ML20245J021

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Identifies Need for Waiver of Compliance for Unit 2.Waiver of Compliance Requested to Be in Effect Until Forthcoming Amend Request Approved by NRC
ML20245J021
Person / Time
Site: LaSalle 
Issue date: 06/16/1989
From: Morgan W
COMMONWEALTH EDISON CO.
To: Murley T
Office of Nuclear Reactor Regulation
References
NUDOCS 8906300165
Download: ML20245J021 (3)


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Addrrss Reply to: Post OIEe Bisii76T

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A Chicago, Illinois 60690 - 0767 June 16, 1989 Dr. Thomas-E. Murley, Director Office of Nuclear Reactor Regulation U.S.~ Nuclear Regulatory Commission ~

Washington, DC l20555

Subject:

LaSalle f'ounty Station Unit 2 Proposed Waiver of Compliance tiEp_QIAttt No. SD-374

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Dear Dr. Murley:

1 Thl's letter identifies a.'need for a Waiver'of Compliance-r r LaSalle a

. County Station Unit 2.

Your prompt attention to this matter is requested to avoid. undue impact on. plant operations and equipment.

As a result of the inoperable status of the LaSalle Station 2B Diesel Generator, LaSalle Station, per its Technical Specifications, is required to

" Demonstrate.the operability of the remaining A.C. sources by performing surveillance ~ requirements 4.8.1.1.la within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 4.8.1.1.2a for.one Diesel Generator at a time within six hours and, at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter..."

This requirement to test each Diesel Generator every eight' hours has

- been recognized by Commonwealth Edison and NRC staff as an undue burden on the Diesel Generators that could potentially affect their operation when required.

After discussions with your staff on June 15 and 16, 1989, it was agreed that a Waiver of Compliance should be pursued in order to relax the requirement until a permanent change to the Technical Specification has been

- requested and approved.

The following attachment provides background information and a justification for the actions implemented until the proposed change is approved.

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t 8906300165 890616 f

PDR ADOCK 05000374 P

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T.E. Murley June 16, 1989 l

l This Waiver of Compliance is requested to be in effect until the j

forthcoming amendment request is approved by the NRC.

The forthcoming amendment request, when submitted, will address both Units 1 and 2 and all Diesel Generators that are affected by the current requirement.

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If you have any further questions regarding this submittal, please contact this office.

j Very truly yours, E

/C AM W.E. Worgan Nuclear Licensing Administrator sc1:

Attachment cc:

A.B. Davis - Regional Administrator, RIII P.C. Shemarski - Project Manager, NRR Senior Resident Inspector - LSCS 0171T 1-2

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ATTAQ94M I_A On' June 14, 1989 the 2B diesel generator was damaged (the diesel had previously been declared inoperable). The diesel generator was not' danaged due to a problem with the diesel generator itself but with the offsite power supply' breaker.which inadvertently closed.

It is expected that the repair i,

will take several days. The other diesels which support Unit 2 operation (0, L

2A and 1A) have been tested every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, in accordance with Technical' Specification 3.8.1.1 Action e.

Commonwealth Edison believes that starting the remaining diesel's every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, is detrimental to their reliability and should be discontinued.

Currently Technical Specification 3.8.1.1 Action.e. for LaSalle Station Unit 2 requires that surveillance requirement 4.8.1.1.2.a.4 be performed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter when the 2B diesel generator is inoperable.

Action e. also-requires that the diesel be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or that the high pressure core spray-(HPCS). system be declared inoperable.

It should be noted that although

'the HPCS system'is declared inoperable, and not utilized to fulfill any Technical Specification requirements, it is normally left in standby, ready for auto initiation whenever it's normal offsite power system power source is available.

The 2B Diesel Generator supplies only the HPCS system.

Since'no further credit is taken for the operability of the HPCS system, the diesel is no longer required to be operable. Because the diesel is no longer required, i

there should be no requirement to continue testing the remaining diesel generators 0, 1A, and 2A.

This request increases the reliability of the other diesels when the 20 diesel generator is inoperable. Continued testing of the other diesels every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is excessive and results in degradation of the diesel engine.

This is contrary to assuring a reliable source of backup power. This is consistent with the guidance of Generic Letter 84-15 in that it is a reduction in excessive diesel testing.

0171T 3

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