RS-06-154, Request for Amendment to Technical Specifications Section 5.5.7, Inservice Testing Program.

Request for Amendment to Technical Specifications Section 5.5.7, Inservice Testing Program.

ML063210361
Person / Time
Site:	LaSalle
Issue date:	11/17/2006
From:	Benyak D Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-06-154
Download: ML063210361 (25)

Text

Exelom Exelon Generation 4300 Winfield Road wwwexeloncorp.co m Nuclear Warrenville, IL 6055 RS-06-154 10 CFR 50.90 November 17, 2006 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 Section 5 .5 .7, "Inservice Testing Program"

References:

1 . TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a,"

dated December 19, 2005

2. TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0 .2 Application to Frequencies of 2 Years or Less," dated July 12, 2006 3 . Letter from T. H . Boyce (U .S . NRC) to members of the Technical Specification Task Force, dated December 6, 2005

4. Letter from T. J. Kobetz (U .S. NRC) to members of the Technical Specification Task Force, dated October 4, 2006 In accordance with 10 CFR 50 .90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC, (EGC), requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License Nos . NPF-11 and NPF-18. Specifically, the proposed changes will replace references to Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) in TS 5.5.7, "Inservice Testing Program ." These proposed changes are consistent with the implementation of the LSCS, Units 1 and 2 Third 10-Year I ST Program in accordance with the requirements of 10 CFR 50.55a, "Codes and standards," paragraph (f), "Inservice testing requirements ." The Third 10-Year Interval for LSCS Units 1 and 2 is scheduled to start on October 12, 2007. In addition to the replacement of the references, EGC is also adding provisions in TS 5.5 .7, item b, to only apply Surveillance Requirement (SR) 3.0.2 to those Inservice Testing Frequencies of two years or less .

These proposed changes are based on Technical Specification Task Force (TSTF) 479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50 .55a," (i .e., Reference 1) as modified by TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3 .0.2 Application to Frequencies of 2 Years of Less" (i .e., Reference 2) and approved by the NRC in References 3 and 4 .

November 17, 2006 U . S. Nuclear Regulatory Commission Page 2 We request approval of the proposed changes by October 1, 2007 with the amendment being implemented within 30 days of issuance .

The attached amendment request is subdivided as shown below.

Attachment 1 provides an evaluation of the proposed changes.

Attachment 2 includes a marked-up copy of the applicable TS pages with the proposed changes indicated .

Attachment 3 includes the revised TS pages with the proposed changes incorporated .

Attachment 4 includes the revised TS Bases pages with the proposed changes indicated .

Note that the TS Bases pages are provided for information only and do not require prior NRC approval .

The proposed changes have been reviewed by the LSCS Plant Operations Review Committee and approved by the Chairman of the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

In accordance with 10 CFR 50 .91, "Notice for public comment; State consultation," EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official .

There are no regulatory commitments contained in this letter . Should you have any questions concerning this letter, please contact Ms . Alison Mackellar at (630) 657-2817 .

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of November 2006.

Respectfully, L

Darin M. Benyak Manager, Licensing and Regulatory Affairs  : Evaluation of the Proposed Changes : Mark-up of Proposed Technical Specifications Page Changes : Typed Page for Technical Specifications Changes : Mark-up of Proposed Technical Specifications Bases Page Changes

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES INDEX 1 .0 DESCRIPTION

2.0 PROPOSED CHANGE

S

4.0 TECHNICAL ANALYSIS

5 .0 REGULATORY ANALYSIS 5 .1 No Significant Hazards Consideration 5 .2 Applicable Regulatory Requirements / Criteria 6 .0 ENVIRONMENTAL EVALUATION 7 .0 REFERENCES

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES 1 .0 DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC, (EGC), requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-11 and NPF-18. Specifically, the proposed changes will replace references to Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) in TS 5 .5.7, "Inservice Testing Program." These proposed changes are consistent with the implementation of the LSCS, Units 1 and 2 Third 10-Year IST Program in accordance with the requirements of 10 CFR 50.55a, "Codes and standards," paragraph (f), "Inservice testing requirements ." The Third 10-Year Interval for LSCS Units 1 and 2 is scheduled to start on October 12, 2007. In addition to the replacement of the references, EGC is also adding provisions in TS 5.5.7, item b, to only apply Surveillance Requirement (SR) 3.0.2 to those Inservice Testing Frequencies of two years or less .

