ML20211P917

Application for Amends to Licenses NPF-11 & NPF-18, Eliminating Unnecessary Details from Accident Monitoring Instrumentation Surveillance Requirements

ML20211P917
Person / Time
Site:	LaSalle
Issue date:	10/15/1997
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20211P926	List: ML20211P917 ML20211P933
References
NUDOCS 9710220029
Download: ML20211P917 (7)

Text

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, 2001 North 21st Road Marwilles, II.61.411 9757 ni sisasw6i October 15,1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

LaSalle County Station Units 1 and 2 Application for Amendment of Facility Operating Licenses NPF-11 and NPF 18, Appendix A, Technical Specifications, Elimination of Unnecessary Detail from the Accident Monitoring Instrumentation Surveillance Requirements.

LaSalle County Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Pursuant to 10 CFR 50.90, Commonwealth Edison Company (Comed) proposes to revise Appendix A, Technical Specifications of Facility Operating Licenses NPF-11 and NPF-13, LaSalle County Station Units 1 and 2. The proposed changes include changes to the Technical Specifications (TS) to eliminate unnecessary detail from the Accident Monitoring Instrumentation Surveillance Requirements. The TS affected is TS Table 4.3.7.5-1, Accident Monitoring instrumentation Surveillance Requirements.

This proposed amendment request is subdivided as follows:

1. Attachment A contains a description and safety analysis of the proposed changes in this amendment.

2. Attachment B includes the marked-up Licensefi echnical Specifications pages for LaSalle Units 1 and 2 with the requested changes indicated.

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3. Attachment C describes Comed's evaluation performed in i accordance with 10 CFR 50.92 (c), which confirms that no significant hazard consideration is involved.  ; k

4. Attachment D provides an Environmental Assessment Statement Applicability Review per 10 CFR 51.21.

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This proposed amendment has been reviewed and approved by Comed

- On Site and Off Site Review in accordance with procedures.

Comed requests approval of this license amendment request prior to startup of LaSalle Unit 1 from its current forced outage, L1F35. The amendment should be made effective upon issuance for both units. Comed will implement the amendment prior to startup of LaSalle Units 1 and 2, from their current respective outages.

Comed is notifying the State of Illinois of this application for smendment by transmitting a copy of this letter and its attachments to the designated state official.

If there are any questions or comments conceming this letter, please refer them to Perry Barnes, Regulatory Assurance Supervisor, at (815) 357-6761, extension 2383.

Respectfully, W. T. Subalusky \ '-

Site Vice President LaSalle County Statie g#/

Enclosure cc: A. B. Beach, NRC Region ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle F. Niziotek, Office of Nuclear Facility Safety - IDNS

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STATE OF ILLINOIS )

COUNTY OF LASALLE )-

Docket Nos. 50-373 50 374 IN THE MATTER OF )

COMMONWEALTH EDISON COMPANY )

LASALLE COUNTY STATION - UNITS 1 & 2 )

AFFIDAVIT l affirm that the content of this transmittal is true and correct to the best of my knowledge,information and belief.

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" Wihiam'T. Subaluy>T Site Vice President -

LaSalle County Station Subscribed and swom to before me, a Notary Public in and for the gtate and County above named, this /M day of Ncdwlu o . 197 7. My Commission expires on 10 - 1 . Acco.

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Description of the Proposed Chance Commonwealth Edison Company (Comed) proposes to revise Appendix A, Technical Specifications of Facility Operating Licenses NPF-11 and NPF-18, LaSalle County Station Units 1 and 2. The proposed changes include changes to the Technical Specifications (TS) to eliminate unnecessary detail from the Accident Monitoring instrumentation Surveillance Ken,uirements. The TS affected is TS Table 4.3.7.5-1, Accident Monitoring instrumentation Surveillance Requirements.

