RS-02-076, Request for Amendment to Technical Specifications, Excess Flow Check Valve Testing Surveillance Requirement 3.6.1.3.8 & Relief Request RV-12

From kanterella
(Redirected from RS-02-076)
Jump to navigation Jump to search
Request for Amendment to Technical Specifications, Excess Flow Check Valve Testing Surveillance Requirement 3.6.1.3.8 & Relief Request RV-12
ML021630391
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 05/31/2002
From: Jury K
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-02-076
Download: ML021630391 (25)
v • d • e


Text

Exel I fZl-Exelon Generation www.exeloncorp.com Nuclear 4300 Winfield Road Warrenville, IL60555 10 CFR 50.90 RS-02-076 May 31, 2002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Request for Amendment to Technical Specifications Excess Flow Check Valve Testing Surveillance Requirement 3.6.1.3.8 and Relief Request RV-12 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company (EGC), LLC, proposes a change to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-1 1 and NPF-1 8.

Specifically, the proposed change modifies TS Surveillance Requirement (SR) 3.6.1.3.8 to reduce the number of excess flow check valves (EFCVs) required to be tested every 24 months. The proposed SR will require that a representative sample of reactor instrumentation line EFCVs actuate to the isolation position on an actual or simulated instrumentation line break signal every 24 months. All reactor instrumentation line EFCVs will be tested at least once every 10 years (nominal). The proposed change implements Technical Specification Task Force Traveler 334 (TSTF-334), "Relaxed Surveillance Frequency for Excess Flow Check Valve Testing," Revision 2.

The LaSalle County Station radiological dose assessment for an instrument line break is documented in the LaSalle County Station Updated Final safety Analysis Report (UFSAR)

Table 15.6-4, "Instrument Line Break Radiological Effects." The instrument line break analysis does not credit closure of EFCVs.

Additionally, in accordance with 10 CFR 50.55a(a)(3), this submittal includes Relief Request RV-12, Revision 0. The relief request proposes an alternative to the American Society of Mechanical Engineers (ASME) / American National Standards Institute (ANSI), Operation and Maintenance of Nuclear Power Plants, OMa-1996, Subsection Inservice Testing Code (ISTC),

Paragraph 4.1, "Valve Position Verification," and Table 3.6-1, "Inservice Test Requirements,"

that provides an acceptable level of quality and safety. The proposed change will require that a representative sample of EFCVs with remote position indication be observed locally at least AiLbl

May 31, 2002 U. S. Nuclear Regulatory Commission Page 2 once every two years (nominal) to verify that valve operation is accurately indicated. All EFCVs will be tested at least once every 10 years (nominal).

The proposed changes are similar to changes approved for Susquehanna Steam Electric Station, Units 1 and 2, by the NRC in two letters dated April 11, 2001.

The information supporting the proposed TS change is subdivided as follows.

1. Attachment A gives a description and safety analysis for the proposed TS change.
2. Attachment B includes the marked-up and retyped TS pages with the proposed change indicated.
3. Attachment C describes our evaluation performed using the criteria in 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (a)(1) which provides information supporting a finding of no significant hazards consideration in accordance with 10 CFR 50.92, "Issuance of amendment," paragraph (c).
4. Attachment D provides information supporting an Environmental Assessment.
5. Attachment E provides Relief Request RV-12.

The proposed TS change has been reviewed by the LaSalle County Station Plant Operations Review Committee (PORC) and approved by the Nuclear Safety Review Board (NSRB) in accordance with the Quality Assurance Program.

EGC is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.

We request approval of the proposed changes by December 2, 2002 to support the next refueling outage of LaSalle County Station, Unit 2, currently scheduled for January, 2003.

Should you have any questions concerning this submittal, please contact Mr. T. W. Simpkin at (630) 657-2821.

Respectfully, 4&Keith R. uryv Director - Licensing Mid-West Regional Operating Group Attachments:

Attachment A. Description and Safety Analysis for the Proposed TS Change Attachment B. Marked-up and Retyped TS Pages for the Proposed TS Change Attachment C. Information Supporting a Finding of No Significant Hazards Consideration Attachment D. Information Supporting an Environmental Assessment Attachment E. Valve Relief Request - RV-12.

May 31, 2002 U. S. Nuclear Regulatory Commission Page 3 cc: Regional Administrator - NRC Region III NRC Senior Resident Inspector - LaSalle County Station Office of Nuclear Facility Safety - Illinois Department of Nuclear Safety

STATE OF ILLINOIS )

COUNTY OF DUPAGE

)

IN THE MATTER OF:

)

EXELON GENERATION COMPANY (EGC), LLC ) Docket Numbers LASALLE COUNTY STATION - UNIT 1 and UNIT 2 ) 50-373 and 50-374

SUBJECT:

Request for Amendment to Technical Specifications Excess Flow Check Valve Testing Surveillance Requirement 3.6.1.3.8 and Relief Request RV-12 AFFIDAVIT I affirm that the content of this transmittal is true and correct to the best of my knowledge, information, and belief.