These proposed changes are based on Technical Specification Task Force (TSTF) 479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a," (i.e ., Reference 1) as modified by TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years of Less" (i .e., Reference 2) and approved by the NRC in References 3 and 4.

Note that EGC recently synchronized the 10-Year I ST intervals between Units 1 and 2 to assure that the IST Program implemented at LSCS uses the same Code Edition and Addenda for the next and successive intervals . The Second 10-Year Interval for Unit 1 started on November 23, 1994 and is scheduled to end on October 11, 2007. The Second 10-Year Interval for Unit 2 started on October 17, 1994 and is also scheduled to end on October 11, 2007 . Reference 5 documented the synchronization of the 10-Year IST intervals between LSCS Units 1 and 2.

2.0 PROPOSED CHANGE

S EGC proposes to revise the existing wording of TS 5.5 .7 to replace references to the ASME Boiler and Pressure Vessel Code Section XI with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) . The revised TS 5.5.7, with changes italicized, will be as follows.

a . Testing Frequencies applicable to the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda are as follows :

ASME OM Code and applicable Addenda terminology for Required Frequencies inservice testing for performing inservice act ivi ties_. testinq activities Weekly At least once per 7 days Monthly At least once per 31 days Page 2 of 8

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days Every 48 months At least once per 1461 days b . The provisions of SR 3 .0 .2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities ;

c. The provisions of SR 3 .0 .3 are applicable to inservice testing activities ; and

d. Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS .

The marked-up and retyped TS pages are contained in Attachments 2 and 3.

TS Bases Sections B 3.4.4, B 3.4.6, B 3.5 .1, B 3.6.2.3, B 3.6.2.4, and B 3.8 .1 will also be revised to replace the references to Sections XI of the ASME Boiler and Pressure Vessel Code with a reference to the ASME OM Code for Inservice Testing.

3 .0 BACKGROUND In 1990, the ASME published the initial edition of the ASME OM Code that provided rules for inservice testing of pumps and valves . The ASME OM Code replaced Section XI of the Boiler and Pressure Vessel Code for inservice testing of pumps and valves .

The 1995 edition with the 1996 Addenda of the ASME OM Code (i.e ., Reference 7) was incorporated by reference into 10 CFR 50.55a paragraph (b) on September 22, 1999 (i.e., Reference 6). Since 10 CFR 50.55a paragraph (f), "Inservice testing requirements," section (4)(ii) requires that inservice testing during successive 120-month intervals comply with the requirements of the latest edition and addenda of the Code incorporated by reference into 10 CFR 50.55a(b) 12 months before the start of the 120-month interval, therefore TS 5 .5.7 must be revised to reference the ASME OM Code.

The 2001 edition with the 2003 Addenda of the ASME OM Code was approved for use by the NRC and was incorporated by reference into 10 CFR 50.55a paragraph (b) on October 1, 2004 (i.e., Reference 8). The 2001 edition with the 2003 Addenda of the ASME OM Code (i.e., Reference 9) is the ASME Code of record for the upcoming Third 10-Year IST Interval Program for LSCS Units 1 and 2.

These proposed changes are consistent with TSTF 479-A, Revision 0, (i .e ., Reference

1) that was approved by the NRC in Reference 3 and incorporated into NUREG-1433, Page 3 of 8

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES "Standard Technical Specifications, General Electrical Plants BWR/4," Revision 3.1 and NUREG-1434, "Standard Technical Specifications, General Electrical Plants BWR/6,"

Revision 3.1 .

