ML20217M638

Provides Response to NRC 980317 RAI Re Application for Amend to Licenses NPF-11 & NPF-18,adding Ventilation Filter Testing Program.Rev 2 to Calculation L-001166, Post LOCA CR Auxiliary Electric Equipment Room & Offsite Dose, Encl

ML20217M638
Person / Time
Site:	LaSalle
Issue date:	05/01/1998
From:	Dacimo F COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217M645	List: ML20217M638 ML20217M661 ML20217M667
References
NUDOCS 9805050074
Download: ML20217M638 (13)

Text

Commonwraith I'diwn Company (Nile deneratmg Nation -!

2(ol North Jlst Road l Marwilles, 11.013616757 TelMi53%7 6 %I I

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l May 1,1998 I United States Nuclear Regulatory Commission

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Attention: Document Control Desk )

Washington, D.C. 20555 {

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Subject:

_ LaSalle County Nuclear Power Station Units 1 and 2 l Supplement to Application for Amendment of Facility )

Operating Licenses NPF-11 and NPF-18, Appendix A, l Technical Specifications, Addition of a Ventilation Filter l Testing Program  !

NRC Docket Nos. 50-373 and 50-374

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Reference:

See Attachment B 4 Pursuant to 10 CFR 50.90, Commonwealth Edison Company (Comed) submitted an Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18, Technical Specifications, Addition of a Ventilation Filter Testing Program, Reference (a). During the NRC review of the submittal, the NRC staff determined that eleven questions needed to be answered to complete their review and this Hequest For Additional Information (RAI) was provided via the Reference (b) letter. The response to question five of the i RAI was provided in the Reference (c) letter. The purpose of this letter is to i supplement the Reference (a) letter by providing the attached response to

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the remaining ten RAI questions.  :

Attachment A provides the response to the RAI questions.

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' Attachment B provides the list of referenced documents. l l

9805050074 980501 nU oO\

PDR ADOCK 05000373 P PDR A iinicom rumpan>

Attachment C provides; (a) Calculation 01166, Rev. 2, " Post LOCA Control Room, Auxiliary Electric Equipment Room, and Offsite Doses" and (b) GE Input Data contained in the D. Grim to G. Lahti letter dated January 16,1998.

Attachment D provides the marked-up Technical Specifications pages for LaSalle Units 1 and 2 with the requested changes indicated.

This proposed amendment supplement has been reviewed and approved by Comed Onsite and Offsite Review.

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

The original Significant Hazards Consideration and Environmental Assessment in the Reference (a) letter remain valid.

If there are any questions or comments conceming this letter, please refer them to Harold D. Pontious, Jr., Regulatory Assurance Manager, (815) 357-6761, extension 2383.

Respectfully, c)W t

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Fred Dacimo Site Vice President LaSalle County Station Attachment cc: A. B. Beach, NRC Region Ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle F. Niziolek, Office of Nuclear Facility Safety - IDNS

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l L STATE OF ILLINCIS )

l Docket Nos. 50-373 50-374 IN THE MATTER OF . )

COMMONWEALTH EDISON COMPANY )

LASALLE COUNTY STATION - UNITS 1 & 2 )

AFFIDAVIT l affirm that the content of this transmittal is true and correct to the best of my knowledge,information and belief.

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Fred R. Dacimo Site Vice President LaSalle County Station Subscribed and swom to beforege, a Notary Public in and for the StatAabove named, this ./ day of WWa#_ . If 9 7. My Commission expires on 0 to-t . Acco .

OFFICIAL SEAL DEBRAJ.FEENEY h bo -

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w A1 - NOTARY PUBUC, STATE OF ILUNOIS MMISS10N EERESM2M Nothry Public

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i ATTACHMENT A - RESPONSE TO RAI QUESTIONS l Question 1 The scaling factors to adjust the main steamline isolation valve (MSIV) leakage contribution to I control room operator dose for the changes made to the ventilation systems were calculated as the ratios of the Murphy-Campe iodine protection factors (IPFs) of the new over old designs.

