ML20134C174
| ML20134C174 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/29/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20134C169 | List: |
| References | |
| NUDOCS 9701310276 | |
| Download: ML20134C174 (4) | |
Text
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.117 TO FACILITY OPERATING LICENSE NO. NPF-ll AND AMENDMENT NO. In? TO FACILITY OPERATING LICENSE NO. NPF-18 COMONWEALTH EDISON COMPANY j
LASALLE COUNTY STATION. UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374
1.0 INTRODUCTION
By letter dated October 31, 1996, the Commonwealth Edison Company (Comed, the licensee), submitted a request for changes to the LaSalle County Station, Units 1 and 2, Technical Specifications (TS). The proposed amendment would 1
relocate TS 3/4.3.7.2, " Seismic Monitoring Instrumentation" and associated Bases from the TS to the Updated Final Safety Analysis Report (UFSAR) in accordance with Generic Letter (GL) 95-10, " Relocation of Selected Technical Specifications Requirements Related to Instrumentation."
2.0 BACKGROUND
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TS as part of the license.
The i
Commission's regulatory requirements related to the content of the TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
The Comission has provided guidance for the content of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents.
Consistent with this approach, the Final Policy Statement identified four criteria to be used in detemining whether a particular matter is required to be included in the TS. These criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36 (60 FR 36953; July 19,1995). The criteria incorporated into the rule are as follows:
9701310276 970129 PDR ADOCK 05000373 P
- (1)
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.
As a result, existing TS requirements which fall within or satisfy any of the criteria must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
On December 15, 1995, the staff issued GL 95-10 " Relocation of Selected Technical Specifications Requirements Related to Instrumentation." This GL indicated that, in accordance with the 10 CFR 50.36 criteria, several specifications did not warrant inclusion in the TS. The GL listed several TS, including seismic monitoring instrumentation, as candidates for relocation to licensee-controlled documentation.
3.0 EVALUATION Section VI(a)(3) of Appendix A to 10 CFR Part 100, requires that seismic i
monitoring instrumentation be provided to promptly determine the response of those nuclear power plant features important to safety in the event of an earthquake. This capability is required to allow for a comparison of the measured response to that used in the design basis for the unit. Comparison of such data is needed to (1) determine whether the plant can continue to be operated safely, and (2) permit such timely action as may be appropriate.
However, seismic instrumentation does not actuate any protective equipment or serve any direct role in the mitigation of an accident.
The licensee has proposed to relocate these provisions to the UFSAR such that changes to the operation and surveillance of the seismic monitoring instrumentation could be made in accordance with 10 CFR 50.59.
The proposed TS change was requested to support a modification to replace the txisting seismic monitoring instrumentation. Spare parts for the current instrumentation are no longer available. Therefore, the new instrumentation will not be a like-for-like rcplacement and does not meet the description of the instrumentation in the current TS. The function of the seismic
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instrumentation and the alarm / annunciator setpoints will be unchanged by the i
modification. The licensee has committed to relocate the list of.the seismic monitoring components (as revised for the replacement instrumentation) to Table 3.7-11 of the UFSAR and the surveillance requirements to section 3.7.4 l
of the UFSAR.
The four criteria of 10 CFR 50.36 are addressed below:
(1)
Installed instrumentation that is used to detect, and indicate in i
the control room, a significant abnormal degradation of the reactor j
coolant pressure boundary; Seismic monitoring instrumentation is used to alert operators to the j
seismic event and evaluate the plant response. The Final Policy Statement explained that instrumentation to detect precursors to reactor coolant pressure boundary leakage, such as seismic instrumentation, is not included in the first criterion (58 FR 39137).
1 (2) a process variable, design feature, or operating restriction that
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is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; l
The seismic monitoring instrumentation provides information only and is j
not considered in any design basis accident or transient.
i (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis j
Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; The seismic monitoring instrumentation does not provide any function to mitigate an accident or the consequences of an accident.
(4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public i
health and safety.
The licensee has determined the loss of this instrumentation to be a i
non-significant risk contributor to core damage frequency and offsite release.
The staff has determined that the requirements for seismic monitoring instrumentation do not meet the 10 CFR 50.36 criteria for inclusion in the TS.
In addition, the staff finds that sufficient regulatory controls exist under J
10 CFR 50.59 to assure continued protection of public health and safety.
Therefore, the relocation of the seismic monitoring instrumentation from the 1
TS to the UFSAR is acceptable.
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Technical specification 3.3.7.2.a. currently requires that a special report be submitted to the Commission if one or more seismic monitoring instruments is inoperable for more than 30 days. The licensee proposes to delete the special reportirg requirement because the associated LCO is being relocated. The staff finds that the deletion of this requirement is acceptable based on the j
existence of adequate reporting requirements in 10 CFR 50.72 and 10 CFR 50.73.
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This change will have no effect on the health and safety of the public and is therefore acceptable.
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In addition to the changes to the TS, the operating licenses are modified by the addition of a license condition. The license condition approves the 3
relocation of the TS requirements to the UFSAR and states that the location of these requirements shall be retained by the licensee.
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4.0 STATE CONSULTATION
i In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendn.ents change a requirement with respect to the installation or use of j
a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released i
offsite, and that there is no significant increase in individual or cumulative j
occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (61 FR 66703). The amendments also change reccrd-keeping or reportirg i
requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 51.22(c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or 3
environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commiission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, j
and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
D. Skay Date: January 29, 1997 4