On February 23, 2006 at a meeting between the TSTF and the NRC, the NRC stated that they did not agree with a portion of TSTF-479 referring to the application of a 25%

IST interval extension for SR 3.0.2 to test Frequencies and would not approve plant-specific amendments incorporating that portion of TSTF-479 . Specifically, the NRC expressed a concern that frequency extensions may be applied to Frequencies greater than two years and requested that the TSTF be revised to apply the provisions of SR 3.0 .2 to Frequencies of two years or less only . On July 12, 2006, TSTF-497, Revision 0, (i.e., Reference 2) was submitted to reflect the revised NRC position. These proposed changes for LSCS Units 1 and 2 are based on TSTF 479-A, Revision 0, as modified by TSTF-497, Revision 0, which was approved by the NRC on October 4, 2006 (i .e.,

Reference 4).

4.0 TECHNICAL ANALYSIS

On September 22, 1999 the NRC amended 10 CFR 50.55a, "Codes and Standards," by Final Rule (64 FR 51370) (i .e., Reference 6) to incorporate by reference more recent editions and addenda of the ASME Boiler and Pressure Vessel Code and the ASME OM Code for construction, inservice inspection, and inservice testing . These provisions provide updated rules for the construction of components of light-water-cooled nuclear power plants, and for the inservice inspection and inservice testing (IST) of those components.

The 2001 edition with the 2003 Addenda of the ASME OM Code was approved for use by the NRC and was incorporated by reference into 10 CFR 50.55a paragraph (b) on October 1, 2004 (i .e., Reference 8). The 2001 edition with the 2003 Addenda of the ASME OM Code (i.e., Reference 9) is the ASME Code of record for the upcoming Third 10-Year IST Interval Program for LSCS Units 1 and 2.

TS 5 .5.7 for LSCS Units 1 and 2 currently reference the ASME Boiler and Pressure Vessel Code,Section XI, as the standard for testing frequencies and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves . The ASME Code of record for the upcoming Third 10-Year IST Interval Program for LSCS Units 1 and 2 is the ASME OM Code 2001 Edition through the 2003 Addenda (i .e., Reference 9). The proposed changes to TS 5.5 .7 will replace references to Section XI of the ASME Boiler and Pressure Vessel Code with a reference to the ASME OM Code to conform the TS to the updated Inservice Testing Program to meet the requirements of the Code currently endorsed by reference in 10 CFR 50 .55a(f)(4), as amended in Reference 8, for the upcoming LSCS Units 1 and 2 Third 10-Year IST intervals.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Overview In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC, (EGC), requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-11 Page 4 of 8

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES and NPF-18 . Specifically, the proposed changes will replace references to Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) in TS 5 .5.7, "Inservice Testing Program ." These proposed changes are consistent with the implementation of the LSCS, Units 1 and 2 Third 10-Year IST Program in accordance with the requirements of 10 CFR 50.55a, "Codes and standards," paragraph (f), "Inservice testing requirements ." The Third 10-Year Interval for LSCS Units 1 and 2 is scheduled to start on October 12, 2007 . In addition to the replacement of the references, EGC is also adding provisions in TS 5.5.7, item b, to only apply Surveillance Requirement (SR) 3.0.2 to those Inservice Testing Frequencies of two years or less .

According to 10 CFR 50.92, "Issuance of amendment," paragraph (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:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated ; or (3) Involve a significant reduction in a margin of safety .

In support of this determination, an evaluation of each of the three criteria set forth in 10 CFR 50.92 is provided below regarding the proposed license amendment.

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

Response : No The proposed changes revise TS 5 .5.7 for LSCS Units 1 and 2 to conform to the requirements of 10 CFR 50.55a, "Codes and standards," paragraph (f) regarding the inservice testing of pumps and valves for the Third 10-Year Interval . The current TS reference the ASME Boiler and Pressure Vessel Code,Section XI, requirements for the inservice testing of ASME Code Class 1, 2, and 3 pumps and valves . The proposed changes would reference the ASME OM Code, which is consistent with 10 CFR 50 .55a, paragraph (f), "Inservice testing requirements,"

and approved for use by the NRC. In addition, provisions modifying TS 5.5.7, item b, clarify that SR 3.0.2 is only applied to those inservice testing frequencies of two years or less . The definitions of the frequencies are not changed by this license amendment request.