T. W. Sirt`kin Manager - Licensing Mid-West Regional Operating Group Subscribed and sworn to before me, a Notary Public in and

____1____-day of for the State above named, this 2002 optary PQbli SEAL' "OFFICIALA. BYAM "TIMTHY

  • COMMISSION EXPIRES 12/04/05

ATTACHMENT A Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Page 1 of 5 DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED TECHNICAL SPECIFICATIONS CHANGE A.

SUMMARY

OF PROPOSED CHANGE In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company (EGC), LLC, proposes a change to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-1 1 and NPF-1 8.

Specifically, the proposed change modifies TS Surveillance Requirement (SR) 3.6.1.3.8 to reduce the number of excess flow check valves (EFCVs) required to be tested every 24 months. The proposed SR will require that a representative sample of reactor instrumentation line EFCVs actuate to the isolation position on an actual or simulated instrumentation line break signal every 24 months. All reactor instrumentation line EFCVs will be tested at least once every 10 years (nominal). The proposed change implements Technical Specification Task Force Traveler 334 (TSTF-334), "Relaxed Surveillance Frequency for Excess Flow Check Valve Testing," Revision 2.

The proposed change is described in Section E of this Attachment. The marked up and retyped TS pages are shown in Attachment B. Additionally, the retyped TS Bases page, for information only, is shown in Attachment B.

B. DESCRIPTION OF THE CURRENT REQUIREMENTS SR 3.6.1.3.8 requires a demonstration that each EFCV is OPERABLE by verifying that the valve actuates to the isolation position on an actual or simulated instrument line break condition at least once every 24 months.

C. BASES FOR THE CURRENT REQUIREMENTS The EFCVs are used as a means of automatic isolation on all static instrument sensing lines that penetrate the drywell containment and connect to the reactor pressure boundary. SR 3.6.1.3.8 provides assurance that the instrumentation line EFCVs will perform as designed. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant refueling outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power.

D. NEED FOR REVISION OF THE REQUIREMENTS LaSalle County Station, Units 1 and 2, currently test all 99 high pressure EFCVs on each unit, at least once every 24 months. A review of recent LaSalle County Station EFCV operating experience demonstrates that these valves are reliable and that the incidence

ATTACHMENT A Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Page 2 of 5 of test failures is low. A significant cost and radiation dose savings can be achieved by the proposed relaxation of the EFCV testing frequency without any significant reduction in overall plant safety or valve performance.

E. DESCRIPTION OF THE PROPOSED CHANGE The current SR 3.6.1.3.8 is as follows.

"Verify each EFCV actuates to the isolation position on an actual or simulated instrument line break signal."

The proposed SR 3.6.1.3.8 with the change underlined, will be as follows.

"Verify a representative sample of EFCVs actuate to the isolation position on an actual or simulated instrument line break signal."

The representative sample consists of an approximately equal number of EFCVs, such that each EFCV is tested at least once every 10 years (nominal). In addition, the EFCVs in the sample are representative of various plant configurations and operating environments. This ensures that any potential common problems with a specific type or application of EFCV is detected at the earliest possible time.

F. SAFETY ANALYSIS OF THE PROPOSED CHANGE The proposed change implements TSTF-334, Revision 2. TSTF-334 notes that its implementation is only allowed for plants for which General Electric Nuclear Energy Topical Report NEDO-32977-A, "Excess Flow Check Valve Testing Relaxation," is applicable. In addition, an EFCV performance criteria and basis must be developed to ensure that the corrective action program can provide meaningful feedback for appropriate corrective actions.

The NRC approved the generic use of Topical Report NEDO-32977-A if licensees perform the following.

1. Perform a plant-specific radiological dose assessment for an instrument line break.
2. Perform a plant-specific EFCV failure rate analysis.
3. Perform a plant-specific release frequency initiated by an instrument line break.
4. Develop a feedback mechanism and corrective action program to ensure EFCV performance.

The LaSalle County Station Updated Final Safety Analysis Report (UFSAR) Section 6.2.4.1, "Design Basis," identifies that EFCVs are used as a means of automatic isolation on all static instrument sensing lines that penetrate the drywell containment and connect to the reactor pressure boundary. The EFCV is located downstream of the root

ATTACHMENT A Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Page 3 of 5 valve and as close as practical to the outside surface of the drywell containment. The valve is automatically closed to restrict flow in case of a sensing line break outside the drywell containment.

The following EFCV design assumptions used in Topical Report NEDO-32977-A were also verified as being applicable to LaSalle County Station.

  • The single instrument line break frequency of 3.52E-05/year.
  • The instrument lines contain / inch orifices in series with each EFCV.
  • The instrument line break event analysis in the LaSalle County Station UFSAR Section 15.6.2 does not credit closure of EFCVs.

The LaSalle County Station radiological dose assessment for an instrument line break is documented in the LaSalle County Station UFSAR Table 15.6-4, "Instrument Line Break Radiological Effects." Table 15.6-4 identifies that at the Exclusion Area Boundary the estimated Whole Body Dose is 1.8E-07 rem and the estimated Thyroid Dose is 5.5E-05 rem. The Low Population Zone Whole Body Dose is estimated to be 4.OE-07 rem and the Thyroid Dose is estimated to be 2.1E-04 rem. These estimated doses are significantly below the regulatory dose limits listed in 10CFR1 00, "Reactor Site Criteria."