Provide the IPFs and scaling factors used for the design basis case identified and demonstrate that these result in conservative and bounding doses.

Response

Comed /S&L determined that the scaling factors from GE's dose from MSIV leakage contribution (used for MSIV Leakage Control Removal) may not provide conservative values. So, GE was requested to provide specific values for the MSIV leakage contribution. These new inputs from GE were used in the latest revision of dose calculation L-001166, Rev. 2 (Attachment C includes Rev. 2 of the calculation and GE input data used to perform the calculation).

Question 2 Calculation L-001166 assumes that the concentration of unfiltered (Auxiliary Building air) inleakage into the control room is the same as the concentration of air at the control roorn ventilation system intakes. Calculation L-001166 also assumes that the MSIV leakage released from the condenser into the Turbine Building is released directly into the environment from the Turbine Building. If air flows from the Turbine Building into the Auxiliary Building during the design basis loss-of-coolant accident (DBLOCA), then the concentration of the unfiltered inleakage may be greater than the concentration of air at the control room ventilation system intakes. What is the basis for assuming that this flow path will not exist?

Response

The Auxiliary Building is adjacent to the Turbine Building and there are openings designed to allow flow from the Auxiliary Building to the Turbine Building during normal operation. The flow direction, exists because the Turbine Building is maintained at a pressure slightly below atmosphere and the ventilation systems serving the Auxiliary Buileling maintain the building at or above atmospheric pressure. The alignment of the ventilation sy;tems serving in the Auxiliary Building and the Turbine Building, except VC and VE, would not change as a result of a DBLOCA but they would following a LOOP (Loss of Off-Site Power).

Following a LOOP the only ventilation systems that would continue to operate in the Turbine Building or Auxiliary Building would be the Switchgear Ventilation (VX) and the Control room and Auxiliary Electric Equipment HVAC ( VC & VE) systems, all of vdich are located in the Auxiliary Building. These systems combined would supply 7,000 to 20,000 cfm of outside air, drawn in from the Auxiliary Building roof to the Auxiliary Building. With no systems operating in the Turbine Building the excess air in the Auxiliary Building would flow into the Turbine Building.

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i ATTACHMENT A - RESPONSE TO RAI QUESTIONS Question 3a Calculation L-001166 assumes that the DBLOCA is the bounding accident for control room I habitability . The main steamline break (MSL) and rod drop accidents also produce significant releases to challenge control room habitability. What is the basis for assuming that the DBLOCA is bounding ?

I Response: l Section 7.3 of the attached Calculation L-001166, Rev.2 (Attachment C) provides the response to j this question. i Question 3b j I

Does the MSL accident analyzed in the Updated Final Safety Analysis Report (UFSAR) take  !

credit for any filtration?

Response

No credit for any filtration is included. UFSAR Table 15.6-6 lista the activity (curies) released to the environment for " Design (NRC) Basis" conditions. This table may be reproduced from the ,

product of mass release of steam and water (14,000 pounds and 86,000 pounds, respectively)

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(UFSAR, page 15.6-11) and the coolant iodine concentrations, also on UFSAR, page 15.6-11. No 1 reduction due to any filtration is included in determining the release to the environment.

Question 3c ,

if the MSL accident were to occur with reactor coolant activity at the peak Dose Equivalent lodine-131 value allowed by Technical Specifications (TS), would the DBLOCA still be the bounding I accident for control room habitability?

