ML20091R801
| ML20091R801 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/03/1992 |
| From: | Piet P COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9202060066 | |
| Download: ML20091R801 (3) | |
Text
,
,??
f OV Ccmmtnwealth Edis:n -
A[O
[
O ) 1400 Opus Pi ce,
- J t
4, 4,,
Downi,rs Grove, Illinois 60515-January 3,1992 Dr. Thomas E. Murley Office of Nuclear Reactor Regulation
. U.S. Nuclear Regulatory Commission Washirigton, D.C. 20555 Attn: Document Control Desk
Subject:
LaSalle County Station Units 1 and 2 in-Service Testing (IST) 3 and SR:3Z4Prcgram Relief Request RV-NRC Docket Nos_. 50-37
Reference:
- (a); W.E. Morgan letter to T.E. Murley,.
' dated October 2,1989; transmitting Revision 2 to the LaSal'e County Station Unib 1 and 2 IST Program.
Dear Dr. Murlay:
LReference (a) submitted Revision 2 ef Commonwealth Edison's (CECO) sunty Station in-Servica Testing Program. The attachment to this letter LaSa t
- revis % % 'let Aequest RV-19 to include relief from the requirements of ASME Code Section..., Section IWV-3427(b). Such relief has been granted by the Commission in Generic 1.etter 89-04 (Attachment 1, Position 10). Liecause LaSaile's position represer.s a deviation from the Code requirements, it is being documented in the IS T program by transmittal of this letter.'
As stated in Attachment 1, Position 10 of Generic Letter 89-04,"lWV-3427(b) specifies additional requirements on increased test frequencies for valve sizes of six inches and larger and repairs or replacement over the requirements of IWV-3427(a);
Based on input from many uti_lities and staff review of testing data at some plants,- the
- usefulness of IWV-3427(b) does not justify the burden of complying with this requirement." As documented in the attached relief req.mst, LaSalle's revision to Relief Request RV-19 conf.orms to the guidance provided in G%r!c Letter 89-04.
Please direct any questions you rnay have regarding inis matter tc this office.
~
Sincerely.
?
~
Peter L. Piet Nuclear Licensing Administrator Attachment cc; /A. Bert Davis - Regional Administrator, Rlli
~_,.
' Senior Resident lospector.- LaSalle f
Office ofbel-' Project Manager, La a e 0 k(
B. L; Sie S ll uclear Facility Safety - IDNS q
Jn2otB88aan!)k P.
4 1
/
. J
- LASALLE COUNTY STATION Page i of 2
. UNIT #1 and 2 VALVE RELIEF REQUEST /
COLD SHUTDOWN JUSTIFIC ATION: RV-19 APPROV AUREFERENCE DOCUMENT (s):
SER dated 8/16/88 Position 10 of Generic Letter 89-04 AFFECTED COMPONENT (s):
_C.QMP_ONEtiT_EPJi_
_ CLASS /CAIEGQBL IUNCILON_
Ali Category A primary Variouc Containment isolation Valve containment istf ation (CIV) valves /
Pressure boundary Various Pressure boundary isolation function valves (PlV) isolation valves BASIS FOR RELIEF: Primary containment Category A isolation valves will be seat leak tested in accordance with the requirements of Technical Speelfication 3/4.6.1.2 and Appendix J to 10 CFR 50.
W *alcal Spacification 3/4.6.1.2 surveillance testing for measuring valve seat leakage is consistent with the i.
l requirements of Appendix J to 10 CFR 50 with the exception of the exemption granted by the NRC for the main steam isolation l
l valves. Operating expenence with the MSIV's has indicated that degradation has occasionally occurred in the leak tightness l
of the valves; therefore the special requirement for testing the i
MSIV's was added.
Corrective action subsection IWV-3427(b) specifies additional l
requirements on increased test frequencies for valves of sizes 6 o
inches or greater and repairs or replacements over the requirements of IWV-3427(a). Generic Letter 89-04 (Attachment 1, Position 10) riates "The usefulness of IWV-3427(b) does not justify the burden of complying with this requirement." This relief from IWV-3427(b) of the ASME code granted through Generic Letter 89 04 only applies to Containment isolation valves under containment leak rate testing.
l l
The ECCS and RCIC systems will be pressurized with water to a minimum pressure of 43.6 psig (1.10 times peak drywell accident pressure) with the system totally bolated from the primary containment (refer to note 8).
All pressure boundary isolation valves; their classification and leak-rate testing has been previously addressed in the NRC SER for LaSalle Units 1 and 2 (refer to note 5).
j
!sct:1165:30
I d
. LASALLE COUNTY STATION Page 2 of 2 UNIT #1 and 2 VALVE RELIEF REQUEST /'
COLD SHUTDOWN JUSTlFICATION: RV 19 (continued)
ALTERNATIVE TEST:
Perform seat leakage testing in accordance with the requirements of Appendix J to 10 CFR 50, or as amended by Technical Specifications. The seat leakage results of the primary containment isolation valvM will be analyzed in accordance with Appendix J to 10 CFR 50, Technical Specification 3.6.1.2, and ASME Section XI paragraph IWV-3426. Corrective action will be taken in accordance with paragraph IWV-3427(a) and the Technical Specifications. The leakage rates for the primary containment will be limited to the follov.,1g (as taken from T.S.
3.6.1.2):
a.
An overall integrated leakage rate of less than or equal to La,0.635 porcent by we!ght of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at Pe,39.6 psig.
b.
A combined leakage rate of less than or oc ual to 0.60 La for all penetrations and all valves lirted in Tab e 3.6.3-1, except for main steam isolation valves and valves which are hydrostatically leak tested per Table 3.6.31, subject to Type c3 and C tests wh?n pressurized to Pa,39.6 psig.
c.
Less than or equal to 100 scf per hour for all four main steam lincs through the isolation valves when tested at 25.0 psig.
o.
A combined leakage rate of less then or equal to 1 gpm times the t al number of ECCS and RCiC containment isolation s ses in hydrostatically ter ted lines which penetrate los primary containmant, when tested at 1.10 Pa, 43.6 psig.
All pressure boundary isolation valves, as specified in iechn: cal Specification Table 3.4.3.2-1, will be individually leakage rate tested in accordance with Technical Specification 4.4.3.2.2.
- i
/ sci:1165:31
.