ML20236X014

Application for Amends to Licenses NPF-11 & NPF-18,proposing That Provisions of Section 4.0.2.b of Tech Specs Would Not Apply to Refuel Interval Surveillances.Fee Paid

ML20236X014
Person / Time
Site:	LaSalle
Issue date:	12/04/1987
From:	Allen C COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20236X015	List: ML20236X014 ML20236X036
References
3792K, NUDOCS 8712080373
Download: ML20236X014 (5)

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Commonwmith Ediaon 3 3, One First National Plaza, Chicago, liknois V Address Reply to. Post Office B07767-~

Chicago, Illinois 60600 - 0767 December 4, 1987 U.S. Nuclear Regulatory Commission Attn: Do7ument Control Desk Washington, DC 20555

Subject:

LaSalle County Station Units 1 and 2 Proposed Amendment to Technical Specifications for Facility Operating License NPP-ll and NPF-18 NRC Docket No. 50-373 and 50-374

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References -(a): Federal Register Vol. 51 No. 44 dated March 6, 1986

Dear Sir:

Pursuant to 10 CFR 50.90 Commonwealth Edison proposes to amend Facility Operating Licenses NPF-11 and NPF-18. This amendment is being submitted for your staff's review and approval and is in accordance with reference (a).

The proposed amendment identifies that the provisions of section 4.0.2.b of Technical Specifications would not apply to refuel interval surveillance. Elimination of this requirement has no safety significance and will allow scheduling of refueling interval surveillance to correspond to actual scheduled refuel outages.

This issue has generic implications and Commonwealth Edison is agreeable to have LaSalle county Station considered lead plant for this subject. However note that approval is required prior to June 15, 1988 to allow Unit 2 to continue operation. We have approached the BWR Owners Group for consideration as lead plant as described in the Technical Specification Improvement Program dated June 1987 and will forward their response when received.

Attachment A provides an introduction and discussion. Attachment B provides copies of the changes to be made to the Facility Licer.ses.

Commonwealth Edisen has reviewed this clocument and finds that no significant hazards exists. This review is documented in Attachment C.

Commonwealth Edison is notifying the State of Illinois of our request for this amendment by transmitting a copy of this letter and attachments to the designated state official. J

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w In accordance with 10 CFR 170,.a fee remittance in the amount of.

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'$150.00 is enclosed.

The ef fective date of this a:cendment should be the 'date of' issuance. If you:have any additional questions regarding this matter, please.' contact this office.

, .Very truly yours, s,

C, M. Allen Nuclear Licensing Administrator

, Attachments cc: ' Paul Shemanski - NRR Regional Administrator - RIII' NRC Resident Inspector'- LSCS M. C. Parker - IDNS l' l L

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l KTTACHMENT A j i

TECHNICAL SPECIFICATION CHANGE REQUEST LASALLE COUNTY STATION UNITS 1 AND 2 l l

BACKGROUND AND DISCUSSION l

With the advent of longer feel cycles and less frequent and longer outages, LaSalle County Station is encountering difficulty completing )

surveillance required at a refueling interval by Technical Specifications. I As cycle planning continues with longer cycles this problem will-intensify. l 3

Initially the average fuel cycle was expected to last 12 to 18 months, depending on plant performance. Outages were expected to primarily  !

serve to allow refueling and to perform required surveillance. These outages are now predominantly involved in effecting modifications mandated by new regulations and requirements (NUREG-0737, Equipment Qualification, Appendix Rs Regulatory Guide 1.97) Consequently, over the past years l ccheduling has gone to 18-24 month cycles to improve unit availability, fuel ]

utilization and to reduce shutdowns. l The 18 month surveillance interval is based on uhat was perceived f to be the expected fuel cycle longth. This surveillance interval was ]

established during the original development of STS after discussions with q senior NRC staff members and NSSS and fuel vendors. A maximum time period j of 18 months wes thought to be sufficient to accommodate scheduling and performance considerations. Because there is no documented or expressed basis for either the 18 month interval or for the 3.25% value to apply to j the 18 month interval, we are requesting that the 3.25% value be indicated )

as not applicable for the 18 month interval (R as defined in Table 1.1). )

i This will alleviate the immediate problem and prevent recurrence of this specific situation for successive operating cycles.