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Response

Section 7.3 of the attached Calculation L-001166, Rev.2 (Attachment C) provides the response to j this question. I i

Question 4 j j Regulatory Guide (RG) 1.3 states that assumption of an elevated release is only appropriate if the j l stack is 2.5 times as high as any building that impacts the plume. LaSalle's stack is j approximately 2 times as high as the reactor building. Provide a justification for assuming an {

elevated release, contrary to the guidance in RG 1.3. j 1

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I ATTACHMENT A - RESPONSE TO RAI QUESTIONS l

Response

An elevated release had been assumed through the development ei be LaSalle stack design and was approved and/or reviewed on numerous occasions by the NRG. Statements in the NRC SER (NUREG 0519) indicate that the NRC was clearly aware of the stack height and approved Comed actions consistent with that understanding. Prior to SER approval, the PSAR, FSAR, and Environmental Statement provided NRC concurrence and approval. Thus, LaSale's current licensing basis justifies the use of an elevated release for LaSalle. Listed below is the history of LaSalle's stack design and associated NRC concurrence and approval.

Stack Design History 11/3/70. PSAR and Application filed. Station design included a free standing 300 ft. tall chimney (separate from the plant structures) which would handle SJAE and SGTS effluents. All other plant ventilation air would be discharged through a short stack on the reactor building. This configuration is shown in the NRC's Final Environmental Statement of February 1973.

1971 to 1973. Rulemaking on what would become Appendix 1 to 10CFR50. The emphasis on doses due to normal releases of radioactivity and effluent monitoring requirements led to the design change of replacing the original two release points by a single release point.

10/11/73. This design change was discussed at a meeting with the NRC. The design was presented as being a " tall" stack, two (2) times the reactor building height. Its physicallocation is atop the auxiliary building adjacent to the reactor building. This new stack would be a class I structure and would provide significant reduction in calculated doses due to it being an elevated release. The AEC received this proposal well and agreed it was an improvement over the PSAR design. A PSAR Amendment detailing the design change was requested.

4/9/74. Amendment 14 to the PSAR included "Special Report No.1" which addressed details of the stack design. Figure 1 of this report shows the stack,18.5 feet in diameter and 370'-0 above grade.

4/3/75. The NRC letter of 4/3/75 to Commonwealth Edison states "Special Report No.1, Common Exhaust Stack has been reviewed by our staff and we find the proposed modifications described in this report to be acceptable."

1/7/75., While the 370'-0 tall,18.5' diameter stack was being reviewed (and ,being found acceptable) the engineering design was continuing to be scrutinized. It was realized that if the SGTS was operating at its design flow (4000 cfm) and discharging into an 18.5' diameter stack, the discharge velocity would be extremely low if the non-safety-related station ventilation systems were not running. This scenario offers the possibility of stack downwash under accident conditions, negating the benefit of the elevated release. A design change was recommer.ded (S&L letter,1/7/75) to include a separate 24-inch diameter pipe within the large stack; this 24-inch pipe would handle only the SGTS effluent. The pipe would extend one foot above the top of the

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main stack. The exit velocity for SGTS discharge would be 1270 fpm [UFSAR 6.5.1.1.1) and should be sufficient to ensure the release being elevated under accident conditions.

8/31/76. To the best of our knowledge, the 24-inch SGTS pipe never made an entry into the PSAR, but was included in the initial FSAR tendered 8/31/76. The design details in section 11.3.3 and Figure 11.3-2 are unchanged from their original submittal. These include a depiction of both the main stack and the SGTS stack. Similar information is included in the UFSAR, Appendix 1, which addressed the stations response to Appendix 1 to 10CFR50 questions.

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ATTACHMENT A - RESPONSE TO RAI QUESTIONS l

12/76. The NRC asked several questior s regarding the station's gaseous effluent release points

[321.2,321.4,372.22] and responses were provided in the acceptance review edition of the FSAR  !

(12/76). The responses referred the reviewers to FSAR Appendix I which con;ained details of the l vents. No questions specifically addressed the SGTS vent pipe.

11/78. NRC issued NUREG 0486," Environmental Statement Related to Operation of LaSalle County Nuclear Power Station Unit Nos.1 and 2*. Page 2-17 of Environmental Statement says,

" Releases from the station vent stack were considered as elevated".

