ML20116B379

Provides Rev to Relief Request CR-11,per Request by Ltr Dtd 941014.All Ref to IWF-5200 Re Relief Request CR-11, Withdrawn

ML20116B379
Person / Time
Site:	LaSalle
Issue date:	07/22/1996
From:	Querio R COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9607300001
Download: ML20116B379 (3)

Text

_

C.ommonw calsh Illison rennpany I

laSalle Generating Station 2G11 North 21st Roatl Marseilles, 11.61341-9757 Tel sis 3s74761 July 22,1996 United Statec Nuclear Regulatory Commission Attention: Document Control Desk j

Washington, D.C. 20555

Subject:

LaSalle County Nuclear Power Station Units 1 and 2 Revision of Relief Request CR-11 NRC Docket Nos. 50-373 and 50-374

Reference:

1.

G. Benes letter to USNRC dated October 14,1994, Comed Second 10 Year ISI Program Review Reference 1 provided LaSalle Station's ISI program for the second ten year interval. The purpose of this letter is to provide a revision to relief request CR-11 which was requested in i

the Reference 1 document.

During the Staff's review of Relief Request CR-11, a question was raised as to the applicability of ASME Article IWF-5200 to LaSalle's in-service inspection plan for the second ten year interval for snubbers.

This letter withdraws all reference to IWF-5200 on relief request CR-11.

If there are any questions or comments conceming this letter, please refer them to me at l

(815) 357-6761, extension 3600.

l Respectfully, i

hv-R. E. Querio l

Site Vice President l

LaSalle County Station f

l Enclosure cc:

H. J. Miller, NRC Region 111 Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Mar,ager - NRR - Lssalle F. Niziotek, Office of Nuclear Facility Safety - IDNS 1

DCD - Licensing (Hardcopy:

Electronic:

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9607300001 960722 DR ADOCK 05000373

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I RELIEF REQUEST CR-11 l

(Page 1 of 2)

COMPONENT IDENTIFICATION Code Class:

1,2,3

Reference:

IWF-5200(a)

IWF-5300(a)

Examination Category:

Not Applicable item Numbers:

Not Applicable

==

Description:==

ISI Snubbers Induded in the Technical Specification Snubber Visual and Functional Examination Program.

CODE REQUIREMENTS Preservice examination per IWF-5200(a) and inservice examination per IWF-5300(a) in accordance with the first addenda to ASME/ ANSI OM-1987 Edition, Part 4,

- published in 1988 (OMa-1988, Part 4, per 10CFR50.55a, paragraph (b)(2)(viii),

published August 8,1992).

i BASIS FOR RELIEF 1

The current LaSalle Technical Specifications (TS) indude comprehensive program for i

(

visual exainination and functional testing of all safety related hydraulic and mechanical snubbers. The safety related snubber population encompasses all Code Class 1,2, and 3 snubbers.

~

Of the approximate total of 240 safety related snubbers per unit, approximately 215 are Code Class. The overlap of the visual examination and functional test programs per ASME Section XI and Technical Specifications for Code Class snubbers presents an unnecessary redundancy without a compensating increase in the level of quality and. safety.

4 The TS snubber visual examination program requires a sample size of 100% of all safety related snubbers and incorporates the attemate snubber visual examination delineated in US NRC Generic Letter (GL) 90-09. As determined by the NRC Staff, the attemate schedule of GL 90 09 maintains the same confidence level of quality and safety as the previous TS schedule, which was very similar in content to that of OMa-1988, Part 4.

[

The GL 90-09 altomate schedule is based on the number of unacceptable snubbers found during the previous examination in proportion to the sizes of the various snubber populations or categories. The altamative examination interval is based on a i

fuel cycle of up to 24 months and may be as long as two fuel cycles, depending on the number of unacceptable snubbers found during the previous visual examination.

!b 8-26 l

i 1

LAAMLE MRaffY 04Nl1.5AR STAf4BI Nt

.sease,nsimE.fs scemiesua RELIEF REQUEST CR-11 (Page 2 of 2) i The TS anubber functional test program contain the sampling plans described in OMa-1988, Part 4. In the event of a snubber fails to meet the functional test acceptance criteria, the TS required additional testing samples and required corrective schons are equal to or more conservative than those specified in OMa-1988, Part 4.

Based on the reason that the TS snubbe' visual examination and functional test r

programs maintain the same or better levels of quality and safety as that of OMa-1988, Part 4, LaSalle Station requests that the TS visual examination and functional test programs for snubbers be used in lieu of the OMa-1988, Part 4 visual examination and functional test prcgrams required by ASME Section XI, Subartides IWA-5200(a) and IWA-5300(a).

i I

PROPOSED ALTERNATE PROVISIONS I

LaSalle Station will perform visual examinations and functional tests of Code Class snubbers in accordance with the snubber examination and test programs contained in the latest approved revision the Technical Specifications in lieu of the OMa-1988, Part 4 visual examination and functional test programs required by Subartides IWF-5200(a) and IWF-5300(a).

Visual examiners, who are qualified to the app!icable rules of ASME Section XI Artide lWA-2000, will perform the examinations Code Class snubbers. Visual examination and functional test results of Code Class snubbers will be recorded and reported in accordance with the applicable rules of ASME Section XI Artide IWA-6000.

i APPLICABLE TIME PERIOD Relief is requested for the second ten-year interval of the Inservice inspection Program for LaSalle Units 1 and 2.

8-27

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