The proposed changes are administrative in nature, do not affect any accident initiators, do not affect the ability of LSCS to successfully respond to previously evaluated accidents and do not affect radiological assumptions used in the evaluations . Thus, the radiological consequences of any accident previously evaluated are not increased.

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

Page 5 of 8

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES

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

Response: No The proposed changes revise TS 5 .5.7 for LSCS Units 1 and 2 to conform to the requirements of 10 CFR 50.55a(f) regarding the inservice testing of pumps and valves for the Third 10-Year Interval . The current TS reference the ASME Boiler and Pressure Vessel Code,Section XI, requirements for the inservice testing of ASME Code Class 1, 2, and 3 pumps and valves . The proposed changes would reference the ASME OM Code, which is consistent with the 10 CFR 50.55a(f) and approved for use by the NRC . In addition provisions modifying TS 5.5.7, item b, clarify that SR 3.0.2 is only applied to those inservice testing frequencies of two years or less. The definitions of the frequencies are not changed by this license amendment request.

The proposed changes to TS Section 5.5.7 do not affect the performance of any LSCS structure, system, or component credited with mitigating any accident previously evaluated and do not introduce any new modes of system operation or failure mechanisms .

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

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

Response: No The proposed changes revise TS 5.5.7 for LSCS Units 1 and 2 to conform to the requirements of 10 CFR 50.55a(f) regarding the inservice testing of pumps and valves for the Third 10-Year Interval . The current TS reference the ASME Boiler and Pressure Vessel Code,Section XI, requirements for the inservice testing of ASME Code Class 1, 2, and 3 pumps and valves . The proposed changes would reference the ASME OM Code, which is consistent with the 10 CFR 50.55a(f) and approved for use by the NRC . In addition provisions modifying TS 5.5.7, item b, clarify that SR 3.0 .2 is only applied to those inservice testing frequencies of two years or less . The definitions of the frequencies are not changed by this license amendment request.

The proposed changes do not modify the safety limits or setpoints at which protective actions are initiated and do not change the requirements governing operation or availability of safety equipment assumed to operate to preserve the margin of safety .

Therefore, the proposed changes do not involve a significant reduction in a margin of safety .

Based on the above information, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 6 of 8

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES 5.2 Applicable Regulatory Requirements / Criteria 10 CFR 50.55a defines the requirements for applying industry Codes to a licensed boiling or pressurized water-cooled nuclear power facility. 10 CFR 50.55a(f)(4) requires that throughout the service life of a boiling water-cooled nuclear power facility, pumps and valves which are classified as ASME Code Class 1, Class 2 and Class 3, must meet the inservice test requirements that are incorporated by reference in 10 CFR 50.55a(b) to the extent practical within the limitations of design, geometry and materials of construction of the components. 10 CFR 50 .55a(f)(4)(ii) further states that inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month intervals must comply with the latest edition and addenda of the Code, incorporated by reference in 10 CFR 50.55a(b),

12 months before the start of the 120-month interval .

10 CFR 50.55a(f)(5)(ii) states that if a revised inservice test program for a facility conflicts with the TS for the facility, the licensee shall apply to the NRC for amendment of the TS to conform the TS to the revised program . This application shall be submitted at least six months before the start of the period during which the provisions become applicable.

EGC has identified that the implementation of the LSCS Units 1 and 2 Third 10-Year IST Interval Program is in conflict with the requirements specified in TS 5.5.7 . Therefore, in accordance with the requirements of 10 CFR 50.55a(f)(5)(ii), EGC is submitting this License Amendment Request.

6.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed amendment would not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation," and would not change an inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," paragraph (c)(9) .

