ML20118A646
| ML20118A646 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/16/1992 |
| From: | Shields J COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20118A647 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 9209240289 | |
| Download: ML20118A646 (11) | |
Text
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/ - u)) Downers Grove, Illinois 60515 C0mm:nw;alth E-ilstn
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1400 Opus Place
'sNd September 16, 1992 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
LaSalle County Station Units 1 and 2 Response to Request for Additional Information on the Amendrrent Application under Generic Letter 87-09 NRC_DockeLROL_50-373 and 50-374
Reference:
See Attachment A
Dear Dr. Murley:
The NRC has been working in conjunction with 6.he Atomic Industrial Forum (AIF) on a program for technical specification improvements.
As part of this program the NRC has issued Generic Letter 87-09, Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements.
The generic letter addresses three specific problems that have been encountered with Sections 3.0 and 4.0 of the standard technical specifications (STS).
The recommendations contained in the Generic Letter for improvements to the technical specifications were incorporated into the reference (a) submittal.
In reference (b), the NRC requested the following:
affirmation that remedial measures prescribed by the technical specification action statements for which exceptions to Specification 3.0.4 will be granted tmder Generic Letter 87-09 provide a sufficient level of protection te permit operational mode changes and safe long term operation consistent with the UFSAR and its supporting safety analyses.
identification of and affirmation that procedures, management directives, onsite safety reviews, etc. have been established to limit the use of the Specification 3.0.4 exceptions.
affirmation that training necessary for ensuring that plant operators are made aware of, and are instructed to exercise, the controls promulgated in limiting the use of such exceptions have been developed.
91 A 1 rs a 92092402e9 920916 PDR ADOCK 05000373 p
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s Dr. Thomas E. Murley September 16, 1992 An evaluation was performed. of the-remedial measures pre' scribed by technical specification action statements for which the exception _will be grante1, to ensure that a sufficient level of. protection existed <to allow continuad operation and mode changes. -To aid in this review, all of the technical specification action statements wera-categorized and evaluated by group.
This evaluation determined that all=of_the action statements for which m
an exception to 3.0.4 will be granted provide a sufficient : level.of: protection-to permit operational mode changes'and safe _long term operation consistent--
with licensing basis described in the UFSAR..
As Generic Letter 87-09 states that it was not the intent of the NRC Staff to_ place additional restraints-on-unit operation as a result of the recommendations contained in the generic letter, for ali specification action statements for which "3.0.4 Not' Applicable" statements currently exist, 3.0.4 will remain Not Applicable-whether or not the specific statement is removed by this amendment. LThe results of this evaluation will be retained'at LaSalle County Station.
Station. administrative procedures will be revised to provide guidance for; the application of Technical Specification-3.0.4 Exemptions.
This guidance ~
will stress the importance_of maintaining equipment operability, the importance of focusing attention on.overal_1 plant s'.fety and potential-system interactions, and that in cases where-a technical = specification does not-prohibit a change in operational conditions,'It will be-the' exception'when a startup proceeds with important safety features inoperable.
Administrative controls will be established for Technical Specification 3.0.4 Exemptions, including the level of authority required.to approve such i
exemptions.
In addition',_the licensed operator training program will~: include j.-
training on the above procedure revisions-and_ administrative controls.
The original No Significant Hazards Consideration Determination'was reviewed with respect to this letter, and found.to acceptably-address-the-additional administrative changes.
Also included with this letter are the following:
Attachment A, which lists references contained in this-letter.
Attachment B, which contains correction's' to the origi_nal submittal.
-Attachment C,-which requests additional editorial and: typographical changes.
Attachment D, which provides.a reference--to other technical-_. specification amendments whose pages may be-affected by this. amendment.
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Mr. Thomas E. Murley September 16, 1992 Attachment E, which contains the marked-up technical specification pages.
Please note that several Technical Specification changes have been approved, and others requested, since the original 3.0/4.0 amendment request was submitted.
This letter references the Technical Specification sections and pages as if they had remained unchanged.
Hhere necessary for clarity, information regarding these changes has been discussed in the appropriate attachment.
It is requested that the most current revision of each page be used in creating the updated version of the page as a result of this amendment request.
If there are any questions, please direct them to this office.
