ML20235J462

Requests Relief from Notification & Reporting Requirements of IE Bulletin 86-002 & Committed to in long-term Action Plan Re Static O-Ring Reportability

ML20235J462
Person / Time
Site:	LaSalle
Issue date:	02/06/1989
From:	Morgan W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
5539K, IEB-86-002, IEB-86-2, NUDOCS 8902240283
Download: ML20235J462 (3)

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b Commonwealth Edison -

T One First National Plaza. Chicago, lHinois ;

i Address Reply to: Post Olkce Box 767 Chicago, Illinois 60690 February'6,;1989-U.S. Nuclear. Regulatory Commission H

Attnt. Document Control Desk Washington, DC 20555 1

Subject:

LaSalle County Station Units 1 and 2 Static "O" Ring Deportability NRC Docket Nos. 50-373 and 50-374 References (a):

IE Bulletin No. 86-02 " Static

'O' Ring Differential Pressure Switches" dated July 18, 1986.

(b)*

December-22,.1986 letter from B.L. Thomas to H.R. Denton transmitting the SOR Differential Pressure Switch Long Term Action Plan and Justification for Continued Operation (c): March 10, 1987 letter from C.M. Allen to U.S.-NRC transmitting Revised Surveillance-Requirements for SOR Differential Pressure

' Switch Long Term Action Plan.

Dear Sir:

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At the present time, SOR differential pressure switches that exceed their reject limit (limit established which is more conservative than the technical specification limit) are rejected from further service and replaced. These failures have been reported in accordance with 10 CFR 50.72 (Immediate Notifications) and 10 CFR 50.73 (Licensee Event Repor* System) as a Voluntary LER as required by IE Bulletin No. 86-02 in Faragraph 4 of section titled Agtlons' Required of All_Licanages (Reference (a)).

In the past two years, LaSalle has had 13 of these SOR dp switch failures, where each failure required an ENS notification and LER.

These ENS Notifications and LERs reflect negatively in LaSalle Station's rating in the Systematic Assessment of Licensee Performance (SALP) without due justification because, in most cases, Technical Specification limits are not exceeded.

Even if the LCO is exceeded, 1

the failure would not normally be reportable per the criteria of 10 CFR 50.72 l

and 10 CFR 50.73.

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--2 FebEuary 6, 1989 LaSalle County Station has put in-place, since IEB 86-02 became 4 effective,.a Long Term Action Plan (References (b) and.(c)) which established

new surveillance-requirements, action.11mits, reject limits and associated

.setpoints for the dp switches, along with modification plans for replacement

, of SOR dp switches. This Action Plan incorporated the.10 CFR 50.72 and 10 CFR 50.73 reporting requirements.

LaSalle. County Station-is requesting relief'from the Notification and Reporting requirements of IEB 86-02.and committed to in the Long Term Action

. Plan.

SOR dp switch failures will still be reported to the NRC within 30' days.

of. discovery using the attached,SOR dp Switch Failure Data Sheet and a cover

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letter.

LaSalle will-continue to investigate'each failureJand document this investigation with a -deviation report, NPF;DS Failure Report 'and Instrument Discrepancy Record.

Tour expeditious response regarding this matter would be greatly appreciated.

Any questions you may have concerning this matter can be directed to this office.

Very truly yours,

. W W.E.

organ Nuclear Licensing Administrate.r 1m 1

l cc A.B. Davis - Regional Administrator, RIII P.C. Shemanski - NRR, Project Manager Senior-Resident Inspector - LaSalle i

p 5539K

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SOR do Switch Failure Data'Sheetl

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g Model Number

, Equipment Piece Nurnbert

. Serial! Number:

Applications'

'Date and Time of'Discoveryi, hours Reactor Modes Power Levels

.' Calibration Tolerance s --

"WC LNominal Setpoints "WC

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Action Limits:

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' or > :

"WC Reject >Limitst.

. Technical Specification Limit ~

' +/-

"WC As Found Setpoints.

"WC Date and Time of Return to. Services hours

- i Model Number of Replacement Switch

. Serial' Number of' Replacement Switch:

Cause I,

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Corrective Actions l) i I

.l DOCUMENT ID 3276r/

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