7.0 REFERENCES

1 . TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a," dated December 19, 2005

2. TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less," dated July 12, 2006 3 . Letter from T. H . Boyce (U.S. NRC) to members of the Technical Specification Task Force, dated December 6, 2005

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES

4. Letter from T. J. Kobetz (U .S. NRC) to members of the Technical Specification Task Force, dated October 4, 2006 5 . Letter from S. Landahl to U .S . NRC, "Proposed Third Ten-year Interval Inservice Testing Program," dated October 16, 2006

6. Federal Register, Volume 64, Number 183, "10 CFR Part 50 -Industry Codes and Standards; Amended Requirements," dated September 22, 1999

7. American Society of Mechanical Engineers (ASME), "Operation and Maintenance of Nuclear Power Plants (OM Code)," 1995 Edition through the 1996 Addenda

8. Federal Register, Volume 69, Number 190, "10 CFR Part 50 -Industry Codes and Standards; Amended Requirements," dated October 1, 2004

9. American Society of Mechanical Engineers (ASME), "Operation and Maintenance of Nuclear Power Plants (OM Code)," 2001 Edition through the 2003 Addenda

ATTACHMENT 2 LASALLE COUNTY STATION UNITS 1 and 2 Docket Nos. 50-373 and 50-374 License Nos. NPF-11 and NPF-18 Markup of Proposed Technical Specifications Page Changes REVISED TS PAGES 5.5-5 5 .5-6

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .6 Inservice Inspection Program for Post Tensioning Tendons This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity . The program shall include baseline measurements prior to initial operations . The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Section XI, Subsection IWL of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50 .55a as amended by relief granted in accordance with 10 CFR 50 .55a(a)(3) .

The provisions of SR 3 .0 .3 are applicable to the Tendon Surveillance Program inspection frequencies .

5 .5 .7 Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 pumps and valves .

a . Testing Frequencies the A S M E

$o- -~ d---Pres-s-a-re--~leKs~e-1°--- ede and applicable Addenda are as follows :

'v'`0- i"Va irifQ tlCrl c 0-1 M t"'uc" 6af Eac .,zr- fl kc ~t ASME -1?ei l er- aRd Pressure

-e~ Code and applicable Addenda terminology for Required Frequencies inservice testing for performing inservice activities testing activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days Every 48 months At least once per 1461 days (continued)

LaSalle 1 and 2 5 .5-5 Amendment No . -14et-134-

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .7 Inservice Testing Program (continued)

b. The provisions of SR 3 .0 .2 are applicable to the above required Frequencies for performing inservice testing activities ;

c . The provisions of SR 3 .0 .3 are applicable to inservice testing activities ; and t~ ~1

d. Nothi ng i n the ASME Code shal l be construed to supersede the requirements of any TS .

5 .5 .8 Ventilation Filter Testing Program (V FTP)

The VFTP shall establish the required testing of Engineered Safety Feature (ESF) filter ventilation systems . Tests described in Specification 5 .5 .8 .a and 5 .5 .S .b shall be performed once per 24 months ; after each complete or partial replacement of the HEPA filter bank or charcoal adsorber bank ; after any structural maintenance on the HEPA filter bank or charcoal adsorber bank housing ; and, following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation that could adversely affect the filter bank or charcoal adsorber capability .

Tests described in Specification 5 .5 .8 .c shall be performed once per 24 months ; after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation ; after any structural maintenance on the charcoal adsorber bank housing ; and, following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation that could adversely affect the charcoal adsorber capability .

Tests described in Specification 5 .5 .8 .4 and 5 .5 .8 .e shall be performed once per 24 months .

The provisions of SR 3 .0 .2 and SR 3 .0 .3 are applicable to the VFTP test frequencies .