The proposed change does not change the assumptions or the estimated doses associated with a LaSalle County Station instrument line break and is consistent with Topical Report NEDO-32977-A.

A plant specific EFCV failure rate analysis was performed which included a review of the work history on all 198 reactor instrumentation line EFCVs at LaSalle County Station, Units 1 and 2. The review identified that during 2574 valve-years of EFCV operation, EFCVs failed to close 35 times during the performance of SR 3.6.1.3.8; 20 times on Unit 1, and 15 times on Unit 2. This results in a Best Estimate failure rate (i.e., failures/year) of 0.0136/year. This failure rate is greater than the Best Estimate failure rate used in Topical Report NEDO-32977-A of 1.01 E-07/hour or 8.85E-04/year. The LaSalle County Station EFCV Best Estimate failure rate of 0.0136/year corresponds to an Upper Limit Failure Rate of 0.018/year, or 2.05E-06/hour. This upper limit failure rate is greater than the composite upper limit failure rate used in the Topical Report of 1.67E-07/hour.

A review of the information associated with the 35 EFCV failures revealed the following.

Insufficient investigative work was performed or documented to assess the reason for most of the 35 EFCV failures. However, the assessment did indicate that a majority of the failures were related to inadequate test methods rather than actual valve failures. For example, there are eight Residual Heat Removal System (RHR)

EFCVs associated with shutdown cooling out of a total EFCV population of 198.

These EFCVs accounted for 17 of the 35 EFCV failures (i.e., approximately 48%).

The available information indicates that the failures of the RHR EFCVs were the result of the failure to establish adequate test conditions which resulted in inadequate flow/pressure drop across the check valve due to a large length of tubing downstream of these EFCVs.

ATTACHMENT A Proposed Technical Specifications Change LaSalle County Station, Units I and 2 Page 4 of 5

" Improvements have been made to reduce the impact of testing methods on the EFCV testing. These include:

" Improved test prerequisites to ensure test conditions adequately represent the specified conditions.

"* Installation of test taps to allow for better control of test pressures/configuration and to permit the use of external pressure sources (e.g., hydro rig) to allow enhanced control of the system test pressure.

" The use of reduced weight springs, where practical, within the EFCVs that lowers the flow/differential pressure at which the valves close.

" Many of the above enhancements have been implemented in recent years.

These efforts have reduced the failure rate of the EFCVs. Prior to 1996, 30 EFCVs failed the surveillance test, however, since 1996 only 5 EFCVs have failed the surveillance test. Additionally, in the last two refueling outages only one failure has been identified per outage. This corresponds to approximately a 1% failure rate (i.e., 1 of 99 EFCVs). These recent results are more consistent with the results presented in the NEDO document.

Based on the above, LaSalle County Station has had a historical EFCV failure rate that is above the industry average. However, due to changes in testing methods, recent results are more consistent with the industry average and the results presented in the NEDO document.

A LaSalle County Station release frequency due to a break in an instrument line concurrent with an EFCV failure to close was performed using the methodology contained in Topical Report NEDO-32977-A. The current LaSalle County Station release frequency associated with the current SR 3.6.1.3.8 is 1.25E-04/year. The proposed change to SR 3.6.1.3.8 will increase the release frequency to 6.26E-04/year, resulting in an increase in release frequency of 5.01 E-04/year. These release frequencies are higher than the industry average release frequency due to the relatively higher upper limit failure rate, which is an input to the release frequency analysis.

TSTF-334 identifies that the failure of EFCVs must be evaluated in the corrective action program with appropriate corrective actions. LaSalle County Station will evaluate EFCV failures and take appropriate corrective actions as required by its corrective action program. Additionally, LaSalle County Station will perform the following sample expansion under its corrective action program if additional SR 3.6.1.3.8 failures are discovered under the proposed change to SR 3.6.1.3.8. A SR 3.6.1.3.8 failure is defined as a failure of the EFCV to check flow during the as-found test.

LaSalle County Station will group the EFCVs in accordance with the Inservice Testing (IST) Program's condition monitoring program. This approach will require that a continuing review of the failures be performed to assess performance trends. The initial plan is to group the EFCVs into three to five groups. Each refueling outage approximately 20% of each group will be tested.

ATTACHMENT A Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Page 5 of 5 This approach will ensure that a representative sample of all LaSalle's EFCVs are tested each refueling outage.

If any one EFCV in a group fails to check flow as the result of either test methodology or valve failure, LaSalle County Station will test another representative sample (i.e., approximately 20%) of EFCVs in that group. If one of the additional EFCV fails to check flow, LaSalle County Station will test all EFCVs within that group prior to restart. Any valve that fails to check flow will be tested again in the next refueling outage, in addition to the normal required test population sample. Initially, all RHR EFCVs discussed above will be tested in the next refueling outage due to their past performance even though recent testing performance has significantly improved.

Based on the above, the proposed change for LaSalle County Station, Units 1 and 2, meets the overall requirements to implement TSTF-334, Revision 2.

G. IMPACT ON PREVIOUS SUBMITTALS The proposed change has no impact on any outstanding submittal.

H. SCHEDULE REQUIREMENTS Approval of the proposed change is requested by December 2, 2002 to support the next refueling outage of LaSalle County Station, Unit 2, currently scheduled for January 2003.

