View source for RA07-036, LaSalle, Units 1 and 2 - Submittal of Relief Requests Associated with the Third Inservice Inspection (ISI) Interval and the Second Containment Inservice Inspection (Cisi) Interval

{{Adams
| number = ML071280395
| issue date = 04/30/2007
| title = LaSalle, Units 1 and 2 - Submittal of Relief Requests Associated with the Third Inservice Inspection (ISI) Interval and the Second Containment Inservice Inspection (Cisi) Interval
| author name = Landhal S R
| author affiliation = Exelon Nuclear
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR/ADRO
| docket = 05000373, 05000374
| license number = NPF-011, NPF-018
| contact person = 
| case reference number = RA07-036
| document type = Inservice/Preservice Inspection and Test Report, Letter type:RA
| page count = 32
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:" Exelon.LaSalle Generating Station www.exeloncorp.com Nuclear 2601 North 21st Road Marseilles, I L 61341-9757 RA07-036 10 CFR 50.55a April 30, 2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 LaSalle County Station, Units land 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374 

==Subject:==
Submittal of Relief Requests Associated with the Third Inservice Inspection (ISI)Interval and the Second Containment Inservice Inspection (CISI) Interval 

==References:==
: 1. Letter from S. R. Landahl (Exelon Generation Company, LLC) to U. S.NRC, "In Service Inspection (ISI) Intervals," dated September 22, 2006 2. Letter from A. J. Mendiola (U. S. NRC) to 0. D. Kingsley, (Exelon Generation Company, LLC), "LaSalle County Station, Units 1 and 2 -Relief Request CR-35," dated December 27, 2001 In accordance with 10 CFR 50.55a, "Codes and standards," Exelon Generating Company, LLC (EGC), hereby requests NRC approval of the following requests for the Third Inservice Inspection (ISI) Interval, and the Second ISI Interval of the Containment Inservice Inspection (CISI) Interval for LaSalle County Station (LSCS), Units 1 and 2.1. Alternate Risk-Informed Selection and Examination Criteria for Examination Category B-F, B-J, C-F-i, and C-F-2 Pressure Retaining Piping Welds -10 CFR 50.55a(a)(3)(i).
: 2. Examination of the High Pressure Core Spray (HPCS), Low Pressure Core Spray (HPCS), Residual Heat Removal (RHR) Pump Casing Welds -10 CFR 50.55a(g)(5)(iii).
: 3. Examination of the Reactor Pressure Vessel (RPV) Stabilizer Bracket Welds on Shell Course -10 CFR 50.55a(g)(5)(iii).
: 4. Post-Tensioning Inspection Scheduling Requirements For Sites With Two Plants -10 CFR 50.55a(a)(3)(i).
April 30, 2007 U.S. Nuclear Regulatory Commission Page 2 5. Alternative Pressure Testing of the RPV Head Flange Seal Leak Detection System -10 CFR 50.55a(g)(5)(iii).
: 6. Continuous Pressure Monitoring of the Control Rod Drive (CRD) System Accumulators 
-10 CFR 50.55a(a)(3)(i).
: 7. Alternative Pressure Testing of the Safety Relief Valve (SRV) Automatic Depressurization System (ADS) Accumulators 
-10 CFR 50.55a(a)(3)(i).
: 8. Hydrogen Recombiner System Piping -10 CFR 50.55a(a)(3)(ii).
The details of the 10 CFR 50.55a requests are enclosed.
Please note that all of the attached relief requests were previously approved as a part of the previous ISI and CISI intervals for LSCS Units 1 and 2 except 13R-03 (item 2 above).The third interval of the ISI and the second CISI interval programs comply with the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code. As detailed in Reference 1, the new inspection intervals for both the ISI and CISI programs will begin on October 1, 2007 and will conclude on September 30, 2017 for LSCS Units 1 and 2. Twelve months prior to the start of the new ISI and CISI intervals (i.e., September 30, 2006) the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b)(2) was the 2001 Edition through the 2003 Addenda.Note that item 1 above, "Alternate Risk-Informed Selection and Examination Criteria for Examination Category B-F, B-J, C-F-i, and C-F-2 Pressure Retaining Piping Welds," is the risk-informed relief request that was previously approved by Reference 2.EGC requests approval of these relief requests by January 31, 2008.Should you have any questions concerning this letter, please contact Mr. Terrence T.Simpkin, LSCS Regulatory Assurance Manager, at (815) 415-2800.Respectfully, S usan R. Landh Site Vice President LaSalle County Station 

==Attachment:==

10 CFR 50.55a Relief Requests cc: Regional Administrator 
-NRC Region III NRC Senior Resident Inspector 
-LaSalle County Station Relief Requests Associated with the Third Inservice Inspection (ISI) Interval and the Second Containment Inservice Inspection (CISI) Interval 13R-01 13R-03 13R-04 13R-05 13R-08 13R-09 13R-10 13R-1 1 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-01 Revision 0 (Page 1 of 6)Request for Relief for Alternate Risk-Informed Selection and Examination Criteria for Examination Category B-F, B-J, C-F-i, and C-F-2 Pressure Retaining Piping Welds In Accordance with 10 CFR 50.55a(a)(3)(i) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: 1 and 2 Examination Category:
B-F, B-J, C-F-I, and C-F-2 Item Number: B5.10, B9.11, B9.21, B9.31, B9.32, B9.40, C5.11, C5.21, C5.51, and C5.81