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0 .05% when tested in accordance with ANSI/ASME N510-1989 at the system flowrate specified below :

(continued)

LaSalle I and 2 5 .5-6 Amendment No . 7/-133-°

ATTACHMENT 3 LASALLE COUNTY STATION UNITS 1 and 2 Docket Nos. 50-373 and 50-374 License Nos . NPF-11 and NPF-18 Typed Pages for Technical Specifications Changes REVISED TS PAGES 5 .5-5 5 .5-6

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .6 Inservice Inspection Program for Post Tensioning Tendons This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity . The program shall include baseline measurements prior to initial operations . The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Section XI, Subsection IWL of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50 .55a as amended by relief granted in accordance with 10 CFR 50 .55a(a)(3) .

The provisions of SR 3 .0 .3 are applicable to the Tendon Surveillance Program inspection frequencies .

5 .5 .7 Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 pumps and valves .

a . Testing Frequencies applicable to the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda are as follows :

ASME OM Code and applicable Addenda terminology for Required Frequencies inservice testing for performing inservice activities testing activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days Every 48 months At least once per 1461 days (continued)

LaSalle 1 and 2 5 .5-5 Amendment No . /

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .7 Inservice Testing Program (continued)

b. The provisions of SR 3 .0 .2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities ;

c. The provisions of SR 3 .0 .3 are applicable to inservice testing activities ; and

d. Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS .

5 .5 .8 Ventilation Filter Testing Program ( VFTP)

The VFTP shall establish the required testing of Engineered Safety Feature (ESF) filter ventilation systems . Tests described in Specification 5 .5 .8 .a and 5 .5 .8 .b shall be performed once per 24 months ; after each complete or partial replacement of the HEPA filter bank or charcoal adsorber bank ; after any structural maintenance on the HEPA filter bank or charcoal adsorber bank housing ; and, following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation that could adversely affect the filter bank or charcoal adsorber capability .

Tests described in Specification 5 .5 .8 .c shall be performed once per 24 months ; after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation ; after any structural maintenance on the charcoal adsorber bank housing ; and, following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation that could adversely affect the charcoal adsorber capability .

Tests described in Specification 5 .5 .8 .d and 5 .5 .8 .e shall be performed once per 24 months .

The provisions of SR 3 .0 .2 and SR 3 .0 .3 are applicable to the VFTP test frequencies .

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0 .05% when tested in accordance with ANSI/ASME N510-1989 at the system flowrate specified below :

(continued)

LaSalle 1 and 2 5 .5-6 Amendment No . /

ATTACHMENT 4 LASALLE COUNTY STATION UNITS 1 and 2 Docket Nos. 50-373 and 50-374 License Nos. NPF-11 and NPF-18 Markup of Proposed Technical Specifications Bases Page Changes REVISED TS BASES PAGES B 3.4.4-4 B 3 .4 .6-5 B 3.5 .1-11 B 3.5 .1-14 B 3 .6.2.3-4 B 3.6.2.4-4 B 3.8 .1-26 B 3.8.1-44

S/RVs B 3 .4 .4 BASES ACTIONS A .1 and A .2 (continued) a MODE in which the LCO does not apply . To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems .

SURVEILLANCE SR 3 .4 .4 .1 REQUIREMENTS This Surveillance demonstrates that the required S/RVs will open at the pressures assumed in the safety analysis of Reference 2 . The demonstration of the S/RV safety function lift settings must be performed during shutdown, since this is a bench test, and in accordance with the Inservice Testing Program . The lift setting pressure shall correspond to ambient conditions of the valves at nominal operating temperatures and pressures . The S/RV setpoint is +/- 3% for OPERABILITY ; however, the valves are reset to +/- 1% during the Surveillance to allow for drift . Additionally, during the performance of this Surveillance, the S/RV will be manually actuated by providing air to the valve actuator to verify the performance of the valve actuator, lever and pivot mechanism to open the valve . A Note is provided to allow up to two of the required 12 S/RVs to be physically replaced with S/RVs with lower setpoints . This provides operational flexibility which maintains the assumptions in the overpressure protection analysis .