Respectfully, bh t
JoAnn Shields Nuclear Licensing Administrator 4
1 At.tachments cc: A.B. Davis, Regional Director - RIII B.L. Siegel Project Manager - NRR D.L. Hills, Senior Resident Inspector - LSCS Office of Nuclear Safety - IDNS i
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ATTACHMENT A References d
(a)- H.E. Morgan (Ceco) letter to Dr. T.E. Murley (USNRC), dated December 15, 1989; Application for Amendment to facility 0perating License NPF-ll and NPF-18:
Clarification of General Requirements for Application to Technical Specification LCOs and Surveillance Requirements I
(b)
R.M. Pulsifer (USNRC) letter to T.J. Kovach (CECO), dated February'27, 1990; Request for Additional Information on the.
i Licensee Amendment Application under Generic Letter 87-09 for LaSalle County Station Units 1 and 2 (c)
B.L. Siegel letter to T.J. Kovach, dated November 27, 1991; 4
Approving Amendments 81 (Unit 1) and 65 (Unit 2); HPCS/RCIC.
(d)
P.C. Shemanski letter to T.J. Kovach, dated July 19, 1989; Approving Amendments 68 (Unit 1) and 50 (Unit 2); Revision to 4.0.2 (e)
H.R. Butler letter to D.L. Farrar, dated May 22, 1985; Approving Amendments 23 (Unit 1) and 11 (Unit 2); Administrative Changes.
(f)
B.L. Siegel letter to T.J. Kovach, cated September 1, 1992; 3
Approving Amendments 85 (Unit _1) and 69 (Unit 2); Radiological Environmental Technical Specifications.
I (g) P L. Piet-letter to USNRC, dated April. 2,1991; Application for Amendment to Delete Rod Sequence Control Sy' tem and Lower Rod North Minimizer Setpoint, (h) _J.M. Shields letterfto Dr. T.E. Murley, dated June 17, 1992; Application for Amendment to Remove Table.3.8.3.2-1.
(1)
H.D. Shafer (NRC)-letter to C. Reed, dated February 6, 1990; transmitting Inspection Report 50-373/89026 and 50-374/89025.
(j)
H.E. Morgan (CECO) letter to Dr. T.E. Murley, dated January 8, 1990; Correction to Amendment 26 to Facility. Operating License.NPF-11.
(k)
P.C. Shemanski (USNRC) letter to T.J. Kovach,. dated Janaury 12, 1990; Correction to Amendment 26 to Facility Operating License NPF-il, 4
s t
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e Attachment B Corrections to the Original Submittal Diarked-up versions of these pages may be found in Attachment E.)
The original submittal contained Technical Specification 3.3.7.11, page 3/4 3-86, for both Unit I and Unit 2, and *equested deletion of exemption from both 3.0.3 and 3.0.4.
This Limiting Condition for Operation will present a startup following a unit outage if certain of the required instrumentation is inoperable, even though the action statement provides for continued operation if alternative monitoring capability, such as periodic grab samples, etc. is satisfied.
Therefore, as allowed by Generic Letter 87-09, CECO requests to retain the exemption from Specifications 3.0.3 and 3.0.4.
Corrected versions of these pages arc lacluded in Attachment E, and replace the pages in the original submittal.
The original submittal contained Technical Specification 3.6.1.3, rage 3/4 6-5, for both Unit 1 and Unit 2, and requested deletion of exemption from 3.0.4.
This timiting Condition for Operation will prevent a startup following a unit outage if one primary containment air lock door is inoperable, even though the action statement provides for continued operation if the surveillaiice requirements are vt.
Therefore, as allowed by Generic Letter 87-09. CECO requests to retah ine exemption from Specification 3.0.4.
Corrected versions of h m p ;es are included in Attachment E, and replace the pages in the original submittal.
The Generic Letter 89-09 wording to replace the existing Technical Specification 3.0.4, for both Unit 1 and Unit 2, was included in the original submittal as Insert A.
In the second sentence of Insert A, a clause was erroneously omitted.
The sentence should state " Entry into an OPERATIONAL CONDITION OLSDEC.intiWndit10D may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time." Also, in the third sentence the word "through" is misspelled. Please make these corrections in the final version of the appropriate pages for both Units 1 and 2.
e.
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4 b
ATTACHMENT C Additional Editorial and Typographical Changes (Marked-up verstens of these pages may be found in Attachment E.)
i Unit 1 2
P3ge Reit ti pilon_of_f bang e._Re q u eit ad 4
3/4 3-1 LCO 3.3.1 action b:
delete the extra "the" from the beginning of this sentence.