ATTACHMENT B Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 MARKED-UP AND RETYPED TECHNICAL SPECIFICATION PAGES FOR THE PROPOSED CHANGE

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Verify the isolation time of each MSIV is In accordance 2 3 seconds and

  • 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to 24 months the isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify 24 months

)reDreenta- ive sampen CVs ctuateto the lsoTai-on position on an actual or simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP STAGGERED TEST System. BASIS SR 3.6.1.3.10 Verify leakage rate through any one main In accordance steam line is 5 100 scfh and through all with the four main steam lines is < 400 scfh when Primary tested at Ž 25.0 psig. Containment Leakage Rate Testing Program SR 3.6.1.3.11 Verify combined leakage rate through In accordance hydrostatically tested lines that with the penetrate the primary containment is Primary within limits. Containment Leakage Rate Testing Program LaSalle I and 2 3.6.1.3-8 Amendment No. 147/133

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Verify the isolation time of each MSIV is In accordance

>3 seconds and < 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to 24 months the isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify a representative sample of EFCVs 24 months actuate to the isolation position on an actual or simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP STAGGERED TEST System. BASIS SR 3.6.1.3.10 Verify leakage rate through any one main In accordance steam line is

  • 100 scfh and through all with the four main steam lines is < 400 scfh when Primary tested at Ž 25.0 psig. Containment Leakage Rate Testing Program SR 3.6.1.3.11 Verify combined leakage rate through In accordance hydrostatically tested lines that with the penetrate the primary containment is Primary within limits. Containment Leakage Rate Testing Program LaSalle 1 and 2 3.6.1.3-8 Amendment No.

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.8 REQUIREMENTS (continued) This SR requires a demonstration that a representative sample of EFCVs are OPERABLE by verifying that the valves actuate to the isolation position on an actual or simulated instrument line break condition. The representative sample consists of an approximately equal number of EFCVs, such that each EFCV is tested at least once every 10 years (nominal). In addition, the EFCVs in the sample are representative of various plant configurations, models, sizes, and operating environments. This ensures that any potential common problems with a specific type or application of EFCV is detected at the earliest possible time. This SR provides assurance that the instrumentation line EFCVs will perform as designed. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. The nominal 10 year interval is based on performance testing as discussed in Topical Report NEDO 32977-A, "Excess Flow Check Valve Testing Relaxation."

Furthermore, any EFCV failures will be evaluated to determine if additional testing in that test interval is warranted to ensure overall reliability is maintained.

Operating experience has demonstrated that these components are highly reliable and that failures to isolate are very infrequent. Therefore, testing a representative sample was concluded to be acceptable from a reliability standpoint.

SR 3.6.1.3.9 The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. Other administrative controls, such as those that limit the shelf life and operating life, as applicable, of the explosive charges, must be followed. The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative LaSalle I and 2 B 3.6.1.3-14 Revi si on 0

ATTACHMENT C Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Page 1 of 3 INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION Exelon Generation Company (EGC), LLC, has evaluated the proposed change to the Technical Specifications (TS) for LaSalle County Station, Unit 1 and Unit 2, and has determined that the proposed change does not involve a significant hazards consideration and is providing the following information to support a finding of no significant hazards consideration. According to 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

Involve a significant increase in the probability or consequences of an accident previously evaluated; Create the possibility of a new or different kind of accident from any previously evaluated; or Involve a significant reduction in a margin of safety.

The proposed change to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-1 1 and NPF-1 8 would modify TS Surveillance Requirement (SR) 3.6.1.3.8 to reduce the number of excess flow check valves (EFCVs) required to be tested every 24 months. The proposed SR will require that a representative sample of reactor instrumentation line EFCVs actuate to the isolation position on an actual or simulated instrumentation line break signal every 24 months. All reactor instrumentation line EFCVs will be tested at least once every 10 years (nominal). The proposed change implements Technical Specification Task Force Traveler 334 (TSTF-334), "Relaxed Surveillance Frequency for Excess Flow Check Valve Testing," Revision 2.

The information supporting the determination that the criteria set forth in 10 CFR 50.92 are met for the proposed change is provided below.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change to LaSalle County Station, Unit 1 and Unit 2 Technical Specifications (TS) modifies TS Surveillance Requirement (SR) 3.6.1.3.8 to reduce the number of excess flow check valves (EFCVs) required to be tested every 24 months. The proposed SR will require that a representative sample of reactor instrumentation line EFCVs actuate to the isolation position on an actual or simulated instrumentation line break signal every 24 months. All reactor instrumentation line EFCVs will be tested at least once every 10 years (nominal).

The performance of EFCV surveillance testing is not a precursor to any accident previously evaluated and is not related to the frequency of instrument line

ATTACHMENT C Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Page 2 of 3 failures. Thus, the proposed change to modify the test frequency associated with EFCV surveillance does not have any effect on the probability of an accident previously evaluated.