== Description:==

Alternate Risk-Informed Selection and Examination Criteria for Examination Category B-F, B-J, C-F-I, and C-F-2 Pressure Retaining Piping Welds Component Number: Pressure Retaining Piping 2.0 APPLICABLE CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.3.0 APPLICABLE CODE REQUIREMENT:
Table IWB-2500-1, Examination Category B-F, requires volumetric and surface examinations on all welds for Item Number B5.10.Table IWB-2500-1, Examination Category B-J, requires volumetric and/or surface examinations on a sample of welds for Item Numbers B9.11, B9.21, B9.31, B9.32, and B9.40. The weld population selected for inspection includes the following:
: 1. All terminal ends in each pipe or branch run connected to vessels.2. All terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed either of the following limits under loads associated with specific seismic events and operational conditions:
: a. primary plus secondary stress intensity range of 2.4 Sm for ferritic steel and austenitic steel.b. cumulative usage factor U of 0.4.Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-01 Revision 0 (Page 2 of 6)3. All dissimilar metal welds not covered under Category B-F.4. Additional piping welds so that the total number of circumferential butt welds, branch connections, or socket welds selected for examination equals 25% of the circumferential butt welds, branch connection, or socket welds in the reactor coolant piping system. This total does not include welds exempted by IWB-1220.Table IWC-2500-1, Examination Categories C-F-I and C-F-2 require volumetric and/or surface examinations on a sample of welds for Item Numbers C5.1 1, C5.21, C5.51, and C5.8 1. The weld population selected for inspection includes the following:
: 1. Welds selected for examination shall include 7.5%, but not less than 28 welds, of all dissimilar metal, austenitic stainless steel and high alloy welds (Examination Category C-F-i) or of all carbon and low alloy steel welds (Examination Category C-F-2) not exempted by IWC-1220. (Some welds not exempted by IWC-1220 are not required to be nondestructively examined per Examination Categories C-F-I and C-F-2. These welds, however, shall be included in the total weld count to which the 7.5% sampling rate is applied.)
The examinations shall be distributed as follows: a. the examinations shall be distributed among the Class 2 systems prorated, to the degree practicable, on the number of nonexempt dissimilar metal, austenitic stainless steel and high alloy welds (Examination Category C-F-i) or carbon and low alloy welds (Examination Category C-F-2) in each system;b. within a system, the examinations shall be distributed among terminal ends, dissimilar metal welds, and structural discontinuities prorated, to the degree practicable, on the number of nonexempt terminal ends, dissimilar metal welds, and structural discontinuities in the system; and c. within each system, examinations shall be distributed between line sizes prorated to the degree practicable.

===4.0 REASON===
FOR REQUEST: Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative utilizing Reference 1 along with two enhancements from Reference 4 will provide an acceptable level of quality and safety.Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-01 Revision 0 (Page 3 of 6)As stated in "Safety Evaluation Report Related to EPRI Risk-Informed Inservice Inspection Evaluation Procedure (EPRI TR-1 12657, Revision B, July 1999)" (Reference 2): "The staff concludes that the proposed RISI program as described in EPRI TR- 112657, Revision B, is a sound technical approach and will provide an acceptable level of quality and safety pursuant to 10 CFR 50.55a for the proposed alternative to the piping ISI requirements with regard to the number of locations, locations of inspections, and methods of inspection." The initial LaSalle County Station RISI Program was submitted during the Second Period of the Second Interval for Units 1 and 2. This initial RISI program was developed in accordance with EPRI TR- 112657, Revision B-A, as supplemented by Code Case N-578-1. The program was approved for use by the NRC via a Safety Evaluation as transmitted to Exelon on February 5, 2002 (Reference 5).The transition from the 1989 Edition to the 2001 Edition through the 2003 Addenda of ASME Section XI for LaSalle County Station's Third Interval does not impact the currently approved Risk-Informed ISI evaluation process used in the Second Interval, and the requirements of the new Code edition/addenda will be implemented as detailed in the LaSalle County Station ISI Program Plan.The Risk Impact Assessment completed as part of the original baseline RISI Program was an implementation/transition check on the initial impact of converting from a traditional ASME Section XI program to the new RISI methodology.
For the Third Interval ISI update, there is no transition occurring between two different methodologies, but rather, the currently approved RISI methodology and evaluation will be maintained for the new interval.
As such, the original risk impact assessment is not a necessary element of the implementing process and is not required to be continually updated.As an added measure of assurance, any new systems, portions of systems, or components being included in the RISI Program for the Third Interval will be added to the Risk Impact Assessment performed during the previous interval.
These components will be addressed within the evaluation at the start of the new interval to assure that the new Third Interval RISI element selection provides an acceptable overall change-in-risk when compared to the old ASME Section XI population of exams which existed prior to the implementation of the first RISI Program.The actual evaluation and ranking procedure including the Consequence Evaluation and Degradation Mechanism Assessment processes of the currently approved (Reference 5)RISI Program remain unchanged and are continually applied to maintain the Risk Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-01 Revision 0 (Page 4 of 6)Categorization and Element Selection methods of EPRI TR- 112657, Revision B-A.These portions of the RISI Program are reevaluated as major revisions of the site PRA occur and modifications to plant configuration are made. The Consequence Evaluation, Degradation Mechanism Assessment, Risk Ranking, and Element Selection steps encompass the complete living program process applied under the LaSalle County Station RISI Program.5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE: The proposed alternative originally implemented in the "Risk Informed Inservice Inspection Plan, LaSalle County Station Units 1 and 2 (Reference 3), along with the two enhancements noted below, provide an acceptable level of quality and safety as required by 10 CFR 50.55a(a)(3)(i).
This original program along with these same two enhancements is currently approved for LaSalle County Station's Second Inspection Interval as documented in Reference 5.The Third Interval RISI Program will be a continuation of the current application and will continue to be a living program as described in the Reason For Request section of this relief request. No changes to the evaluation methodology as currently implemented under EPRI TR- 112657, Revision B-A, are required as part of this interval update. The following two enhancements will continue to be implemented.
In lieu of the evaluation and sample expansion requirements in Section 3.6.6.2,"RISI Selected Examinations" of EPRI TR- 112657, LaSalle County Station will utilize the requirements of Subarticle 
-2430, "Additional Examinations" contained in Code Case N-578-1 (Reference 4). The alternative criteria for additional examinations contained in Code Case N-578-1 provides a more refined methodology for implementing necessary additional examinations.
To supplement the requirements listed in Table 4-1, "Summary of Degradation-Specific Inspection Requirements and Examination Methods" of EPRI TR-1 12657, LaSalle County Station will utilize the provisions listed in Table 1, Examination Category R-A, "Risk-Informed Piping Examinations" contained in Code Case N-578-1 (Reference 4). To implement Note 10 of this table, paragraphs and figures from the 2001 Edition through the 2003 Addenda of ASME Section XI (LaSalle County Station's code of record for the Third Interval)will be utilized which parallel those referenced in the Code Case for the 1989 Edition. Table 1 of Code Case N-578-1 will be used as it provides a detailed breakdown for examination method and categorization of parts to be examined.The LaSalle County Station RISI Program, as developed in accordance with EPRI TR- 112657, Rev. B-A (Reference 1), requires that 25% of the elements that are Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-01 Revision 0 (Page 5 of 6)categorized as "High" risk (i.e., Risk Category 1, 2, and 3) and 10% of the elements that are categorized as "Medium" risk (i.e., Risk Categories 4 and 5) be selected for inspection.
For this application, the guidance for the examination volume for a given degradation mechanism is provided by the EPRI TR- 112657 while the guidance for the examination method and categorization of parts to be examined are provided by the EPRI TR-112657 as supplemented by Code Case N-578-1.In addition to this risk-informed evaluation, selection, and examination procedure, all ASME Section XI piping components, regardless of risk classification, will continue to receive Code required pressure testing as part of the current ASME Section XI program.VT-2 visual examinations are scheduled in accordance with the LaSalle County Station pressure testing program, which remains unaffected by the RISI program.6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the Third Ten-Year Inspection Interval for LaSalle County Station Units 1 and 2.7.0 PRECEDENTS:
Similar relief requests have been approved for: LaSalle County Station Second Inspection Interval Relief Request CR-35 was authorized per SER dated December 27, 2001. The Third Inspection Interval Relief Request utilizes an identical RISI methodology as was previously approved.Susquehanna Steam Electric Station Third Inspection Interval Relief Request 3RR-01 was authorized per SER dated July 28, 2005.Dresden Station Fourth Inspection Interval Relief Request 14R-02 was authorized per SER dated September 4, 2003.Quad Cities Station Fourth Inspection Interval Relief Request 14R-02 was authorized per SER dated January 28, 2004.

