ML20205P801

Application for Amends to Licenses NPF-11 & NPF-18,revising Tech Specs to Clarify Ambiguous Wording Re Frequency of Fast Starting & Loading of Diesel Generators from Ambient Conditions

ML20205P801
Person / Time
Site:	LaSalle
Issue date:	11/02/1988
From:	Morgan W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20205P806	List: ML20205P801 ML20205P807
References
3389K, NUDOCS 8811080300
Download: ML20205P801 (4)

Text

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w ;5> ;p 7/- CN Commonwealth Edison

'* _[ ) One First Nition11 Plaza. Chicago. lilinois l C Addrrss Riply to: Post Office Bog 767.

\ . Chicago, lilinois 60690 November 2, 1988 U.S,. Nuclear Regulatory Commissiu;t Attn: Document Control Desk ,

Washington, DC 20555

• l Subjects LaSalle County Station Units 1 and 2 Proposed Amend *.sents to Diesel Generator -

Technical Specifications for Facility Operating Licenses NPF-11 and NPF-18 HRC Docket JQh_iO-373 and 50-374 References (a): Federal hghter Vol. 51 No. 44 dated Thursday, Merch 6, 1986. >

(b): Letter dated July 23, 1987 from D.R. Muller to L.D. Butterfield (c): Letter dated July 28, 1987 from ,

C.M. Allen i E

Dear Sirs Pursuant to 10 CFR 50.90 Conwnonwealth Edison proposes to amend Facility Operating Licenses NPF-11 and NPF-18. This revised ame.ndment roquest.

is being submitted for your staff's review and approval and is in accordance, with reference (a). This is a revision to the amendmeat request submitted. in Attachment (c) and entirely replaces that submittel.  !

r This change is being submitted at the request of your staff (Reference (b)) to clarify technical specification wording which has been determined to be ambiguous. The rhenge ir. a puroly administratlve changs of -

wording to clarify the intent of the technical specification. i We request approval for this enange ad soon es possible. The ,

effective date of this amendment, when approved, should be 30 days following f the date of issuance.

Attachment A provides an introduction and discussion. Attachment B (

provides copies of the changes to be made to the Facility License. Commonwealth Edison has reviewed this document and finds that no significant hazards exists. l This review is documented in Attachment C. l t

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Commo.1 wealth Edison is notifying the State of Illinois of our request  !

for this amendment by transmitting a copy of this letter and attachments to i the designated state official.

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f0 8911080300 891102 g PDR ADOCK 05000573 P PDC

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USNRC November 2, 1988 If you have any additional questions regarding this matter, please-contact this office.  ;.

Very truly yours, (N

W. ' Morgan Nuclear Licensing Administrator i

9d Attachments cc Paul Shemanski - NRR Regional Administrator - RIII NRC Resident Inspector - LSCS

- M. C. Parker - IDNS P

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October 12, 1988 ATTACliMENT A BAflGROUND AND DISCUSSION BACKGROUND A question concerning interpretation of the technical specification requirements for the frequency of fast starting and loading of the diesel generators from ambient conditions has been raised by the NRC. Technical Specifications 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 originally required a fast start'and loading of the diesel generators in accordance with Table 4.8.1.1.2-1 (normally on a monthly basis). A footnote was added to the specifications (prior to licensing) to relax these requirements such that a

. fast start and load would only be required once every 6 months (184 days).

The balance of the monthly tests would include a warmup period as  ;

recommended by the manufacturer, to minimise the mechanical stress and wear,

- caused by fast starting and loading of the diesel generators. ?he question regards the ambiguity in the wording of the existing footnote which could be interpreted to apply the relaxation to the 13 second start requirement in Technical Specification 4.8.1.1.2.a.4 only, and not to the 60 second load requirement in Technical Specification 4.8.1.1.2.a.5. The station has always applied the footnote to both surveillance requirements.

On July 28, 1987 Commonwealth Edison submitted a request (reference f) to revise the Technical specifications accordingly. Upon review of the submittal the NRC expressed some concerns about the wording and placement of the footnote and requested that Commonwealth Edison revise the footnote to further clarify the issue. This submittal is intended to 4 address those concerns.

DISCUSSION i

On December 9, 1983 Commonwealth Edison requeJted (reference d) that the Unit 1 technical specifications be amended to allow a relaxation of the diesel generator fast start requirements. This proposed aman >1mont wr5 based on the investigation and analysis performed by the NRC in reference (c). The submittal clearly stated that it was the intention of LaSalle Station to apply the footnote to both the 13 second start requirement and the 60 second load requirement. The proposed snendment was approved by ths NRC in Amendment 16 to the LaSalle Unit 1 technical specifications and the mnendment was also mentioned in the LaSalle SSER 7. The snendment to the Unit 2 technical specifications was approved prior to initial licensing of that unit.

Based on the above discussion it is proposed that the Unit 1 (NPT-11) and Unit 2 (NPT-18) technical specifications be revised (see Attachment A) to clarify the intent of the footnote as follows:

• Revise the footnote so that it is clear that it applies to the requirements of both Technical Specification 4.8.1.1.2a.4 and 4.8.1.1.2.a.5.

• Revise the technical specification bases to more accurately describe the Intent of the footnote.

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-HETERENCES

a. Final Procedures.and Standards on No Significant Hazards-Considerations, Final Rule, 511rR 7744.

b. Technical Specifications 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5

c. NUREG-0519 Supplement No 7, Safety Evaluation Report related to operation of LaSalle county Station, Units 1 and 2.

d. NRC Internal Memorandum For Power System Branch from Reliability and Risk Assessment Branch dated February 4, 1983, "Frequency of Diesel Generator rast Start Surveillance Testing By Technical Specification Requirement.

e. Commonwealth Edison latter to Harold R. Denton dated December 9, 1983, "LaSalle county Station Units 1 and 2 Request for An Exigent Change to NPT-11 Appendix A Technical Specifications Regarding Diesel Generator rast Starts."

f. Commonwealth Edison letter to Nuclear Regulatory Commission, "LaSalle county Station Units 1 and 2 Proposed Amendments to Diesel Generator Technical Specifications for racility Operating Licenses NPT-11 and NPT-18, NRC Docket Nos. 50-373 and 50-374," dated July 28, 1987.