The performance of the EFCV surveillance testing does provide assurance that the EFCV will perform as designed. The LaSalle County Station radiological dose assessment for an instrument line break is documented in the LaSalle County Station UFSAR Table 15.6-4, "Instrument Line Break Radiological Effects." The assessment does not credit performance of the EFCV to limit instrument line flows during an assumed break. These estimated doses are significantly below the regulatory dose limits listed in 10CFR1 00, "Reactor Site Criteria." The proposed change does not change the assumptions or the estimated doses associated with a LaSalle County Station instrument line break Thus, the radiological consequences of any accident previously evaluated are not increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change modifies TS SR 3.6.1.3.8 to reduce the number of excess flow check valves (EFCVs) required to be tested every 24 months while requiring all EFCVs to be tested at least once every 10 years (nominal). The proposed change does not affect the performance of any LaSalle County Station structure, system, or component credited with mitigating any accident previously evaluated.

The proposed change to modify the surveillance will not affect the control parameters governing unit operation or the response of plant equipment to transient conditions. The proposed change does not introduce any new equipment, modes of system operation or failure mechanisms.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Does the change involve a significant reduction in a margin of safety?

The proposed change for LaSalle County Station, Units 1 and 2, implements Technical Specification Task Force Traveler 334 (TSTF-334), "Relaxed Surveillance Frequency for Excess Flow Check Valve Testing," Revision 2.

TSTF-334 notes that its implementation is only allowed for plants for which General Electric Nuclear Energy Topical Report NEDO-32977-A, "Excess Flow Check Valve Testing Relaxation," is applicable. In addition, an EFCV performance criteria and basis must be developed to ensure that the corrective

ATTACHMENT C Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Page 3 of 3 action program can provide meaningful feedback for appropriate corrective actions.

LaSalle County Station, in accordance with Topical Report NEDO-32977-A, has performed a plant-specific radiological dose assessment for an instrument line break, EFCV failure rate analysis, release frequency initiated by an instrument line break analysis and has proposed a corrective action program to ensure continued EFCV performance. The result of the assessment and analyses meets the overall requirements to allow implementation TSTF-334, Revision 2 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Therefore, based upon the above, it is concluded that the proposed change involves no significant hazards consideration.

ATTACHMENT D Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT Exelon Generation Company (EGC), LLC, has evaluated the proposed change against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21, "Criteria for and identification of licensing and regulatory actions requiring environmental assessments." EGC has determined that the proposed change meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9) and as such, has determined that no irreversible consequences exist in accordance with 10 CFR 50.92(b). This determination is based on the fact that the change is being proposed as an amendment to a license issued pursuant to 10 CFR 50, that the proposed change is to a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or that a change is proposed to an inspection or a surveillance requirement, and the amendment meets the following specific criteria.

(i) The proposed change involves no significant hazards consideration.

As demonstrated in Attachment C, the proposed change involves no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed change does not affect the types or amount of any effluent that may be released offsite. Therefore, there will be no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiation levels within the plant.

Therefore, there will be no significant increase in individual or cumulative occupational radiation exposure resulting from the proposed change.

ATTACHMENT E Proposed Technical Specifications Change LaSalle County Station, Units 1 and 2 Valve Relief Request - RV-12

Valve Relief Request - RV-12 Rev. 0 Page 1 of 7 Component Identification Code Class: 2

Reference:

American Society of Mechanical Engineers (ASME) I American National Standards Institute (ANSI), Operation and Maintenance of Nuclear Power Plants, OMa-1996, Subsection ISTC.

Examination Category: AC

==

Description:==

Excess Flow Check Valves (EFCVs) which connect to the reactor coolant pressure boundary Affected Components: See attached Table.

Code Requirements The applicable Code of record for LaSalle County Station is ASME OMa-1988 Part 10, and check valve portions of ASME OMa-1 996, Subsection Inservice Testing Code (ISTC), and Appendix II, "Check Valve Condition Monitoring Program."

OMa-1996, Section ISTC 4.1, "Valve Position Verification", and Table ISTC 3.6-1, "Inservice Test Requirements" require that Category C valves with remote position indication shall be observed locally at least once every two years to verify that valve operation is accurately indicated.

Basis for Relief Pursuant to 10 CFR 50.55a(a)(3), relief is requested on the basis that the proposed alternative provides an acceptable level of quality and safety.

Previously, all EFCVs were closure tested and Position Indication Tested (PIT) every refuel cycle to satisfy Inservice Testing requirements set forth by the ASME Code and LaSalle County Station Technical Specifications (TS). TS Surveillance Requirement (SR) 3.6.1.3.8 required verification that each EFCV actuated to the isolation position on an actual or simulated instrument line break signal on a 24 month frequency.

Using the guidance and justification contained in TS Task Force Traveler 334 (TSTF 334), "Relaxed Surveillance Frequency for Excess Flow Check Valve Testing," Revision 2 and General Electric Topical Report NEDO-32977-A, "Excess Flow Check Valve Testing Relaxation," the frequency for exercise testing is proposed to be relaxed. The detailed justification for this proposed testing relaxation is contained in Attachment A, Section F, "Safety Analysis of the Proposed Change," of the licensing amendment submittal. The proposed requirements will be to test a representative sample of EFCVs every 24 months (nominal). All EFCVs will be tested at least once every 10 years (nominal).