==8.0 REFERENCES==
:
: 1) Electric Power Research Institute (EPRI) Topical Report (TR) 112657 Rev. B-A,"Revised Risk-Informed Inservice Inspection Evaluation Procedure", December 1999 2) W. H. Bateman (NRC) to G. L. Vine (EPRI) letter dated October 28, 1999 transmitting "Safety Evaluation Report Related to EPRI Risk-Informed Inservice Inspection Evaluation Procedure (EPRI TR- 112657, Revision B, July 1999)" Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-01 Revision 0 (Page 6 of 6)3) Initial Risk-Informed Inservice Inspection Evaluation 
-LaSalle County Station Units 1 and 2, dated February 2001 4) American Society of Mechanical Engineers (ASME) Code Case N-578-1, "Risk-Informed Requirements for Class 1, 2, or 3 Piping, Method B" 5) A. J. Mendiola (NRC) to 0. D. Kingsley (Exelon) letter dated December 27, 2001 transmitting "Safety Evaluation of Second Interval Risk-Informed Inservice Inspection Program Relief Request" A lion Science & Technology L4S03.G03 Alion Science & Technology LAS03. GO3 151 Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-03 Revision 0 (Page 1 of 3)Request for Relief Regarding Inservice Inspection Impracticality Due to the Examination of the RHR, HPCS, and LPCS Pump Casing Welds In Accordance with 10 CFR 50.55a(g)(5)(iii) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: 

==Reference:==

Examination Category: Item Number:

== Description:==

Component Number: Drawing Number: 2 IWC-2500, Table IWC-2500-1 C-G C6.10 Examination of the RHR, HPCS, and LPCS Pump Casing Welds IA RHR Pump Casing Welds 1B RHR Pump Casing Welds IC RHR Pump Casing Welds 2A RHR Pump Casing Welds 2B RHR Pump Casing Welds 2C RHR Pump Casing Welds 1 HPCS Pump Casing Welds 2 HPCS Pump Casing Welds 1 LPCS Pump Casing Welds 2 LPCS Pump Casing Welds GEL-1103, GEL-1049, GEL-1050 (Unit 1)GEL- 1108, GEL-2049, GEL-2050 (Unit 2)APPLICABLE CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.2.0 APPLICABLE CODE REQUIREMENT:
Table IWC-2500-1 states that the pump casing welds require a surface examination in accordance with the examination requirements illustrated in Figure IWC-2500-8.
Per Table IWC-2500-1, the multiple-component concept applies, and examinations are limited to either 100% of the welds of one of three Residual Heat Removal Pumps, one High Pressure Core Spray Pump, and one Low Pressure Core Spray Pump (per unit), or distributed among any of the pumps of that same group (per unit) with similar design, A lin Scenc & TchnoogyL450.GI Ation Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-03 Revision 0 (Page 2 of 3)size, function, and service in the system. The examination may be performed from either the inside or outside surface of the component.