3/81. The NRC'r, Safety Evaluation Report NUREG-0519 (3/81), in Table 2.2 provides X/O values consistent with accepting the LaSalle release point as being an elevated one for accident assessments. -

1 Additionally, RG 1.3 uses the word "Should* in regards to the 2.5 times stack requirement. The l use of the word "Should" as opposed to "Shall* implies that alternate requirements may be acceptable, which is the situation for LaSalle as described by the above mentioned NRC I approvals.

Question 5 The term "in general conformance with" in proposed TS 6.2.F.8, " Ventilation Filter Testing ,

Program" implies that portions of these standards will not be met. Please clarify.

Response

This question was previously answered by the Reference (c) letter. i l

Question 6 j l

Your submittal states that proposed TS 6.2.F.8, " Ventilation Filter Testing Program" is consistent i with the requirements in NUREG-1434, " Standard Technical Specifications, General Electric  !

Plants, BWR/6". TS 5.5.8.d in NUREG-1434 requires demonstration for each of the ESF systems  ?

that the pressure drop across the HEPA filter, prefilters and charcoal adsorbers is less than the value specified. The purpose of this test is to ensure that the fan is capable of supplying the TS t required flow rate with the loading on the filter components that is expected to occur during the course of the accident. Since the CRRF and AEERRF are parts of the ESF systems that are  ;

relied on in the dose analysis, this test is required for these filters as well. Provide a basis for not j including pressure drop tests for the CRRF and AEERRF in the proposed TS.

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The staff typically uses a pressure drop of 2 inches water gage for each component (prefilter, j HEPA filter, and 2 inches of charcoal)in the filter housing. Since the CRRF and AEERRF i recirculation housings at LaSalle have a prefilter and a 2 inch charcoal filter bed, they should be tested for a maximum pressure drop of 4 inches water gage. Can the CRRF and AEERRF fans at  !

LaSalle supply the TS required flow rate with a 4 inch water gage pressure drop across the l pref 9ter and charcoal filter? If not, what is the maximum pressure drop across the prefilter and l charcoal filter at which the CRRF and AEERRF fans can still supply the TS required flow rate and l what is the ba is for this maximum pressure drop?

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l ATTACHMENT A - RESPONSE TO RAI QUESTIONS i

Response

The proposed wording of TS 6.2.F.8 Ventilation Filter Testing Program" has been revised to include testing of the pressure drop across the prefilter and charcoal filter for the Control Room Recirculation Filter (CRRF) and Auxiliary Electric Equipment Room Recirculation Filter (AEERRF) units.. The proposed revisions to the Technical Specification pages are included in Attachment D .

to this letter. During the review of this change it was identified that the upper flow limit for the AEERRF was limiting. The revised flow values are also included in TS 6.2.F.8.b and TS 6.2.F.8.d.

The specific changes are also provided below.

TS 6.2.F.8.d ESF Ventilation Filter System Delta P (inches wg) Flowrate (cfm)

CRRF System 3.0 >=18000 and <= 28900 AEERRF System 3.0 >=14000 and <= 22800 TS 6.2.F.8.b ESF Ventilation System Penetration and System Flowrate (cfm)

Bypass AEERRF System 2.0 % a 14000 and s 22800 The generic use of a 2 inch pressure drop (cP) across each ESF filter component is not appropriate in this application. UFSAR tables 9.4-1 and 9.4-3 provide the design dP across the CRRF and AEERRF components. For the prefilters, the clean dP is 0.35 inches and the dirty dP is 1.0 inch. The dP across the prefilters increases over time as the filter loads with dirt. A review of work history showed that the prefilters take about 4 to 5 years to load to the point that they need to be replaced. For the charcoal filter, the dP is 1.9 inches and the dP remains essentially

. the same over time.