The Unit 1 Cycle 2 refuel outage uas originally scheduled to begin j on December 7, 1987, however, problems with one of the reactor recirculation j pumps necessitated plant operati.on in single loop at a 50% power level for  !

an extended period of time. A major outage of approximately three months l duration was required to repair the recirculation pump. As a result of j these delays in the fuel cycle it was necessary to reschedule the Unit 1 Cycle 2 refuel outage to ensure adequate fuel utilization. The outage is now scheduled to begin on March 13, 1988. The extension of the Unit 1 fuel cycle has also impacted the Unit 2 schedule. Unit 2 was originally ,

scheduled to begin the next refuel outage on July 23, 1988. This schedule l would have resulted in an overlap of the Unit I and 2 outages. Since a two j unit outage is very difficult to plan for and would place excessive demands on the station rasources, it was decided to reschedule the Unit 2 refuel outage to begin on October 16, 1988 and to end in early 1989. The outage start date was moved as far back as the fuel cycle would permit in order to l provide a maximum amount of time for planning, preparation and scheduling )

between the Unit 1 and Unit 2 outages. l

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h. q over 100 of the LaSalle county Station Technical Specifications surveillance must be performed at 18 month intervals. Specification 4.0.2 j ellows this interval to be extended by as much as 25%. Specification 4.0.3 1 allows an even longer interval between tests provided that the equipment is j not required to be operable. For a single interval these allowances provide j sufficient flexibility (with appropriate preplanning) to reach the next j planned octage. Over time however, the limit (from 4.0.2.b), not to exceed i 3.25 times the stated interval for any three consecutive intervals, becomes extremely difficult to meet. For example, recent reviews of the upcoming cycle indicate that LaSalle will exceed the 3425 limit for more than 50 ]

surveillance prior to the scheduled refuel date of October 16, 1988. The l 1.25 interval does not require any of these to be done in this time frame. )

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If a forced shutdown does not occur during mid-cycle, either a surveillance outage or 4 massive technical specification relief request will  !

be necessary. In mar,i cases the 18 month surveillance test must be done in )

Modes 4 and 5 result.ing in making forced outages even longer as adequate preplanning cannot be accomplished. Thus efficient operation of the Unit is punished by requiring a shutdown solely to comply with the portion of the 18 4 month surveillance interval relating to the 3.25% criteria. Neither the j i

surveillance outage requiring an additional shutdown and associated transient nor the " band aid" solution of a one time technical specification relief are desirable. ]

The " surveillance outage" option is not considered to be necessary l or desirable for the following reasons:

• All of the Unit 2 surveillance requiring shutdown coming due prior to October 16, 1988 are limited by th6 3.25% criteria rather than the 1.25% criteria, l I

I The planning and scheduling of a surveillance outage of sufficient duration to meet all of the surveillance requirements due would )

conflict with the Unit I refuel outage and place a significant l drain on company resources at a critical time. j l

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• l'he same type of surveillance outage would also be required for the other unit and will also be required on succeeding operating cycles.  !

The "one time" technical specification amendment request option was  !

not considered desirabie for the following reasons;

• It is anticipated that the long fuel cycles and outages that have characterized the first two cycles on each of the units will I

continue into the future. This is consistent with industry experience and acknowledged by the NRC staff.

• The same resources are required by the preparation of a "one time" l technical specification amendment request as for a " permanent" l change.

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• Essentially the same NRC staff resources would be required for the )

technica1L review of the proposed amendment for a "one time" change j ac for a " permanent" change.  ;

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• This change has generic applications and submittal as a "tead plant"itemisinkeeksingwith"NRCTechnicalSpecificatiens Improvement Program P an, Rev. 2, June 1987".

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l Deletion of the requirement *any three consecutive intervals must not exceed 3.25 times the interval" will not significantly effect equipment reliability. The current criteria allows a 22.5 month interval for as many .

as two intervals during a three interval period. Deletion of the 3.25 j

, criteria will permit all three intervals to be a maximum of 22.5 months I long. Per specification 4.0.2. a the staff has already accepted that a 22.5 L

month interval will provide sufficient level of protection. Allowing this l l interval to be applied to all cycles will continue to; maintain a constant ]

level of protection. l J

Approval of this proposed amendment is required prior to l June'15, 1988 to prevent a Unit 2 shutdot . June 15 is the date of the j first surveillance using the~3.25% criteria that will require shutdown to (

perform. Approval of this proposed amendment will allow Unit 2 to continue  !

operation until the refuel outage scheduled for October 1988.

If for any reason this amendment cannot be reviewed using the " lead  !

plant" process we need to know as soon as possible. In that eventuality we will resubmit for a "one time" technical specification change to allow Unit 2 to remain at power.  ;

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