===3.0 IMPRACTICALITY===

OF COMPLIANCE:
Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested on the basis that conformance with these code requirements is impractical.
LaSalle County Station's Residual Heat Removal Pumps, High Pressure Core Spray Pump, Low Pressure Core Spray Pump were originally designed where the pump casing welds were encased in concrete, thus making the welds inaccessible for inservice inspection.
Therefore, it is impractical for LaSalle County Station to perform the surface examination of these welds without destruction of the concrete resulting in unnecessary engineering and installation costs and radiation exposure without a compensating increase in safety. Additionally, due to the design of the subject pumps, access to the affected welds can only be achieved through disassembly of the pump, removal of the pump internals, and the required surface examinations performed from the inside surface of the welds. This effort, in the absence of any other necessary pump maintenance, represents a significant expenditure of man hours and radiation exposure to plant personnel, without a compensating increase in plant safety.4.0 BURDEN CAUSED BY COMPLIANCE:
Compliance with the applicable Code requirements can only be accomplished by redesigning and refabricating the subject pumps. Based on this, the Code requirements are deemed impractical in accordance with 10 CFR 50.55a(g)(5)(iii).

===5.0 PROPOSED===
ALTERNATIVE AND BASIS FOR USE: In the event the subject welds become accessible upon disassembly of any one (1) of the pumps, the welds will be surface examined from the inside surface or a VT-1 visual examination will be performed for that particular pump group to the maximum extent practicable based on the obstructions and geometric constraints detailed in the Impracticality Of Compliance section of this relief request. The examination method will be determined by LaSalle County Station based on radiation environment data at the time access is enabled. Additionally, a VT-2 visual examination during system pressure testing per Examination Category C-H will be performed once each period by examining the surrounding area (exposed areas around these components where the pump casing join/merge with the concrete) for evidence of leakage in accordance with IWA-5241(b).
Alion Science & Technology LASO3. G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-03 Revision 0 (Page 3 of 3)These examinations will provide reasonable assurance of continued structural integrity of the piping systems.6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the Third Ten-Year Inspection Interval for LaSalle County Station Units 1 and 2.7.0 PRECEDENTS:
Similar relief requests have been approved for: Limerick Generating Station Second Inspection Interval Relief Request RR-07 was granted per SER dated May 2, 2002.Susquehanna Steam Electric Station Third Inspection Interval Relief Request 3RR-02 was granted per SER dated February 1, 2005.A lion Science & Technology LASO3.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-04 Revision 0 (Page 1 of 4)Request for Relief Regarding Inservice Inspection Impracticality Due to the Examination of the RPV Stabilizer Bracket Welds on Shell Course In Accordance with 10 CFR 50.55a(g)(5)(iii) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: 1 

==Reference:==

IWB-2500, Table IWB-2500-1 Examination Category:
B-K Item Number: B 10.10

== Description:==

Examination of the RPV Stabilizer Bracket Welds on Shell Course Component Number: RPV Stabilizer Bracket Welds Drawing Number: GEL- 1109 (Unit 1)GEL- 1119 (Unit 2)2.0 APPLICABLE CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.3.0 APPLICABLE CODE REQUIREMENT:
Per Table IWB-2500-1, Examination Category B-K, Item Number B 10.10, a surface examination is required over essentially 100% of the length of the weld for Pressure Vessel welded attachments.
Examination Category B-K, Note 4 states that for multiple vessels of similar design, function, and service, only one welded attachment of only one of the multiple vessels shall be selected for examination.

===4.0 IMPRACTICALITY===

OF COMPLIANCE:
Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested on the basis that conformance with these code requirements is impractical.
Due to other plant structures and components, accessibility of 100% of the examination areas for these welds was not provided in the original plant design which occurred prior to the issuance of ASME Section XI Inservice Inspection requirements.
As indicated by Figure 13R-04. 1, surface examination of the vessel stabilizer bracket Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-04 Revision 0 (Page 2 of 4)weld is not possible due to the proximity of the bioshield wall, the stabilizer bar, and vessel insulation.
The stabilizer bracket lugs are approximately 14" long by 7" wide. From past examination data and configuration details, LaSalle County Station has identified that the entire lower length of the weld is inaccessible for surface or visual examination due to the biological shield wall and the stabilizer bar. The two side lengths and the entire top length are also not accessible for surface examination due to the Reactor Pressure Vessel insulation; however, limited visual access can be obtained.
LaSalle County Station has calculated the best effort examination coverage to be between 52% and 66% of the entire weld surface. This would account for the entire top length of the weld and essentially the full length of the side welds.Due to the vessel insulation being panel type linked by several small screws which are inaccessible for the subject panels due to the stabilizer bars and brackets, the ability to remove the insulation is not practical due to the tight clearances and potential to damage the fasteners and insulation joints. Also, these activities would have to take place in elevated dose rates and would not be consistent with ALARA practices.
Based on the limited geometrical configuration described above and detailed in Figure 13R-04. 1, LaSalle County Station requests relief from the ASME Section XI surface examination coverage area requirements for the six stabilizer bracket lugs per unit.5.0 BURDEN CAUSED BY COMPLIANCE:
Compliance with the applicable Code requirements can only be accomplished by redesigning and refabricating the subject Reactor Pressure Vessel. Based on this, the Code requirements are deemed impractical in accordance with 10 CFR 50.55a(g)(5)(iii)