Recent testing of the VC system has shown that the fans could supply more than 18,000 cfm with a simulated prefilter dP of 1.1" wg and the charcoal filter on-line for combined prefilter and charcoal dP of approximately 3.0 inches wg. The VE system has not been tested in the same way because it is not available, however the modifications being made to the system will ensure that the system will operate at greate.'than 14,000 cfm with a dP of 3.0 inches wg. For the VC and VE systems a pressure drop of greater than 3.0" wg will be simulated across the combined prefilter and adsorber and the flow through the filter will be verified to be greater than the TS minimum. This will be done prior to declaring the VC and VE systems operable.

The change in the upper limit for the AEERRF filter from the previously proposed flow of 19,900 l

cfm to 22,800 cfm is being made to allow for improvements in system flow due to the addition of a new duct run feeding the AEER. This modification was conceived after the original submittal

[ reference a) and the significance of the improvement in system flow was not recognized until the t

recently completed system pressure drop calculation was reviewed in preparation for testing.

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ATTACHMENT A - REEPONSE TO RAI QUESTIONS This new flow, of 22,800 cfm, is less than the original design flow of 31,300 cfm and the associated face velocity of 80 fpm, therefore the use of 80 fpm is conservative. In addition calculation L 001166 revision i shows that as recirculation flow is increased the dose in the AEER will be reduced.

Question 7 SR 4.7.2.a.1 should be revised to specify the filters for which this surveillance applies.

Response

The proposed wording of SR 4.7.2.a.1 has been revised. The revised Technical Specification pages are included in Attachment D to this letter.

Question 8 TS 3.7.2 Bases states that:

" Cumulative operation of the system with the heeters OPERABLE for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters."

This statement should be modified to specify that the system is run continuously for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

Response

The proposed wording of SR 4.7.2.a.1 and TS 3.7.2 Bases have been revised. The revised Technical Specification pages are included in Attachment D to this letter.

Question 9 The tracer gas test that was performed in 1996 found 500 cfm of unfiltered inleakage in the control room for only one train and 1200 cfm and 2900 cfm of unfiltered inleakage in the auxiliary electric equipment room for each train.

A. Was this test determining the integrity of the control room envelope by measuring unfiltered inleakage for the control room envelope or was this test determining the integrity of the ductwork by measuring the inleakage into the ductwork? l' B. Which tracer gas test method was used (Concentration Decay, Concentration Buildup / Steady State, or Buildup / Decay)?

C. How were the other inleakages (g1 and g3 in calculation L-001166) determined?

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ATTACHMENT A - RESPONSE TO RAI QUESTIONS

Response

A. The tracer gas testing done in 1996 as well as that committed Q on page A-23 of the Reference (a) submittal are tests to determine duct inleakage.

1 B. The tracer gas test method is constant injection, technique number 2, per ASTM E 741-95, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas I Dilution".

C. Inleakage value g1 consists of CREF unit housing inleakage test results and calculated fan shaft leakage. The filter housing inleakage was determined by the pressure dccay method. The test results are summarized on the table below. ' The fan shaft inleakage was determined to be no greater than 50 cfm by calculation. This calculation was based on the existing gap between fan shaft and fan housing. Using the maximum housing inleakage, from the table below, and the calculated fan shaft leakage, provides a total inleakage of 55.2 cfrn for value 91.

Inleakage value g3 is bad on the CRRF and AEERRF unit housing inleakage test results. The test results are summarized in the table below. For the CRRF train the maximum housing l inleakage provides in an inleakage of 7.0 cfm for value g3. For the AEERRF train the maximum j housing inleakage provides an inteakage of 6.0 cfm for value g3 l

"A" Train 'B' Train CR5F 5.2 cfm @ 7"wg 3.1 cfm @ 7"wg CRRF 6.6 cfm @ 6"wg 7.0 cfm @ 6'wg AEERRF 5.9 cfm @ 6"wg 4.1 cfm @ 6"wg Question 10  :

What would be the effect in the control room and auxiliary electric equipment room of a fire in the Auxiliary Building, taking into consideration the increased amount of unfiltered inleakage into these rooms?

