ML20132E287

Application for Amends to Licenses NPF-11 & NPF-18,changing Tech Specs to Defer One 18-month Interval Surveillance Requirement for Each Unit to Allow Unit 1 to Continue Operation Past 850927

ML20132E287
Person / Time
Site:	LaSalle
Issue date:	09/23/1985
From:	Massin H COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20132E291	List: ML20132E287 ML20132E302
References
0672K, 672K, NUDOCS 8510010052
Download: ML20132E287 (3)

Text

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[N Commonwealth Edison

/ One First National Plaza. Chicago. tranois

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C Address Reply to: Post Office Box 767 Chicago Illinois 60690 September 23, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

LaSalle County Station Units 1 and 2 Proposed Emergency Technical Specification Amendment for Facility Operating Licenses FFF-11 and tPF-18 Waiver of 18-Month Surveillance Interval NRC Docket Nos. 50-373 and 50-374 References (a): July 15, 1985 letter from H. L. Massin to H. R. Denton.

(b): August 9, 1985 letter from H. L. Massin to H. R. Denton.

(c): September 20, 1985 letter from W. R. Butler to D. L. Farrar transmitting tPF-11, Amendment 24.

Dear Mr. Denton:

Pursuant to 10 CFR 50.90, Commonwealth Edison Conpany (CECO) proposes an emergency an er.dment to Appendix A, Technical Specifications, for Operating Licenses NPF-11 and NPF-:.8. The proposed changes provide deferral of one 18-month interval surveillance requirement for each unit to allow LSCS Unit 1 to ccrtinue operation past Septenber 27th.

Reference (a) submitted a request for approval of a one-time-only waiver of a limited number of 18-month interval surveillance requirements for LaSalle County Unit 1 first cycle. Reference (b) modified the initial submittal to delete items completed during an unplanned outage. While preparing for the upcoming outage, it was determined that while all the surveillances which needed to be deferred were included in the submittals referenced, two of the corresponding Technical Specification references were inadvertantly omitted. This was discovered on September 18, 1985, and was discussed with your staff on Septenber 20, 1985 after it was confirmed no other similar omissions had been made.

On September 20, 1985 it was judged that these two additions to our request did not qualify as "aoministratve" changes to your evaluation of Reference (b) due to Federal Register notification requirements. Accordingly, they were not included with the amendment issued on September 20, 1985 (Reference ' (c)) . -

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H. R. Denton Septenter 23, 1985 l

l The emergency situation arises because the previous submittals did

not include two Technical Specification references. Without the proposed

amendments the following will occur

, (a): LaSalle County Unit 1 cannot continue operation past September 27,  ;

1985 due to surveillance requirement 4.5.1.c for the Low Pressure Coolant Injection (LPCI) Systems A, 8, and C.

1 (b): LaSalle County Unit I will be forced to shutdown on no later than ,

September 27, 1985 to perform surveillance requirement 4.8.1.1.2.d [

for the Unit 1 Division 2 (lA) diesel generator to allow this diesel generator to remain operable for Unit 2 and thus allow

] continued operation of Unit 2.

Specification 4.5.1.c was not included with Reference (b). The 18 month surveillance for Technical Specification 4.3.3.2 was included in Reference (b) and waived by reference (c). The surveillance requirement of 1 Technical Specification 4.3.3.2 is redundant and functionally equivalent to

Technial Specification 4.5.1.c for the LPCI system. The logic system functional test for the Low Pressure Coolant Injection System is performed by t surveillance procedure LES-RH-01 which satisfies both Specifications 4.3.3.2 j and 4.5.1.c. No change to the significance or impact on plant safety will i occur because no change to references (a) and (b) has occurred except to i

include the adoitional Tech Spec reference.

Attachment A of Reference (a), Item 4.a for Division II "A" diesel i generator affects the Unit 2 Technical Specifications in that the 1A diesel is required to be operable for Unit 2 operation. The surveillance of specification 4.8.1.1.2.d address the ability of the diesel generator system  !

to supply sufficient emergency power to the unit to which it is assigned.  :

l' The requirements were deferred for Unit 1 (Reference (c)). The power require-ments for which the 1A ciesel is necessary to support Unit 2 operation are

-much less than those required for Unit 1. The 1A diesel's only power requirements for Unit 2 are the standby gas treatment system subsystem A, Unit 1 drywell and suppression chaaber hydrogen reconbiner system, and the control room and auxiliary electric equipment room emergency filtration system 1

train A. Therefore since the diesel generator will be operable for Unit 1 4

operation during the extension period granted by reference (c), it should be j considered operable for Unit 2 operation during the same period since the

. Unit 2 surveillance requirements are identical to those of Unit 1. Since the same diesel generator is affected, no additional impact will occur. The Unit 2 Specification 4.8.1.1.2.d was inadvertantly omitted from the original submittal.

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i . CECO believes that the amendment involves no significant increase in i the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. Given our belief that the j amendment involves no significant hazards consideration and has no environ-mental impact, we believe that the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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l H. R. Denton September 23, 1985 l

The proposed amendment can be found in Attachment 1 and has been both Onsite and Offsite reviewed. We have reviewed this amendment request and find j that no significant hazards consioeration exists. Our review is documented in

! Attachment 2. Commonwealth Edison has notified the State of Illinois of our request for this amendment and our appraisal on the question of no significant hazaros by telephone call and transmittal of a copy of this letter and its attachments to the designated State Official.

This approval is requireo by Septenber 25, 1985. LaSalle Unit I will begin an unscheduled shutdown on September 26, 1985 in order to perform the required surveillances before they become due on September 27, 1985. The outage time would be a minimum of 3 days. An unscheduled outage is not in the interests of safe operation nor is it consistent with our request for an extension of certain 18-month survcillances to allow time for planning and to more fully utilize the Unit 1 core.

This request could not have been reasonably foreseen because all the surveillance procedures were addressed in prior submittals. The computer tracking program controls surveillances by due dates of the procedures used to satisfy the Tech Spec requirements. More than one Tech Spec is conplied with by some procedures. There was no prior need to sort all the procedures by Tecn Spec. This emergency request does not defer additional requirements, it sirrply includes two additional Technical Specification references that were inadvertantly omitted from the previous submittals.

In accordance with 10 CFR 170, a fee remittance in the amount of

! $150.00 is enclosed. Please direct any questions you may have concerning this matter to this office.

Three signed original and thirty-seven (37) copics of this transmit-tal and its attachments are provided for your use.

Very truly yours, H. L. Massin Nuclear Licensing Administrator i im Attachments (1): Technical Specification Changes to tPF-ll and fPF-18 (2): Evaluation of Significant Hazards Consideration ec: Region III Inspector - LLCS A. Bournia - NRR M. C. Parker - State of IL l l

SUBSCR EfD AND SWORt to befor me thi- d l day of M M ffra. , 1985 ep \

"L Y/11An

' Notary P~u olid

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