===6.0 PROPOSED===
ALTERNATIVE AND BASIS FOR USE: As an alternate examination to the Code required surface examination, LaSalle County Station will perform a VT-1 visual examination on the accessible portions of the stabilizer bracket welds (approximately 52% of the weld length) when one of these lugs is scheduled for examination in accordance with ASME Section XI.7.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the Third Ten-Year Inspection Interval for LaSalle County Station Units 1 and 2.Alion Science & Technology LASO3. G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-04 Revision 0 (Page 3 of 4)8.0 PRECEDENTS:
Similar relief requests have been approved for: None.Alion Science & Technology LASO3.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-04 Revision 0 (Page 4 of 4)Figure 13R-04.1 REACTOR PRESSURE VESSEL STABILIZER BRACKET WELDS 14.0" -7.5" L_,_-__ _ _J 17.25" 7.0" Reactor Vessel O.D.8.50" Insulation Alion Science & Technology LASO3.G03 Alion Science & Technology LASO3. G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-05 Revision 0 (Page 1 of 3)Request for Relief for Post-Tensioning System Inspection Scheduling Requirements For Sites With Two Plants In Accordance with 10 CFR 50.55a(a)(3)(i) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: CC 

==Reference:==

IWL-2421 Examination Category:
L-B Item Number: L2.10, L2.20

== Description:==

Inservice Inspection Scheduling Requirements For Sites With Two Plants Component Number: Tendons and Wire Strands for Class CC Concrete Containment

===2.0 APPLICABLE===

CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.3.0 APPLICABLE CODE REOUIREMENT:
IWL-2421(a) allows the test schedule for concrete containment poet-tensioning systems for sites with two plants to be modified if the following are met:* Both containments utilize the same prestressing system and are essentially identical in design;* Post-tensioning operations for the two containments were completed not more than two years apart, and;" Both containments are similarly exposed to or protected from the outside environment.
IWL-2421(b) specifies the modified test schedule when the conditions of IWL-2421(a) are met.4.0 REASON FOR REQUEST: Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-05 Revision 0 (Page 2 of 3)On August 8 1996, the USNRC published a final rule in the Federal Register (i.e., 61 Federal Register 41303) to amend 10 CFR 50.55a, "Codes and standards," to incorporate by reference Subsection IWL of ASME Section XI. Subsection IWL of ASME Section XI, provides rules for the containment inservice inspection (CISI) and repair/replacement activities of the reinforced concrete and post tensioning systems of Class CC components.
LSCS Units 1 and 2 primary containments are Class CC components.
The amended 10 CFR 50.55a required incorporation of Subsection IWL into inspection programs by September 9, 2001. The initial IWL examinations were allowed to be based on the existing (prior to September 9, 1996) post-tensioning system program schedules per 10 CFR 50.55a(g)(6)(ii)(B)(4) at that time. After establishing this initial IWL inspection date, subsequent 5 year inspections are based on IWL-2400.
LaSalle County Station maintains an inspection program to implement Subsection IWL requirements.
IWL-2421(a) allows the test schedule for post-tensioning systems of the concrete containments for sites with two plants to be modified if (1) both containments utilize the same prestressing system and are essentially identical in design, (2) post-tensioning operations for the two containments were completed not more than two years apart, and (3) both containments are similarly exposed to or protected from the outside environment.
LaSalle County Station, Units 1 and 2, primary containments utilize the same prestressing system, are essentially identical in design, and both primary containments are similarly exposed to or protected from the outside environment.
Regarding the final condition, LaSalle County Station Unit 1 post-tensioning operation was performed in July 1978, and Unit 2 post-tensioning operation was performed in December 1980 (29 months apart).Prior to the endorsement of the IWL rules, the USNRC in Amendment No. 100 for Unit 1 and Amendment No. 84 for Unit 2 (letter dated June 3, 1994) approved the use of the guidance contained Regulatory Guide (RG) 1.35, "Inservice Inspection of Ungrouted Tendons in Prestresssed Concrete Containments," Revision 3, and the use of the provisions of Surveillance Requirement (SR) 3.0.2. Additionally, the USNRC reviewed LaSalle County Station's request at that time to treat the Units 1 and 2 primary containments as "twin containments" even though the initial Structural Integrity Tests (SITs) were not within two years of each other as described in RG 1.35. (Note that the two year period in Regulatory Guide 1.35 was based on the SIT dates whereas the two year period in IWL-2410(a) is based on Post-Tensioning Operation.)
The LaSalle County Station Unit 1 initial SIT was performed in December 1978, and the Unit 2 initial SIT was performed in June 1983 (55 months apart).The USNRC approved this approach was based on a detailed review of data from five Unit 1 and four Unit 2 inservice inspections.
The USNRC reviewers noted that for the liftoff forces, the difference between the two unit's construction dates was of little significance.
The USNRC review of this data concluded that there is reasonable Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-05 Revision 0 (Page 3 of 3)agreement in the deflection values obtained during the testing at comparable locations of the primary containments and that the treatment of the LaSalle County Station Units 1 and 2 primary containments as "twin containments" was acceptable.
The current IWL Program for tendons and wires/strands is based on the continued treatment of the LaSalle County Station Units 1 and 2 primary containments as "twin containments." Post-tensioning system inspections completed to date have been performed for the 1st, 3', 5t, 10', 15', 20th, and 25th years for Unit 1, and the 1s, 3rd, 5 10', 15t', and 2 0 th years for Unit 2, with the tendon and wire/strand tests being completed every other 5 year period. These Post-Tensioning System tests and examinations for both units have all met the applicable acceptance criteria.
The results of these inspections completed to date demonstrate that the performance of the Unit 2 post-tensioning relative to the Unit 1 post-tensioning (i.e., 29 months apart) is not a factor contributing to any unique condition that may subject either primary containment to a different potential for structural or tendon deterioration.
Relief is requested from the IWL-2421(a) requirement to apply the modified test schedule of 1WL-2421(b) only if post-tensioning operations for the two primary containments were completed not more than two years apart. Based on the above discussion, the proposed alternative will provide an acceptable level of quality and safety.5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE: The modified test schedule of IWL-2421(b) will continue to be used for LaSalle County Station, Units 1 and 2 tendon tests (L2. 10) and wire/strand examinations (L2.20). The initiation of the IWL-2400 rolling 5 year schedule was based on the previous inspection dates under the Station Tendon Surveillance Program prior to Subsection IWL being endorsed and will continue throughout this interval.6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the Second Ten-Year IWL Interval of the Containment Inservice Inspection Program for LaSalle County Station, Units 1 and 2.7.0 PRECEDENTS:
Similar relief requests have been approved for: LaSalle County Station First Containment Inservice Inspection Interval Relief Request CR-32 was authorized per SER dated August 16, 2001. The Second Containment Inservice Inspection Interval Relief Request utilizes an identical approach as was previously approved.Alion Science & Technology LASO3.G03 151 Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-08 Revision 0 (Page 1 of 5)Request for Relief for Inservice Inspection Impracticality of Pressure Testing the RPV Head Flange Seal Leak Detection System In Accordance with 10 CFR 50.55a(g)(5)(iii) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: 

