ML20248D808
| ML20248D808 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/31/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Bradley Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8908110138 | |
| Download: ML20248D808 (4) | |
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N' j/. j Commonwrith Edison a
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.( r 72 West Adams Street, Chicago. Ilknois
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Address Repfy to: Po5i DfEe bot 767~
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Chicago, Ilknois 60000 0767 j
July 31, 1989
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l Mr. A.
Bert Dhvis Regional Administrator U.S. Nucleer Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subject?
LaSalle County Station Units 1 and 2 Response to Inspection Report Not..
50-373/89014 and 50-374/89014 j
NRC Docket Nos. 50-373 and 50-374 Reference (a): Letter from L.R. Greger to Cordell Reed dated June 30, 1989, transmitting Inspection Report 50-373/89014 and 50-374/89014.
l Dear Mr. Davis This letter is in response to the inspection conducted by Messrs.
p C.F. Gill and M.J. Slawinski of certain activities at LaSalle County Station.
Reference (a) indicated that certain activities appeared to be in noncompli-ance with NRC requirements. The Commonwealth Edison Company's response to the Level IV Notice of Violation is provided la the Attachment.
If you have any further questions regarding t.his matter, please I
contact this office.
Very truly yours, j
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fot 8908110138 890731 T
T.J. Kovach PDR ADOCK 05000373:
Nuclear Licensing Manager O
PNU 1m Attachment l
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R.D. Lanksbury - Senior Resident Inspector, LSCS l
I P.C. Shemanski - Project Manager, NER l
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CECO RESPONSE TO LASALLE COUNTY STATION UNITS 1 AND 2
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LI2/IL,,,U1 VIOLATION 373/B3014-031 374./19014-03 l
ylOLATION:
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, j
and Drawings, requires that activities affecting quality be prescribed by
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I documented instructions, procedures, or drawings and be accomplished in accordance with these instructions, procedures, or drawings and that instr uctions, procedures, or drawings shall include appropriate quantitative I
or qualitative acceptance criteria for determining that important activit.ies have been satisfactorily accomplished.
Technical Specification Surveillance Requirements 4.6.5.3.b.2 and l
4.6.5.3.c for the Standby Ces Treatment System and 4.7.2.b.2 and 4.7.2.c for the Control Room and Auxiliary Electric Equipment Room Emergency Filtration System specify that the charcou edsorbers meet the 'aboratcry testing critoria of Eegulatory "ositlon C.6.a of Regulatory Guide 1.52, Revision 2, j
March 1978. This regt atory position specifica, that charcoal adsorbers of two-inch bed depth with assigned decontaminatir)n efficiencies of 95% be tested with methyl iodide with a penetration acceptance criterion of less ti.an 1% and that charcoal adsorbers of four-inch or greater bed depth with assigned decontamination efficiencies of 99% be tested with methyl iodide with a l
penetration acceptance criterion of less than 0.175%
Nuclear Eegulatory Commission (NRC) Generic Letter No. 83-13, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorl'er Units in Standard Technical Specifications ou EST Cleanup Systems, l
issued to all applicants for operating licenses and holders of construction permits for power reactors on March 2, 1963, specifies a methyl lodide penetration test acceptance criterion of less than 0.175% when a enarcoal adsorber efficiency of 99% is assumed m less than 1% when a charcoal adsorber ef ficiency of 95% is assumed in the NRC staf f's safety evaluation. The NRC ctaff's Safety Evalustion Report for LaSalle County Station Units 1 and 2, HUREG-0519, March 190t, states that the Standby Gas Treatment System charcon' I
bed depths are eight inches with an assigned elficiency of 99% (Subsections 6.5.2.2 and 15.3.2.1 and Table 15.1) and that the Control Room and Auxiliary 2
l Electric Equipment Room Emergency filtration System charcoal bed depths are I
two inches with an assigned efficiency of 95% (Subsection 6.5.2.1).
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4 Contrary ti the above, the licensee failed to include the appropriate quantitative and qualitative acceptance criteria specified by Technical Specifications for the aforementioned ventilation systems into the implementing procedure in that Station Procedure No. LTS-400-16, Removal of Carbon Test Canisters from Filtration System Trains for Analysis, establishes an acceptance l
criterion for methyl iodide penetration of less than or equal to 10% rather than the Technical Specification Surveillance Requirement acceptance criteria for methyl lodide penetration of less than 0.175% for the Standby Gas Treatment System and 1% for the Control Room and Auxiliary Electric Equipment Room Emergency Filtration System. As a result of the erroneous procedural acceptance criteria there were five apparent failures to meet Technical Specification Surveillance Requirements (April 4, 1985; May 01, 1985 (two adsorber beds); and June 5, 1985 (two adsorber beds)) and four periods of time during at least part of which the licensee was in apparent violation of Technical Specification Limiting Condition of Operation Action Requirements which specified restoration of the inoperable ventilation systems or reactor shutdown within specified periods of time (April 4 through July 1, 1985; May 31, 1985 through November 25,1986; June 5,1985 through July 8, 1986; and June 5, 1985 through December 3, 1986).
CDRRECTIVE ACTION TAKEN AND RESULTS ACHIEVED LER 373/89-019-00 was issued which investigated the circumstances of the problem, the causes, safety consequences, and corrective actions.
LaSalle Technical Surveillance LTS-400-16, " Removal of Carbon Test Canisters from Filtration System Trains for Analysis" was revised to include the following:
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Standby Gas Treatment (SBGT) charcoal filters will be tested for an acceptable penetration of less than 0.175% at a face velocity of 20 fpm.
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Control Room Emergency Make-up charcoal filters will be tested for an acceptable penetration of less than 1.0% at a f ace velocity of 40 fpr.
3.
Control Room Recirculation charcoal filters will be tested for an acceptable penetration of less than 10.0% at a face velocity of 80 fpm.
CORRECTIVE ACTION TAKEN TO AVOID FURlHER VIQLATJDH Technical Specifications will be revised to provide explicit acceptable penetration criteria requirements for the SBGT and Control Room charcoal filters based on a new control room dose assessment which is currently underway.
It is expected that this proposed amendment can be submitted by early September, 1989.
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DAllLQF - FULL COMPLI ANCE
' The Station-is presently in f all compliance in that all Standby Gas Treatment and Control Room Ventilation charcoal filters meet the appropriate acceptance criteria and LTS-400-16 was revised on June 26, 1989 to reflect
.these acceptance criteria. Following NRC review and approval of the proposed revision to the Technical Specifications discuFsed above, LTS-400-16 will be revised accordingly.
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