The Frequency is specified in the Inservice Testing Program which requires the valves be subjected to a bench test during refueling outages . The Frequency is acceptable based on industry standards and operating history .

REFERENCES 1. ASME, Boiler and Pressure Vessel Code,Section III .

2. UFSAR, Section 5 .2 .2 .1 .3 .

3. UFSAR, Chapter 15 .

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RCS PIV Leakage B 3 .4 .6 BASES SURVEILLANCE SR 3 .4 .6 .1 (continued)

REQUIREMENTS per inch of nominal valve diameter up to 5 gpm maximum applies to each valve . Leakage testing requires a stable pressure condition . As stated in the LCO section of the Bases, the test pressure may be at a lower pressure than the maximum pressure differential (at the maximum pressure of 1050 psig) provided the observed leakage rate is adjusted in accordance with Reference 4 . For the two PIVs tested in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves (i .e ., the leakage acceptance criteria is the criteria for one valve to account for the condition where all of the leakage is through one valve) . If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement . In this situation, the protection provided by redundant valves would be lost .

A 9te o N1 The Frequency?, required by the Inservice Testing Program is Frequency within the ASKl:- z-e~~; requirement and is based on the need to perform this Surveillance under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power .

This SR is modified by a Note that states the leakage Surveillance is only required to be performed in MODES 1 and 2 . Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES .

REFERENCES l. 10 CFR 50 .2 .

2. 10 CFR 50 .55a(c) .

3. 10 CFR 50, Appendix A, GDC 55 .

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5. NUREG-0677, "The Probability of Intersystem LOCA :

Impact Due to Leak Testing and Operational Changes,"

May 1980 .

(continued)

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ECCS-Operating B 3 .5 .1 BASES SURVEILLANCE SR 3 .5 .1 .5 REQUIREMENTS (continued) The performance requirements of the ECCS pumps are determined through application of the 10 CFR 50, Appendix K, criteria (Ref . 8) . This periodic Surveillance is performed

~ GPJ1Ca . (in accordance with the~A-WE---bode';-~e~t4¬~~; requirements for the --ECCS" pumpsT toverify that the ECCS pumps will develop the flow rates required by the respective analyses .

The ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of 10 CFR 50 .46 (Ref . 10) .

The pump flow rates are verified against a test line pressure that was determined during preoperational testing to be equivalent to the RPV pressure expected during a LOCA .

Under these conditions, the total system pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during LOCAs . The Frequency for this Surveillance is in accordance with the Inservice Testing Program requirements .

SR 3 .5 -1 .6 The ECCS subsystems are required to actuate automatically to perform their design functions . This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required position . This Surveillance also ensures that the HPCS System injection valve will automatically reopen on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) injection valve closure signal . The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3 .3 .5 .1 overlaps this Surveillance to provide complete testing of the assumed safety function .

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 the SR when performed at the 24 month Frequency, which is based on the refueling cycle . Therefore, the Frequency (continued)

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ECCS-Operating B 3 .5 .1 BASES REFERENCES (continued) 12 . Memorandum from R .L . Baer (NRC) to V . Stello, Jr .

(NRC), "Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975 .

13 . UFSAR, Section 7 .3 .1 .2 .

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RHR Suppression Pool Cooling B 3 .6 .2 .3 BASES SURVEILLANCE SR 3 .6 .2 .3 .1 (continued)

REQUIREMENTS The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system . This Frequency has been shown to be acceptable, based on operating experience .

SR 3,6 .2 ._3 .2 Verifying each required RHR pump develops a flow rate

>_ 7200 gpm, while operating in the suppression pool cooling mode with flow through the associated heat exchanger, ensures that peak suppression pool temperature can be maintained below the design limits during a DBA (Ref . 1) .

The flow verification is also a normal test of centrifugal pump performa nce required bye -S-M1=---Se-c-tfen--X-1-(Ref . 2) . This i;est conTTrms onepointon the pump design curve, and the results are indicative of overall performance . Such inservice tests confirm component OPERABILITY and detect incipient failures by indicating abnormal performance . The Frequency of this SR is in accordance with the Inservice Testing Program .