==Reference:==

Examination Category: Item Number:

== Description:==

Component Number: Drawing Number: 2 Table IWC-2500-1 IWC-5200 C-H C7.10 Pressure Testing the RPV Head Flange Seal Leak Detection System Class 2 RPV Head Flange Seal Leak Detection System M-93, Sht. 4 (Unit 1)M-139, Sht. 4 (Unit 2)2.0 APPLICABLE CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.3.0 APPLICABLE CODE REQUIREMENT:
The following Code requirements are paraphrased from the 2001 Edition through the 2003 Addenda of ASME Section XI.Table IWC-2500-1, Examination Category C-H, Item Number C7.10, requires all Class 2 pressure retaining components be subject to a system leakage test with a VT-2 visual examination in accordance with IWC-5220.
This pressure test is to be conducted once each inspection period.4.0 IMPRACTICALITY OF COMPLIANCE:
Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested on the basis that pressure testing the RPV Flange Leak Detection Line is deemed impractical.
The Reactor Vessel Head Flange Leak Detection Line is separated from the reactor pressure boundary by one passive membrane, a silver-plated O-ring located on the vessel Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-08 Revision 0 (Page 2 of 5)flange. A second O-ring is located on the opposite side of the tap in the vessel flange (See Figure 13R-08. 1). This line is required during plant operation and will indicate failure of the inner flange seal O-ring. Failure of the O-ring would result in a High Pressure Alarm in the Main Control Room.The configuration of this system precludes manual testing while the vessel head is removed. As figure 13R-08.1 portrays, the configuration of the vessel tap, combined with the small size of the tap and the high test pressure requirement (approximately 1045 psig), prevents the tap from being temporarily plugged. Also, when the vessel head is installed, an adequate pressure test cannot be performed due to the fact that the inner O-ring is designed to withstand pressure in one direction only. Due to the groove that the O-ring sits in and the pin/wire clip assembly (See Figure I3R-08.2), pressurization in the opposite direction into the recessed cavity and retainer clips would likely damage the 0-ring and thus result in further damage to the O-ring.5.0 BURDEN CAUSED BY COMPLIANCE:
Pressure testing of this line during the Class 2 System Leakage Test is precluded because the line will only be pressurized in the event of a failure of the inner O-ring. Purposely failing the inner O-ring to perform the Code Required test would require purchasing a new set of O-rings, additional time and radiation exposure to detension the reactor vessel head, install the new O-rings, and then reset and retension the reactor vessel head. This is considered to impose an undue hardship and burden on LaSalle County Station.Based on the above, LaSalle County Station requests relief from the ASME Section XI requirements for system leakage testing of the Reactor Vessel Head Flange Seal Leak Detection System.6.0 PROPOSED ALTERNATIVE AND BASIS FOR USE: A VT-2 visual examination on the Class 2 portion of the RPV Flange Leak Detection Line will be performed during each refueling outage when the RPV head is off and the head cavity is flooded above the vessel flange. The static head developed with the leak detection line filled with water will allow for the detection of any gross indications in the line. This examination will be performed each refueling outage as per the frequency specified by Table IWC-2500-1.

