ML20216H427

Requests Addl Info to Complete Review of Util Request Re Proposed Amend Changes to TS for Control Room & Auxiliary Electric Equipment Room Emergency Filtration Sys

ML20216H427
Person / Time
Site:	LaSalle
Issue date:	03/17/1998
From:	Skay D NRC (Affiliation Not Assigned)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
TAC-M99726, TAC-M99727, NUDOCS 9803230016
Download: ML20216H427 (6)

Text

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Q s March 17, 1998 Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company Executive Towers West lil 1400 Opus Place, Suite 500 Downers Crove, IL 60515

SUBJECT:

REQUEST FOR ADDIT!ONAL INFORMATION - LASALLE COUNTY STATION, UNITS 1 AND 2 (TAC NOS. M99726 AND M99727)

Dear Mr. Kingsley:

' By letter dated September 26,1997, Commonwealth Edison Company (Comed) proposed to smond the technical specifications (TS) for LaSalle, Units 1 and 2. The proposed amendinent includes changes to the TS for the Control Room and Auxiliary Electric Equipment Room Emergency Filtration System and is supported by Calculatiobs L-001166, Post LOCA Control Room, Auxiliary Electric Equipment Room; and Offsite Doses" and Calculation L-001119, "VC/VE Mixed Air Relative Humidity Calculation." The staff has determined that the enclosed questions must be addressed in order for the staff to complete its review. Should you have any

. questione, please contact me at (301) 415-1322.

Sincerely, i i

E'4 Orig.' signed by Donna M. Skay, Project Manager n Project Directorate 111-2 grf Division of Reactor Projects - Ill/lV {

.g o.- Office of Nuclear Reactor Regulation j o Docket Nos. 50-373, 50-374

Enclosure:

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\*****/ March 17,1998 Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company Executive Towers West 111 1400 Opus Place, Suite 500 Downers Grove,IL 60515

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - LASALLE COUNTY STATION, UNITS 1 AND 2 (TAC NOS. M99726 AND M99727)

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Dear Mr. Kingsley:

By letter dated September 26,1997, Commonwealth Edison Company (Comed) proposed to amend the technical specifications (TS) for LaSalle, Units 1.and 2. The proposed amendment includes changes to the TS for the Control Room and Auxiliary Electric Equipment Room Emergency Filtration System and is supported by Calculations L-001166, " Post LOCA Control Room, Auxiliary Electric Equipment Room, and Offsite Doses" and Calculation L-001119, "VCNE Mixed Air Relative Humidity Calculation." The staff has determined that the enclosed questions must be addressed in order for the staff to complete its review. Should you have any questions, please contact me at (301) 415-1322.

Sincerely,

{

w 7M Y Donna M. Skay, Project Ma ger Project Directorate 111-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket Nos. 50-373,50 374

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Enclosure:

RAI cc w/ encl: see next page

O. Kingsley . LaSalle County Station .

Commonwealth Edison Company Units 1 and 2 oc:

Phillip P. Steptoe, Esquire - Michael 1. Miller, Esquire Sidiey and Austin . Sidley and Austin .

One First National Plaza One First National Plaza Chicago, Illinois 60603 Chicago, Illinois 60603 Assistant Attomey General Document Control Desk-Licensing 100 W. Randolph St. Suite 12 Commonwealth Edison Company Chicago, Illinois 60601 1400 Opus Place, Suife 400 Downers Grove, Illinois 60515 U.S. NRC-LaSalle Resident inspectors Offme 2605 N. 21st Road Commonwealth Edison Company Marseilles, Illir ois 61341-9756 Site Vice President - LaSalle 2601 N. 21st Road Chairman - Marseilles, Illinois 61341-9757 LaSalle County Board of Supervisors LaSalle County Courthouse Mr. David Helwig Ottawa, Illinois 61350 Senior Vice President Commonwealth Edison Company Attomey General Executive Towers West I!I 500 S. Second Street 1400 Opus Place, Suite 900 Springfield, Illinois 62701 Downers Grove,IL 60515 Chairman Mr. Gene H. Stanley

-Illinois Commerce Commission PWR's Vice President 527 E. Capitol Avenue, Leland Building Commonwealth Edison Company

- Springfield, Illinois 62706. Executive Towers West 111 1400 Opus Place, Suite 900 lllinois Department of Nuclear Safety Downers Grove,IL 60515 Office of Nuclear Facility Safety -

1035 Outer Park Drive Mr. Steve Perry .

Springfield, Illinois 62704 BWR's Vice President .l Commonwealth Edison Company -1 Regional Administrator Executive Towers West til  !