REFERENCES l. UFSAR, Section 6 .2 .

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RHR Suppression Pool Spray B 3 .6 .2 .4 BASES SURVEILLANCE SR 3 .6 .2 .4 .1 (continued)

REQUIREMENTS event requiring initiation of the system is low, and the subsystem is a manually initiated system . This Frequency has been shown to be acceptable based on operating experience .

SR 3 .6 .2 .4 .2 Verifying each required RHR pump develops a flow rate

>_ 450 gpm through the spray sparger while operating in the suppression pool spray mode helps ensure that the primary containment pressure can be maintained below the design limits during a DBA (Ref . 1) . The normal test of centrifugal pump performance required by s°~ )l-af--t#e

. AsmE c>tA Cn,-Le-- (Ref . 2) i s covered by the requirements of LCO 3 .6 .2 .3, "RHR Suppression Pool Cooling ." The Frequency of this SR is in accordance with the Inservice Testing Program .

REFERENCES 1. UFSAR, Section 6 .2 .1 .1 .3 .

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AC Sources-Operating B 3 .8 .1 BASES SURVEILLANCE SR 3 .8 .1 .5 (continued)

REQUIREMENTS fuel oil day tanks once every 31 days eliminates the necessary environment for bacterial survival . This is most effective means in controlling microbiological fouling . In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation . Water may come from any of several sources, including condensation, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria . Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system . The Surveillance Frequency is established by Regulatory Guide 1 .137 (Ref . 10) . This SR is for preventive maintenance . The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance .

SR 3 .8 .1 .6 This Surveillance demonstrates that . each required fuel oil transfer pump operates and automatically transfers fuel oil from its associated storage tank to its associated day tank .

It is required to support the continuous operation of standby power sources . This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE .

The Frequency for this SR corresponds to the testing requirements for pumps as contained i n the -- ,.~

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ogl co,E_e_- h (Ref . 11) .

m  l AS"e SR 3 .8 .1 .8 Transfer of each Division 1 and 2 4 .16 kV emergency bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the Division 1 and 2 shutdown loads . The 24 month Frequency of the Surveillance is based on engineering judgment taking (continued)

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AC Sources-Operating B 3 .8 . 1 BASES SURVEILLANCE SR 3 .8 .1 .21 (continued)

REQUIREMENTS required by the given unit Specification . SR 3 .8 .1 .12, SR 3 .8 .1 .13, SR 3 .8 .1 .17, SR 3 .8 .1 .18, and SR 3 .8 .1 .19 are excepted since these SRs test the opposite unit's ECCS initiation signal, which is not required for the AC electrical power sources to be OPERABLE on a given unit .

The Frequency required by the applicable opposite unit SR also governs performance of that SR for the given unit .

As noted, if the opposite unit is in MODE 4 or 5, or moving irradiated fuel assemblies in secondary containment, SR 3 .8 .1 .3, SR 3 .8 .1 .9 through SR 3 .8 .1 .11, and SR 3 .8 .1 .14 through SR 3 .8 .1 .16 are not required to be performed . This ensures that a given unit SR will not require an opposite unit SR to be performed, when the opposite unit Technical Specifications exempts performance of an opposite unit SR (however, as stated in the opposite unit SR 3 .8 .2 .1 Note 1, while performance of an SR is exempted, the SR must still be met) .

REFERENCES 1 . 10 CFR 50, Appendix A, GDC 17

2. UFSAR, Chapter 8 .

3. Regulatory Guide 1 .9 .

4. UFSAR, Chapter 6 .

5. UFSAR, Chapter 15 .

6. Regulatory Guide 1 .93 .

7. Generic Letter 84-15, July 2, 1984 .

8. 10 CFR 50, Appendix A, GDC 18 .

9. Regulatory Guide 1 .137 .

10 . ANSI C84 .1, 1982 .

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