===7.0 DURATION===
OF PROPOSED ALTERNATIVE:
Relief is requested for the Third Ten-Year Inspection Interval for LaSalle County Station Units 1 and 2.Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-08 Revision 0 (Page 3 of 5)8.0 PRECEDENTS:
Similar relief requests have been approved for: LaSalle County Station Second Inspection Interval Relief Request PR-04 was authorized per SER dated July 3, 1996. The Third Inspection Interval Relief Request utilizes an identical approach as was previously approved.Susquehanna Steam Electric Station Third Inspection Interval Relief Request 3RR-07 was authorized per SER dated September 24, 2004.A lion Science & Technology LASO3.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: I3R-08 Revision 0 (Page 4 of 5)FIGURE 13R-08.1 FLANGE SEAL LEAK DETECTION LINE DETAIL Outer Flange Seal Ring-HMqh Pressure Leak Detection Monitoring Tap inne..r Flange Seal Ring See Detail "A" Detail "A" Vessel Flange Sectional View Alion Science & Technology LASO3.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: I3R-08 Revision 0 (Page 5 of 5)FIGURE I3R-08.2 O-RING CONFIGURATION SECTION A-A Alion Science & Technology L4S03.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-09 Revision 0 (Page 1 of 2)Request for Relief for Continuous Pressure Monitoring of the Control Rod Drive (CRD) System Accumulators In Accordance with 10 CFR 50.55a(a)(3)(i) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: 2 

==Reference:==

IWC-2500, Table IWC-2500-1 Examination Category:
C-H Item Number: C7. 10

== Description:==

Continuous Pressure Monitoring of the Control Rod Drive (CRD) System Accumulators Component Number: CRD Accumulators and Associated Piping 2.0 APPLICABLE CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.3.0 APPLICABLE CODE REQUIREMENT:
Table IWC-2500-1, Examination Category C-H, Item Number C7.10, requires all Class 2 pressure retaining components be subject to a system leakage test with a VT-2 visual examination in accordance with IWC-5220.
This pressure test is to be conducted once each inspection period.4.0 REASON FOR REQUEST: Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.As required by LaSalle County Station Technical Specifications, the CRD System Accumulator pressure must be greater than or equal to 940 psig to be considered operable.
The accumulator pressure is continuously monitored by system instrumentation.
Since the accumulators are isolated from the source of make up nitrogen, the continuous monitoring of the CRD accumulators functions as a pressure decay type test. Should accumulator pressure fall below 1000 psig (+/- 15 psig), an alarm is received in the control room. The pressure drop for the associated accumulator is then recorded in the control room log, and the accumulator is recharged by LaSalle County Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units I & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-09 Revision 0 (Page 2 of 2)Station procedure LOP-RD-20.
If an accumulator requires charging more than twice in a thirty day period, then a leak check is performed to determine the cause of the pressure loss. When leakage is detected, corrective actions are taken to repair the leaking component as required by LOP-RD-20.
Since monitoring the nitrogen side of the accumulators is continuous, any degradation of the examination performed once per inspection period would not provide an increase in safety, system reliability, or structural integrity.
In addition, performance of a VT-2 visual examination would require applying a leak detection solution to 185 accumulators per unit in an elevated dose rate area resulting in significant radiation exposure without any added benefit in safety. This inspection would thus not be consistent with ALARA practices.
Relief is requested from the VT-2 visual examination requirements specified in Table IWC-2500-1 for the nitrogen side of the CRD System Accumulators on the basis that LaSalle County Station Technical Specifications Surveillance requirements exceed the code requirement for a VT-2 visual examination.

===5.0 PROPOSED===
ALTERNATIVE AND BASIS FOR USE: As an alternate to the VT-2 visual examination requirements of Table IWC-2500-1, LaSalle County Station will perform continuous pressure decay monitoring in conjunction with Technical Specifications, 3.1.5.1 -Control Rod Scram Accumulators, Surveillance Requirements for the nitrogen side of the CRD Accumulators including attached piping.6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the Third Ten-Year Inspection Interval for LaSalle County Station Units 1 and 2.7.0 PRECEDENTS:
Similar relief requests have been approved for: LaSalle County Station Second Inspection Interval Relief Request PR-08 was authorized per SER dated June 28, 2002. The Third Inspection Interval Relief Request utilizes an identical approach as was previously approved.Alion Science & Technology LASO3.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-10 Revision 0 (Page 1 of 3)Request for Relief for Alternative Pressure Testing of the Safety Relief Valve (SRV)Automatic Depressurization System (ADS) Accumulators In Accordance with 10 CFR 50.55a(a)(3)(i) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: 2 

==Reference:==

IWC-2500, Table IWC-2500-1 Examination Category:
C-H Item Number: C7.10

== Description:==

Alternative Pressure Testing of the Safety Relief Valve (SRV) Automatic Depressurization System (ADS)Accumulators Component Number: SRV ADS Accumulators and Associated Piping 2.0 APPLICABLE CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.3.0 APPLICABLE CODE REQUIREMENT:
Table IWC-2500-1, Examination Category C-H, Item Number C7.10, requires all Class 2 pressure retaining components be subject to a system leakage test with a VT-2 visual examination in accordance with IWC-5220.
This pressure test is to be conducted once each inspection period.4.0 REASON FOR REQUEST: Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.As required by LaSalle County Station Technical Specifications, the SRV ADS Accumulator pressures are verified to be greater than or equal to 150 psig at least once every 31 days. Two compressors supply a continuous pressurization source to each of the seven accumulators required for the ADS function.
In addition, LaSalle County Station Technical Specifications verify that the ADS accumulator backup compressed gas system bottle pressures are greater than or equal to 500 psig at least once every 31 days.Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-10 Revision 0 (Page 2 of 3)LaSalle County Station technical surveillances LTS-500-18 for Unit 1 and LTS-500-19 for Unit 2 perform operability testing of the main steam safety relief valves including the seven relief valves and accumulators per unit that are required to provide automatic depressurization (ADS). One specific pressure test that these procedures perform is a pressure decay test of the accumulators and associated piping and valves. The maximum pressure drop allowed for this test is 5 psig / 2 hours. If this criteria is exceeded, appropriate troubleshooting is performed including soap-bubble application to locate leakage.Since the accumulator pressures are verified once every 31 days and a pressure decay test is performed every 18 months, any degradation of the accumulator would be detected by normal Technical Specifications surveillance requirements.
A separate VT-2 visual examination performed once per inspection period would not provide an increase in safety, system reliability, or structural integrity.
In addition, performance of a VT-2 visual examination would require applying a leak detection solution to seven accumulators per unit, plus associate valves and piping, in an elevated dose rate area with limited access (drywell -777') resulting in significant radiation exposure without any added benefit in safety. This inspection would thus not be consistent with ALARA practices.
Relief is requested from the VT-2 visual examination requirements specified in Table IWC-2500-1 for the SRV ADS Accumulators on the basis that LaSalle County Station Technical Specifications Surveillances require a pressure decay test essentially twice per period which provides an acceptable level of quality and safety that exceeds the normal code requirements.