SR 4.3...!:
Add a hyphen to the Table number, so that it states i
Table 4.3.1.1-1.
j j
SR 4.3.1.2:
Delete the triple asterisks here, and at the bottom i
of the page.
This footnote waived certain surveillance requirements during Unit 1 Cycle 1, and as such, no longer d
applies.
3/4 3-9 LCO 3.3.2 action b:
The original submittal stated ... place the i
openble channel (s) and/or trip sys w in the tripped condition
- within one hour." and has been corrn ;ed to state "... place the d
biogenble channel (s) and/or trip system in the tripped i
r:ndition+ within one hour." Reference (1) describes the i
a tuation under which the typographical error was discovered.
l Reference (j) documcnts a-telephone. conversation concerning the error, and Reference (k) provided the corrected page.
3/4 3-27 ACTIO6 30 a:
delete the asterisk, as the footnote to which it refers is being deleted i
ACTION 36:
This action was deleted in Amer.'..ent 81.
See reference-(c).
3/4 3-86 This correction was discussed in Nttachment B.
4 3/4 3-91 LCO 3.3.7.17 action b:
The original submittal erroneously delettd exemption from Specification 3.0.3.
Only exemption from Specification 3.0.4 is being deleted.
3/4 4-lb
~ Delete this whole page.
3/4 4-10 LCO 3.4.4 action'c.2:
The word-" exceeded" in the second line is redundant, and may be eliminated without changing the meaning of the required aciton.
3/4 6 This correction was discussed in Attachment B.
i 3/4 6-22 LCO 3.6.3 action b.1:
Delete'the final "s" in the word
" Specifications".
Footnote:
Correct the spelling of the word " satisfy".
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i ATTACHMENT C (Continued)
Additional Editorial and Typographical Changes (Marked-up versions of these pages may be found in Attachment E.)
3/4 7-17 LCO 3.7.5.3:
Realign the last half of the sentence.
APPLICABILITY:
The numtu "0" in the chemical formula for carbon dioxide should be a subsciipt, and there should be a space between the number "2" and the following word.
3 LCC 3.7.5.3 action b:
The word "and" should be deleted.
3/4 8-26 LCO 3.8.3.3:
Table 3.8.4.2-1 does not exist in the LaSalle Specification.
The correct table reference is Table 3.8.3.3-1.
3/4 8-27 Table
Title:
Insert a hyphen in the taFi' number so that it states Table 3.8.3.3-1.
3/4 8-28 Table
Title:
Insert a hyphen in the table number so that it states Table 3.8.3.3 1 Item j: delete all the asterisks from this column and deiete the footnote.
This footnote waived certain surveillance requirements during Unit 1 Cycle 1, and as such, no longer applies.
3/4 B-29 Table
Title:
Insert a hyphen in the table number so that it states Table 3.8.3.3-1.
Item j: Delete all the asterisks from this column and delete-the footnote.
This footnote waived certain surveillance requirements during Un11 Cycle 1, and as such, no longer applies.
2 Unit 2 hat DmrintioILoLChange.leauelted 3/4 0-2 Footnote:
This footnote should have been deleted in Amendment 50.
It waived certain surveillance requirement during Unit 2 Cycle 2, and as such, no longer _ applies.
See reference (d).
3/4 3-1 LCO 3.3.1 action b:
delete the extra "the" from the beginning of this sentence.
3/4 3-27 ACTION 36:
This action was deleted in Amendment 65.
See reference (c).
3/4 3-81 LC0 3.3.7.10 action c:
Reference to 6.6.B.2.b should have been deleted in Amendment 11.
See Refernce (e).
.)
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ATTACHMENT C (Continued)
Additional Editorial and Typographical Changes (Marked-up versions of these pages may be found in Attachment E.)
3/4 3-86 1his correction was discussed in Attachment B.
3/4 3 41 LC6 S.3.7.12 action b:
The original submittal erroneously dele'ed exemption from Specification 3.0.3.
Only exemption from t
Specification 3.0.4 is being deleted.
3/4 4-2a Delete this whole page.
3/4 4-11 LCO 3.4.4 action c.2:
The word " exceeded" in the second line is redundant, and may be eliminated without changing the meaning of the required action.
3/4 6-5 This correction was discussed in Attachment B.
3/4 6-25 LCO 3.6.3 action b.1: Delete the final "s" in the word
" Specifications".
Footnote: Correct the spelling of the word " satisfy".