Valve Relief Request - RV-12 Rev. 0 Page 2 of 7 Since position indication testing is performed in conjunction with the exercise test, relief is requested to perform position indication testing on this same frequency, instead of the Code required frequency of at least once every two years. Relief is not required to extend the exercise frequency, since exercise testing will be controlled using Appendix II, Check Valve Condition Monitoring Program, which allows the Owner to establish the test frequency.

Alternative Test OMa-1 996, Section ISTC 4.1 and Table ISTC 3.6-1 require that Category C valves with remote position indication shall be observed locally at least once every two years to verify that valve operation is accurately indicated. In lieu of this requirement, this submittal requests that a representative sample of EFCV be tested every 24 months (nominal) when practicable. All EFCVs will be tested at least once every 10 years (nominal). At LaSalle County Station, position indication testing is performed concurrently with exercise testing. The remote position indication will be verified at the same frequency as the exercise test, which will be performed at a frequency prescribed in TS SR 3.6.1.3.8.

Applicable Time Period This alternative is requested for the remaining duration of the Inservice Testing Program 2nd ten-year interval for LaSalle County Station, Units 1 and 2.

Valve Relief Request - RV-12 Rev. 0 Page 3 of 7 Affected Components Table EPN NUMBER DESCRIPTION 1B21-F325A A MS Line Hi Flow D/P Inst 1E31-NO08A/NO08B Hi Excess Flow Check Valve (EFCV) 1B21-F325B B MS Hi Line Flow D/P Inst 1E31-NO09AINO09B Hi EFCV 1B21-F325C C MS Line Hi Flow D/P Sw 1E31-NO1OAINO1OB Hi EFCV 1B21-F325D D MS Line Hi Flow D/P Sw 1E31-NO11A/NO11B Hi EFCV 1B21-F326A A MS Line Hi Flow D/P Inst 1E31-NO08A/NO08B Lo EFCV 1B21-F326B B MS Hi Line Flow D/P Inst 1E31-NO09A/NO09B Lo EFCV 1B21-F326C C MS Line Hi Flow D/P Sw 1E31-NO1OA/NO1OB Lo EFCV 1B21-F326D D MS Line Hi Flow D/P Sw 1E31-NO11A/NO1IB Lo EFVC 1B21 -F327A A MS Line Hi Flow D/P Sw 1E31-NO08D/NO08C Lo EFCV 1B21-F327B B MS Line Hi Flow D/P Sw 1E31-NO09D/NO09C Lo EFCV 1B21-F327C C MS Line Hi Flow D/P Inst 1E31-NO10C/NO10D Lo EFCV 1B21-F327D D MS Line Hi Flow D/P Inst 1E31-NO11C/NO11D Lo EFCV 1B21-F328A A MS Line Hi Flow D/P Sw 1E31-NO08D/NO08C Hi EFCV 1B21-F328B B MS Line Hi Flow D/P Sw 1E31-NO09D/NO09C Hi EFCV 1B21-F328C C MS Line Hi Flow D/P Inst 1E31-NO1OC/NO10D Hi EFCV 1B21-F328D D MS Line Hi Flow D/P Inst 1E31-NO11C/NO11D Hi EFCV 1B21-F344 Jet Pump Pressure EFCV 1B21-F346 RPV Bottom Head Drain Flow EFCV 1B21-F348 RPV/ HPCS dP EFCV 1B21-F350 Core dP EFCV 1B21-F353 RPV Level and Pressure EFCV 1B21-F355 RPV Level and Pressure EFCV 1B21-F357 RPV Level and Pressure EFCV 1B21-F359 RPV Level and Pressure EFCV 1B21-F361 RPV Level and Pressure EFCV 1B21-F363 RPV Level and Pressure EFCV 1B21-F370 RPV Level and Pressure EFCV 1B21-F372 RPV Level and Pressure EFCV 1B21-F374 RPV Level and Pressure EFCV 1B21-F376 RPV Level and Pressure EFCV 1B21-F378 RPV Level and Pressure EFCV 1B21-F413A RCIC Steam Supply Flow Instr EFCV 1B21-F413B RCIC Steam Supply Flow Instr EFCV 1B21-F415A RCIC Steam Supply Flow Instr EFCV 1B21-F415B RCIC Steam Supply Flow Instr EFCV 1B21-F437 Jet Pump Flow EFCV 1B21-F439 Jet Pump Flow EFCV 1B21-F441 Jet Pump Flow EFCV 1B21-F443 Jet Pump Flow EFCV 1B21-F445A Jet Pump Flow EFCV 1B21-F445B Jet Pump Flow EFCV 1B21-F447 Jet Pump Flow EFCV 1B21-F449 Jet Pump Flow EFCV 1B21-F451 Jet Pump Flow EFCV 1B21-F453 Jet Pump Flow EFCV 1B21-F455A Jet Pump Flow EFCV 1B21-F455B Jet Pump Flow EFCV