U.S. NRC, Region ill 1400 Opus Place, Suite 900 j 801 Warrenville Road Downers Grove, IL' 60515 l Lisle, Illinois 60532-4351 l

_ Mr. Dennis Farrar i Commonwealth Edison Company Regulatory Services Manager  ;

LaSalle Station Manager Commonwealth Edison Company 2601 N. 2ist Road Executive Towers West 111 i Marseilles, Illinois 61341-9757 1400 Opus Place, Suite 500 Downers Grove,IL 60515 Robert Cushing, Chief, Public Utilities Division i Illinois Attomey General's Office 100 W. Randolph Street Chicago, Illinois 60601

O. Kingsley LaSalle County Station Commonwealth Edison Company Units 1 and 2 Ms. Irene Johnson, Licensing Director Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West lil 1400 Opus Place, Suite 500 Downcrs Grove, IL 60515 Commonwealth Edison Company Reg. Assurance Supervisor- LaSalle 2601 N. 21st Road Marseilles, Illinois 61341-9757 Mr. Michael J. Wallace Senior Vice President Commonwealth Edison Company Executive Towers West 111 1400 Opus Place, Suite 900 Downers Grove,IL 60515 l

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REQUEST FOR ADDITIONAL INFORMATION

1. The scaling factors to adjust the main steamline isolation valve (MSIV) leakage contribution to control room operator dose for the changes made to the ventilation systems were calculated as the ratios of the Murphy-Campe iodine protection factors (IPFs) of the new over old designs. Provide the IPFs and scaling factors used for the design basis case identified and demonstrate that these result in conservative and bounding doses.

2. Calculation L-001166 assumes that the concentration of unfiltered (Auxiliary Building air) inleakage into the control room is the same as the concentration of air at the control room ventilation system intakes. Calculation L-00166 also assumes that the MSIV leakage released from the condenser into the Turbine Building is released directly into the environment from the Turbine Building. If air flows from the Turbine Building into the Auxiliary Building during the design basis loss-of-coolant accident (DBLOCA), then the concentration of the unfiltered inleakage may be greater than the concentration of air at the control room ventilation system intakes. What is the basis for assuming that this flow path will not exist?

3. a. Calculation L-001166 assumes that the DBLOCA is the bounding accident for control room habitability. The main steamline break (MSL) and rod drop accidents also produce significant releases to challenge control room habitability. What is the basis for assuming that the DBLOCA is bounding?

b. Does the MSL accident analyzed in the Updated Final Safety Analysis Report (UFSAR) take credit for any filtratiun?

c. If the MSL accident were to occur with reactor coolant activity at the peak Dose Equivalent lodine-131 value allowed by Technical Specifications (TS), would the DBLOCA still be the bounding F.cedent for control room habitability?

4. Regulatory Guide (RG) 1.3 states that assumption of an elevated release is only appropriate if the stack is 2.5 times as high as any building that impacts the plume. LaSalle's stack is approximately 2 times as high as the reactor building. Provide a justification for assuming an elevated release, contrary to the guidance in RG 1.3.

5. The term "in general conformance with" in proposed TS 6.2.F.8, " Ventilation Filter Testing Program" implies that portions of these standards will not be met. Please clarify.

6. Your submittal states that proposed TS 6.2.F.8, " Ventilation Filter Testing Program" is  ;

consistent with the requirements in NUREG-1434, " Standard Technical Specifications, General Electric Plants, BWR/6". TS 5.5.8.d in NUREG-1434 requires demonstration for each of the ESF systems that the pressure drop across the HEPA filter, profilters and charcoal adsorbers is less than the value specified. The purpose of this test is to ensure that the fan is capable of supplying the TS required flow rate with the loading on the filter components that is expected to occur during the course of the accident. Since the CRRF and AEERRF are parts of the ESF systems that are relied on in the dose analysis, this test l is required for these filters as well.- Provide a basis for not including pressure drop tests for i the CRRF and AEERRF in the proposed TS.

The staff typically uses a pressure drop of 2 inches water gage for each component  !

(prefilter, HEPA filter, and 2 inches of charcoal) in the filter housing. Since the CRRF and  :

AEERRF recirculation housings at LaSalle have a prefilter and a 2 inch charcoal filter bed,  !

they should be tested for a maximum pressure drop of 4 inches water gage. Can the CRRF and AEERRF fans at LaSalle supply the TS required flow rate with a 4 inch water gage pressure drop across the prefilter and charcoal filter? If not, what is the maximum pressure

2 drop across the profilter and charcoal filter at which the CRRF and AEERRF fans can still supply the TS required flow rate and what is the basis for this maximum pressure drop?

7. BR 4.7.2.a.1 should be revised to specify the filters for which this surveillance applies.

8. TS 3.7.2 Bases states that:

" Cumulative operation of the system with the heaters OPERABLE for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters."

This statement should be modified to specify that the system is run continuously for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

9. The tracer gas test that was performed in 1996 found 500 cfm of unfiltered inleakage in the

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control room for only one train and 1200 cfm and 2900 cfm of unfiltered inleakage in the auxiliary electric equipment room for each train.

A. Was this test determining the integrity of the control room envelope by measuring unfiltered inleakage for the control room envelope or was this test determining the integrity of the ductwork by measuring the inleakage into the ductwork?

B. Which tracer gas test method was used (Concentration Decay, Concentration Buildup / Steady State, or Buildup / Decay)?

C. How were the other inleakages (g1 and g3 in calculation L-001166) determined? I

10. What would be the effect in the control room and auxiliary electric equipment room of a fire in the Auxiliary Building, taking into consideration the increased amount of unfiltered inleakage into these rooms?

11. What effect does the 1200 cfm unfiltered inleakage have on control room habitability during a toxic chemical release? Have the shipping pattems of toxic gasses within five miles of the La Salle station changed since the issuance of safety evaluations in 1986 and 1989?

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