Description of the Current ODeratino License / Technical SDeClflCation Reauirement TS Survaillance Requirement (SR) 4.3.7.5 requires the accident monitoring instrumentation channels ilsted in Table 3.3.7.5-1 to be demonstrated Operable by performance of Channel Checks and Channel Calibrations at the frequencies shown in Table 4.3.7.5-1.

Table 4.3.7.5-1 lists the Instrumentation and the associated surveillance frequencies. Item 9, Drywell Hydrogen Concentration Analyzer and Monitor, requires calibration on a quarterly interval. The Channel Calibration for this {

instrumentation is modified by footnote *, which requires the calibration to be done using a sample gas containing four volume percent hydrogen, with the balance nitrogen.

Bases for the Current Reautrement The Bases for TS 314.3.7.5 is as follows:

"The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess important variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97," Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident," Deumber 1975 and NUREG-0578,"TMI-2 Lessons Learned Task Force Statur Report and Short-Term Recommendations."

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

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TS Table 4.3.7.5-1, item 9, states the surveillance requirements for the Drywell Hydrogen Analyzer and Monitors. The quarterly Channel Calibration frequency is modified by footnote *, which requires the calibration to be performed using a sample gas containing four volume percent hydrogen, with the balance nitrogen.

Description of the Need for Amendina the Operatina License / Technical Specification FSAR section L.30, part 6, related to Accident Monitoring instrumentation for Containment Hydrogen Monitoring in accordance with TMl Action Plan item II.F.1.6, stated that the hydrogen monitors met the requirement of a 0% to 10%

range, with an accuracy of i 10% of span. Unit 1 LER 97-019-00 documented that the use of a calibration gas containing four volume percent hydrogen, which is used to span the instrumentation, results in the Control Room indication for drywell hydrogen concentration being limited to a range of 0% to E 4%. The design and licensing basis requires a 0% to 10% indication range,

• which thus requires a calibration gas containing hydrogen gas concentration to span the instrumentation to result in a range of 0% to 10%.

The TS definition of Channel Calibration requires calibrating instrumentation channels over the range of use of the instrument. The hydrogen instruments are used to measure drywell concentration over a range of 0% to 10%.

Therefore, use of 4% as the calibration gas does not meet the TS definition.

Footnote

• spe.:lfles the use of the 4% calibration gas and thus conflicts with the need to use a 10% gas. The note also provides unnecessary detail that is specific to the type of instrument used.

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ATTACHM.ENT A DESCRIPTION OF SAFETY ANALYS!D OF THE P'tOPOSED CHANGES Qggcription of the Amended Operatina License / Technical Specification Reaulrement Footnote

• is proposed to be deleted from Table 4.3.7.5-1.

Bases for the Amended Operatina License / Technical Specification Reauest Footnote

• provides unnecessary detall concerning the calibration requirements for the drywell hydrogen concentration analyzer ar.d monitors that is specific to the type of instrument used for this appilcation. Although the information in the footnote is incorrect, TS SR 4.3.7.5, in conjunction with the frequency specified in Table 4.3.7.51, assures that the calibration of the instrumentation is performed as required without the footnote. The details of how to calibrate the instrumentation will be contained in appropriate station procedures. Therefore, footnote

• is proposed to be deleted from Table 4.3.7.5-1. This change to the level of information regarding this calibration is consistent with the detail for this and other instrumentation in NUREG-1434, Revision 1, Standard Technical Specifications, General Electric Plants, BWRl6.

Schedule Comed requests approval of this license amendment request prior to startup of LaSalle Unit 1 from its current forced outage, L1F35, currently scheduled for December 9,1997. The amendment should be made effective upon issuance for both units. Comed will implement the amendment prior to startup of LaSalle linits 1 and 2, from their current respective outages.

A-3

ATTACHMENT B PROPOSED AMENDMENTS TO THE LICENSE / TECHNICAL SPECIFICATIONS f

NPF-11 NPF-18 3/4 3-69* 3/4 3-69*

3/4 3-71 3/4 3-71

• This ptge does not have changes; it is included for information only.

B-1

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