Valve Relief Request - RV-12 Rev. 0 Page 4 of 7 EPN NUMBER DESCRIPTION 1B21-F457 Jet Pump Flow EFCV 1B21-F459 Jet Pump Flow EFCV 1B21-F461 Jet Pump Flow EFCV 1B21-F463 Jet Pump Flow EFCV 1B21-F465A Jet Pump Flow EFCV 1B21-F465B Jet Pump Flow EFCV 1B21-F467 Jet Pump Flow EFCV 1B21-F469 Jet Pump Flow EFCV 1B21-F471 Jet Pump Flow EFCV 1B21-F473 Jet Pump Flow EFCV 1B21-F475A Jet Pump Flow EFCV 1B21-F475B Jet Pump Flow EFCV 1B21-F570 RPV Level and Pressure EFCV 1B21-F571 Drywell Pressure EFCV 1B33-F301A Recirc Pump Suction Pressure EFCV 1 B33-F301 B Recirc Pump Suction Pressure EFCV 1B33-F305A Recirc Pump Flow EFCV 1B33-F305B Recirc Pump Flow EFCV 1B33-F305C Recirc Pump Flow EFCV 1B33-F305D Recirc Pump Flow EFCV 1B33-F307A Recirc Pump Flow EFCV 1B33-F307B Recirc Pump Flow EFCV 1B33-F307C Recirc Pump Flow EFCV 1B33-F307D Recirc Pump Flow EFCV 1B33-F311A Recirc Pump Flow EFCV 1B33-F311 B Recirc Pump Flow EFCV 1B33-F311C Recirc Pump Flow EFCV 1B33-F31 1D Recirc Pump Flow EFCV 1B33-F313A Recirc Pump Flow EFCV 1B33-F313B Recirc Pump Flow EFCV 1B33-F313C Recirc Pump Flow EFCV 1B33-F313D Recirc Pump Flow EFCV 1B33-F315A Recirc Pump dP EFCV 1B33-F315B Recirc Pump dP EFCV 1B33-F315C Recirc Pump dP EFCV 1B33-F315D Recirc Pump dP EFCV 1B33-F317A Recirc Pump Seal Pressure EFCV 1B33-F317B Recirc Pump Seal Pressure EFCV 1B33-F319A Recirc Pump Seal Pressure EFCV 1B33-F319B Recirc Pump Seal Pressure EFCV 1E12-F315 A RHR LPCI Inj Line Integrity EFCV 1E12-F317 B RHR Inj Line Integrity EFCV 1E12-F319 C RHR Inj Line Integrity EFCV 1E12-F359A RHR SDC Suct Hdr DIP Sw 1E31-NO12AA/AB Lo Side EFCV 1E12-F359B RHR SDC Suct Hdr DIP Sw 1E31-N012AA/AB Hi Side EFCV 1E12-F360A RHR SDC Suct Hdr DIP Sw 1E31-NO12BA/BB Hi Side EFCV 1E12-F360B RHR SDC Suct Hdr D/P Sw 1E31-NO12BA/BB Lo Side EFCV 1E21-F304 LPCS/RHR Integrity EFCV 1 E22-F304 HPCS/Rx Vessel DIP Sw 1E22-N009 EFCV 1G33-F309 RX Vessel Drain Flow Instr EFCV

Valve Relief Request - RV-12 Rev. 0 Page 5 of 7 EPN NUMBER DESCRIPTION 1G33-F312A RWCU Flow Instr EFCV 1G33-F312B RWCU Flow Instr EFCV 2B21-F325A A MS Line Hi Flow D/P Inst 2E31-NO08A/NO08B Hi EFCV 2B21-F325B B MS Hi Line Flow D/P Inst 2E31-NO09A/NO09B Hi EFCV 2B21-F325C C MS Line Hi Flow D/P Sw 2E31-N010A/N010B Hi EFCV 2B21-F325D D MS Line Hi Flow D/P Sw 2E31-NO11A/NO11B Hi EFCV 2B21-F326A A MS Line Hi Flow D/P Inst 2E31-NO08A/NO08B Lo EFCV 2B21-F326B B MS Hi Line Flow D/P Inst 2E31-NO09A/NO09B Lo EFCV 2B21-F326C C MS Line Hi Flow D/P Sw 2E31-NO1OA/NO10B Lo EFCV 2B21-F326D D MS Line Hi Flow D/P Sw 2E31-NO1 1A/NO1 1 B Lo EFCV 2B21-F327A A MS Line Hi Flow D/P Sw 2E31-NO08D/NO08C Lo EFCV 2B21-F327B B MS Line Hi Flow D/P Sw 2E31-NO09D/NO09C Lo EFCV 2B21-F327C C MS Line Hi Flow D/P Inst 2E31-N010C/N010D Lo EFCV 2B21-F327D D MS Line Hi Flow D/P Inst 2E31-NO11C/NO11D Lo EFCV 2B21-F328A A MS Line Hi Flow D/P Sw 2E31-NO08D/NO08C Hi EFCV 2B21-F328B B MS Line Hi Flow D/P Sw 2E31-NO09D/NO09C Hi EFCV 2B21-F328C C MS Line Hi Flow D/P Inst 2E31-N010C/N010D Hi EFCV 2B21-F328D D MS Line Hi Flow D/P Inst 2E31-NO11C/NO11D Hi EFCV 2B21-F344 Jet Pump Pressure EFCV 2B21-F346 RPV Bottom Head Drain Flow EFCV 2B21-F348 RPV / HPCS dP EFCV 2B21-F350 Core dP EFCV 2B21-F353 RPV Level and Pressure EFCV 2B21-F355 RPV Level and Pressure EFCV 2B21-F357 RPV Level and Pressure EFCV 2B21-F359 RPV Level and Pressure EFCV 2B21-F361 RPV Level and Pressure EFCV 2B21-F363 RPV Level and Pressure EFCV 2B21-F370 RPV Level and Pressure EFCV 2B21-F372 RPV Level and Pressure EFCV 2B21-F374 RPV Level and Pressure EFCV 2B21-F376 RPV Level and Pressure EFCV 2B21-F378 RPV Level and Pressure EFCV 2B21-F413A RCIC Steam Supply Flow Instr EFCV 2B21-F413B RCIC Steam Supply Flow Instr EFCV 2B21-F415A RCIC Steam Supply Flow Instr EFCV 2B21-F415B RCIC Steam Supply Flow Instr EFCV 2B21-F437 Jet Pump Flow EFCV 2B21-F439 Jet Pump Flow EFCV 2B21-F441 Jet Pump Flow EFCV 2B21-F443 Jet Pump Flow EFCV 2B21-F445A Jet Pump Flow EFCV 2B21-F445B Jet Pump Flow EFCV 2B21-F447 Jet Pump Flow EFCV 2B21-F449 Jet Pump Flow EFCV 2B21-F451 Jet Pump Flow EFCV 2B21-F453 Jet Pump Flow EFCV 2B21-F455A Jet Pump Flow EFCV 2B21-F455B Jet Pump Flow EFCV 2B21-F457 Jet Pump Flow EFCV