Response

The ductwork on the control room HVAC system (VC) that leaks is located at the elevation above the control room in fire zone 48. The smoke from a fire in this area could leak into th<s VC retum duct and then into the control room itself. Smoke or products of combustion in the control room or return duct will trip the return duct smoke detectors. This will automatically place the recirculation charcoal filter on-line and the recirculation filter will absorb smoke and odors (ref UFSAR 6.4.4 para.4). The operator may also place the VC system into the purge mode which introduces 100% outside air into the control room. In the purge mode all of the air leaving the control room is vented to atmosphere, eliminating the source of the inteakage and any effects of smoke entering the control room in addition, three breathing air sub systems are provided in the control room, each of which will provide a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of breathing air for each user, The ductwork on the Auxiliary Electric Equipment Room HVAC system (VE) that leaks is located at the elevation above the control room in fire zone 48, in three duct chases and in fire zones 4E3 and 4E4 (unit 1 and 2 division 2 switchgear rooms adjacent to the AEER). The automatic alignment of the recirculation Zer would occurin the same manner as on the VC system. The use of the purge mode could be initiated if needed.

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ATTACHMENT A - RESPONSE TO RAI QUESTIONS

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The initiation of the recirculation filter, along with operating the VC and/or VE systems in the purge mode, eliminates any potential effects on the control room or auxiliary electric equipment room l due to a fire in the Auxiliary Building.

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l l Question 11 (part 1) l What effect does the 1200 cfm unfiltered inleakage have on control room habitability during a toxic chemical release?

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Response

The 1200 cfm of inleakage will not result in any additional control room habitability issues related to a toxic chemical miease. From an overall perspective, the 1200 cfm of inleakage would be introduced into the control room ventilation system through the negative pressure ductwork on the 786' elevation of the Auxiliary Building. The toxic gas release events occur outside of the Auxiliary Building Thus, the initial concentration of toxic gas in the Auxiliary Building would be zero and build up over time, similar to the control room. At all times, the concentration of toxic gas in the Auxiliary Building would be significantly less than the concentration of toxic gas that would be drawn directly into the control room from the outside. Considering this dilution effect of the toxic gas within the Auxiliary Building, the time required to build up the Auxiliary Building toxic gas levels along with the short timo frame being considered, two minutes from detection (reference RG 1.78), it is concluded that in comparison to 1500 cfm of air directly drawn in from the environment, the 1200 cfm of inleakage would have a minimal impact on the concentration of toxic gas in the control room. Thus for any toxic gas release, the 1200 cfm of inleakage would have only a smallimpact on the control room habitability evaluations. The following paragraphs provide specific details for the ammonia and chlorine releases.

For the specific case of anhydrous ammonia, Comed performed an analysis to evaluate the realistic aggregate probability of causing uninhabitable conditions in the control room as a result of an accidental release of anhydrous ammonia (Supplement 1 to Revision 5 of Document Titled

" Habitability of the LaSalle County Station Control Room Following Postulated Accidents involving Shipments of Anhydrous Ammonia in the Vicinity of LaSalle County Station" included in Reference d). Based on this analysis, it was concluded that the aggregate probability was sufficiently low such that the postulated ammonia spill accident would not be a design basis event. A review of this evaluation showed that two scenarios, barge traffic release and a release at Seneca Port Authority, considered dispersion analyses to form the basis of the realistic probabilities. Inleakage

was not a parameter considered in these analyses. In these events, the results of the dispersion analyses resulted in toxic gas concentrations (Seneca Port Authority - 79.4 ppm, barge traffic -6.6 ppm) in the control room being less than the toxic limit of 100 ppm and thus the realistic probabilities of causing uninhabitable conditions in the control room were concluded to be negligible. Based on the discussion of the first paragraph and the margins that exist between the resultant concentration and the toxic gas limit, the consideration of 1200 cfm of inleakage from the Auxiliary Building would not result in an increase in the control room above the toxic limit. Thus the conclusion that the realistic probability would be negligible remains valid and the 1200 cfm of inleakage will not change the toxic gas evaluation.