===5.0 PROPOSED===
ALTERNATIVE AND BASIS FOR USE: As an alternate to the VT-2 visual examination requirements of Table IWC-2500-1, LaSalle County Station will verify the ADS Accumulator pressure per LaSalle County Station Technical Specifications 3.5.1 and will also perform pressure decay testing on the ADS Accumulators and associated piping and valves in accordance with surveillance procedure LTS-500-18 for Unit 1 and LTS-500-19 for Unit 2.6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the Third Ten-Year Interval of the Inservice Inspection Program for LaSalle County Station Units 1 and 2.A lion Science & Technology LASO3.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-10 Revision 0 (Page 3 of 3)7.0 PRECEDENTS:
Similar relief requests have been approved for: LaSalle County Station Second Inspection Interval Relief Request PR-10 was authorized per SER dated June 28, 2002. The Third Inspection Interval Relief Request utilizes an identical approach as was previously approved.Alion Science & Technology LASO3.G03 Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-11 Revision 0 (Page 1 of 3)Request for Relief for Hardship Or Unusual Difficulty Without Compensating Increase In Level Of Quality Or Safety for Hydrogen Recombiner System Piping In Accordance with 10 CFR 50.55a(a)(3)(ii) 1.0 ASME CODE COMPONENTS AFFECTED: Code Class: 2 

==Reference:==

IWC-2500, Table IWC-2500-1 Examination Category:
C-H Item Number: C7.10

== Description:==

Hydrogen Recombiner System Piping Component Number: HG Unit Cross-Tie Piping 2.0 APPLICABLE CODE EDITION AND ADDENDA: The Inservice Inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 2001 Edition through the 2003 Addenda.3.0 APPLICABLE CODE REQUIREMENT:
Table IWC-2500-1, Examination Category C-H, Item Number C7.10, requires all Class 2 pressure retaining components be subject to a system leakage test with a VT-2 visual examination in accordance with IWC-5220.
This pressure test is to be conducted once each inspection period.4.0 REASON FOR REQUEST: Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is requested on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.Hydrogen Recombiner System Piping is depicted on page 3 in Figure 13R- 11.1.IWC-5210(b) of the Code states that: When gas is the pressurizing medium, the test procedure shall include methods for detection and location of through-wall leakage. The performance of a Flow Make-up pressure test on unit cross-tie piping would include boundary valves that are not subject to Appendix J Testing, therefore some small amount of seat leakage is likely. If such leakage did occur, application of a leak detection solution to the entire surface of the cross-tie piping would be required in order to ensure no through wall-leakage existed. This would result in undo hardship due to the long runs Alion Science & Technology LASO3.G03 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: I3R-11 Revision 0 (Page 2 of 3)of unit cross-tie piping located high in the overhead.
An estimated 600 man hours and accumulated dose of 1.25 Rem would be required to erect scaffolding and perform a leakage test of the cross-tie piping. Further, scaffolding would have to be erected around several sensitive instrument racks and systems that if jarred could result in a unit trip or other challenges to the operators.
The Hydrogen Recombiners, including the unit cross-ties, are functionally tested every refuel outage to verify system temperature, pressure, and flow requirements are met to ensure operability.
In addition, the system is tested to the requirements of 10 CFR 50 Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors" as well as to the LaSalle County Station IST Program to insure operational readiness.
The frequency at which the above mentioned tests are performed exceeds those required by Table IWC-2500-1.As such, relief is requested from the VT-2 visual examination requirements specified in Table IWC-2500-1 for the Hydrogen Recombiner System unit cross-tie piping.5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE: The Hydrogen Recombiner System will be Pressure Tested and VT-2 visually examined once per period as specified in Table 1WC-2500-1, with the exception of the unit cross-tie piping (from 1HGO02B valve to 2HGO02A valve, from 1HGO02A valve to 2HGO02B valve, from 1HG009 valve to 2HGO06B valve, and from 1HGO06B valve to 2HG009 valve.) However, if any through-wall leakage is detected during these tests, additional Pressure Testing shall be performed on unit cross-tie piping to the extent specified in Table IWC-2500-1.

===6.0 DURATION===
OF PROPOSED ALTERNATIVE:
Relief is requested for the Third Ten-Year Inspection Interval for LaSalle County Station Units 1 and 2.7.0 PRECEDENTS:
Similar relief requests have been approved for: LaSalle County Station Second Inspection Interval Relief Request PR-12 was authorized per SER dated October 6, 2000. The Third Inspection Interval Relief Request utilizes an identical approach as was previously approved in the Second Inspection Interval.Alion Science & Technology LASO3. G03 Alion Science & Technology LAS03. GO3 ISI Program Plan LaSalle County Station Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST: 13R-11 Revision 0 (Page 3 of 3)Fi2ure 13R-11.1 1HG026 Alion Science & Technology L4S03. GILl Alion Science & Technology LASO3.G03}}