Valve Relief Request - RV-12 Rev. 0 Page 6 of 7 EPN NUMBER DESCRIPTION 2B21-F459 Jet Pump Flow EFCV 2B21-F461 Jet Pump Flow EFCV 2B21-F463 Jet Pump Flow EFCV 2B21-F465A Jet Pum Flow EFCV 2B21-F465B Jet Pump Flow EFCV 2B21-F467 Jet Pump Flow EFCV 2B21-F469 Jet Pump Flow EFCV 2B21-F471 Jet Pump Flow EFCV 2_B21-F473 Jet Pump Flow EFCV 2B21-F475A Jet Pump Flow EFCV 2B21-F475B Jet Pump Flow EFCV 2B21-F570 RPV Level and Pressure EFCV 2B21-F571 RPV Level EFCV 2B33-F301A Recirc Pump Suction Pressure EFCV 2B33-F301 B Recirc Pump Suction Pressure EFCV 2B33-F305A Recirc Pump Flow EFCV 2B33-F305B Recirc Pump Flow EFCV 2B33-F305C Recirc Pump Flow EFCV 2B33-F305D Recirc Pump Flow EFCV 2B33-F307A Recirc Pump Flow EFCV 2B33-F307B Recirc Pump Flow EFCV 2B33-F307C Recirc Pump Flow EFCV 2B33-F307D Recirc Pump Flow EFCV 2B33-F311A Recirc Pump Flow EFCV 2B33-F31 1B Recirc Pump Flow EFCV 2B33-F311C Recirc Pump Flow EFCV 2B33-F311D Recirc Pump Flow EFCV 2B33-F313A Recirc Pump Flow EFCV 2B33-F313B Recirc Pump Flow EFCV 2B33-F313C Recirc Pump Flow EFCV 2B33-F313D Recirc Pump Flow EFCV 2B33-F315A Recirc Pump dP EFCV 2B33-F315B Recirc Pump dP EFCV 2B33-F315C Recirc Pump dP EFCV 2B33-F315D Recirc Pump dP EFCV 2B33-F317A Recirc Pump Seal Pressure EFCV 2B33-F317B Recirc Pump Seal Pressure EFCV 2B33-F319A Recirc Pump Seal Pressure EFCV 2B33-F319B Recirc Pump Seal Pressure EFCV 2E12-F315 A RHR LPCI Inj Line Integrity EFCV 2E12-F317 B RHR Inj Line Integrity EFCV 2E12-F319 C RHR Inj Line Integrity EFCV 2E12-F359A RHR SDC Suct Hdr DIP Sw 2E31-NO12AA/AB Lo Side EFCV 2E12-F359B RHR SDC Suct Hdr DIP Sw 2E31-NO12AA/AB Hi Side EFCV 2E12-F360A RHR SDC Suct Hdr D/P Sw 2E31-NO12BA/BB Lo Side EFCV 2E12-F360B RHR SDC Suct Hdr DIP Sw 2E31-NO12BA/BB Hi Side EFCV 2E21-F304 LPCS/RHR Integrity EFCV 2E22-F304 HPCS/Rx Vessel D/P Sw 1E22-N009 EFCV 2G33-F309 RX Vessel Drain Flow Instr EFCV 2G33-F312A RWCU Flow Instr EFCV

Valve Relief Request - RV-12 Rev. 0 Page 7 of 7 I EPN NUMBER F DESCRIPTION 2G33-F312B RWCU Flow Instr EFCV

Retrieved from "https://kanterella.com/w/index.php?title=RS-02-076,_Request_for_Amendment_to_Technical_Specifications,_Excess_Flow_Check_Valve_Testing_Surveillance_Requirement_3.6.1.3.8_%26_Relief_Request_RV-12&oldid=2701332"