For chlorine, the removal of the chlorine detectors was accepted by the NRC, (reference f), based upon the following: distance of chlorine barge traffic from the station was nearly 5 miles; the very low frequency of chlorine barge shipments; and the elevation of the station combined with the settling effects of chlorine. Thus the likelihood of lethal concentrations of chlorine were Page 8 of 9

ATTACHMENT A - RESPONSE TO RAI QUESTIONS considered not credible. The makeup rate for the control room was not a parameter in this evaluation and thus the effect of the 1200 cfm additionalinleakage is not applicable.

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Question 11 (part 2)  !

i Have the shipping pattems of toxic gasses within five miles of the LaSalle station changed since the issuance of safety evaluations in 1986 and 1989?

Response: l l

The NRC staff had previously approved the removal of the chlorine detector monitoring system (reference f) and the ammonia detector monitoring system (reference e) from the LaSalle Technical Specification (T.S.).

' As a condition for deleting Chlorine detection, LaSalle station committed to perform a surveillance on a 3 year frequency to determine changes in patterns of chlorine shipment and to identify any

- new chlorine sources within 5 miles of the station (reference h). The last surveillar"e performed in late 1997 indicated that there are no shipping pattem changes in chlorine from the initial survey used to request 'he T.S. amendment.

LaSalle has not surveyed the shipping patterns of ammonia since the survey done to support the l TS change approved by the NRC (reference e). As a condition for deleting the automatic isolation l function for Ammonia detection, LaSalle station committed (reference g ) to have ammonia j detection instruments operable in the manual mode to provide indication to the station personnel.

There are administrative means in place, by which LaSalle station is notified in a timely manner by the LaSalle County Emergency Services and Disaster Agency of any incident related to ammonia. i LaSalle stat;on lease agreements with farmers prohibit the use or transportation of anhydrous ammonia on LaSalle station property. There was no requirement in the SER, which authorized the elimination of the ESF actuation for ammonia, to perform surveillance's to identify changes in I shipping patterns for ammonia. '

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j ATTACHMENT B (References) )

l (a) W. Subalusky to U.S. NRC letter dated September 26,1997, Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18, ,

- Technical Specifications, Addition of a Ventilation Filter Testing Program (b) D. Skay to O. Kingsley letter dated March 17,1998, Request For Additional Information - LaSalle County Station, Units 1 and 2 (TAC Nos.

M99726 and M99727) -

' (c) - F. Dacimo to U.S. NRC letter dated April 7,1998, Supplement to l Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18, Technical Specifications, Addition of a Ventilation Filter Testing Program (d) C. Allen to U.S. NRC letter dated 3/9/1988, Supplement to Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18, -

Technical Specifications, Ammonia Detection System  ;

(e) P. Shemanski to H. Bliss letter dated 1/18/1989, issuance of Amendment No. 61 to Facility Operating License No. NPF-11 and Amendment No. 42 to Facility Operating License No NPF-18 (TAC NOS. 64849 and 64850),

Revise Technical Specifications to Remove Ammonia Detector Monitoring Instrument System.

(f) E. Adensam to D. Farrar letter dated 4/11i1986, issuance of Amendment No. 38 to Facility Operating License No. NPF-11 and Amendment No. 20 to Facility Operating License No. NPF-18, Revise Technical Specifications to Eliminate Chlorine Detector Monitcring Instrument System.

i (g) W. Morgan to P. Shemanski letter dated 1/6/1989 Supplement to Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18, Technical Specifications, Ammonia Detection System (commitmerit keep alarm function of ammonia detectors inplace.)

(h) C. Allen to H. Denton letter dated 3/5/1986 Supplemental Information for Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18, Technical Specifications, Chlorine Detection System (commitment to perform a surveillance on a 3 year frequency to determine changes in patterns of chlorine shipment and to identify any new chlorine sources within 5 miles of the station)