected duration was optimistically estimated to be 180 days from fuel load to completion of the warranty run.
This estimation was made without considering the impact of the following:
a.
A license conditioned to 5 percent power.
b.
License conditions requiring additional commitments to be completed prior to exceeding 5 percent power.
2.
The estimation of approximately 180 days is very dependent on initial balance-of-plant performance under power operation.
LaSalle Unit 1 experienced some extended outages due to equipment performance problems.
Although these problems were reviewed for applicability to Unit 2, it is hard to predict the total performance of all equipment or i
the preoperational test and System Demonstration alone.
3.
LaSalle has committed to install certain plant modifications (as license conditions) prior to completion of the Startup Test program.
These modifications will require the plant to be shut down.
1-4.
The long-term corrective action for the resolution of the inboard feedwater check valves (see reference (1)) has not been positively identified.
Therefore, an interim testing program may require additional unit shutdowns.
This request is submitted for the purpose of conforming the LaSalle Unit 2 Technical Specifications to 10 CFR 50.44 by means of an approved exemption in the Facility Operating License.
i
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H. R. Denton December 7, 1983 It should be noted that the current wording of reference (e) addresses any potential 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.
To the best of my knowledge and belief the statements contained herein are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If there are any further questions regarding this matter,'please contact this office.
Very truly yours,
/2-/7/s3 C. W. Schroeder Nuclear Licensing Administrator 1m cc:
NRC Resident Inspector - LSCS i
7759N
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