3/4 8-26 LCO 3.8.3.3: Table 3.8.4.2-1 does not entst in the LaSalle Specification.
The correct table referen:e is Table 3.8.3.3-1.
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J ATTACHMENT D l
Reference to other Amendments i
The marked-up pages supporting this amendment have been, or will be affected by other Technical Specification amendments.
These interactions are 1
l discussed below.
Unit 1 Amendment 85 and Unit 2 Amendment 69 Generic Letter 89-01 Radiological Effluent Technical Specifications (RETS)
See Reference (f) i l
i LC0 3.3.7.10 is referred to be on page 3/4 3-81 in this submittal.
Due to l
RETS, this page has been deleted.
J l
LCO 3.3.7.11, on page 3/4 3-86 in the original submittal, has changed title, and has had this title change carried throughout the specification.
This LCO is now located on page 3/4 3-82.
i LCO 3.3.7.12 is referred to be on page 3/4 3-91 in this submittal, Due to RETS, this page is now 3/4 3-85.
a LCO 3.11.1.2 is referred to be on page 3/4 11-6 in this submittal.
Due to RET", this page has been deleted.
I LCO 3.11.1.3 is referred to be on page 3/411-7 in this submittal.
Due to RETS, this page has been deleted, a
i i
LCO 3.11.1.4 is 'eferred to be on page 3/4 11-8 in this submittal.
Due to RETS, this page is now 3/4 11-1.
LCO 3.11.2.2 is teferred to be on page 3/4 11-13 in this submittal.
Due to RETS, this page has been deleted.
LCO 3.11.2.3 is referred to be on pa,e 3/4-11-14 in this submittal.
Due to j.
RETS, this page has been deleted.
LCO 3.11.2.4 is referred to be on page 3/4 11-15_in this submittal.
DUP to RETS, this page has been daleted.
LCO 3.11.2.5 is referred to be on page 3/4 11-16_'in this submittal.
Due to RETS, this page has been deleted.
)
LCO 3.11.2.6 is referred to be on page 3/4 11-16 in this submittal.- Due to RETS, this page has been renumbered, and is now page 3/4 11-2.
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ATTACHMENT D (Continued)
Reference to other Amendments LC0 3.11.2.8 is referred to be on page 3/4 11-19 in this submittal.
Due to RETS, this page has been deleted.
LCO 3.11.3 is referred to be on page 3/4 11-20 in this submittal. Due to RETS, this page has been deleted.
LCO 3.11.4 is referred to be on page 3/4 11-22 in this submittal.
Due to' RETS, this page has been deleted.
LCO 3.12.1 is referred to be on page 3/4 12-1 in this submittal.
Due to RETS, this page has been deleted.
LCO 3.12.2 is referred to be on page 3/412-9 in this submittal.
Due to RETS, this page has been deleted.
LC0 3.12.3 is referred ta be on page 3/4 12-10 in this submittal.
Due to RETS, this page has been deleted.
Application for tmendment Deletion of Rod Sequence Control System and Lowering of Rod Worth Minim 12er Septpoint Submitted April 2, 1991 See Reference (g)
LCO 3.1.3.1 is referred to be on page 3/4 1-4 in this submittal. Due to RSCS, this page is being deleted.
LCO 3.1.3.6 is referred to be on page 3/4 1-11 in this submittal.
Due to RSCS, this page is being deleted.
LC0 3.1.4.1 is referred to be on page 3/4 1-16 in this submittal.
Due to RSCS, this page is being deleted.
Application for Amendment Removal of Table.1.8.3.2-1 Submitted June F/, 1992 See Reference (h)
LCO 3.8.3.2, on page 3/4 8-22, deletes reference to the Table number.
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Attachment E i
Marked-up Pages i
NPF-11 HPL_13 1
l 3/4 0-2 l
3/4 3-1 3/4 3-1 l
3/4 3-9
~
3/4 3-27 3/4 3-27
.i 3/4 3-81 3/4 3-86 3/4 3-86 1
3/4 3-91 3/4 3-91 l
3/4 4-lb 3/4 4-2a l
3/4 4-10 3/4 4-11 i
i 3/4 6-5 3/4 6-5 I
4 3/4 6-22 3/4 6-25 i
3/4 7-17 3/4 8-26 3/4 8-26 3/4 8-27 i
3/4 8-28 3/4 8-29 i
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1 i
1 i
4 i
I I
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e i
l' ZNLC2iiW18 l
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