ML20116E843

Application for Amend to License NPF-18,proposing Emergency Change to TS Table 3.6.3-1, Primary Containment Isolation Valves, in Ref to 921029 Request for Temporary Waiver of Compliance from TS 3.6.3,Action a.2

ML20116E843
Person / Time
Site:	LaSalle
Issue date:	11/02/1992
From:	Shields J COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20116E846	List: ML20116E843 ML20116E849
References
NUDOCS 9211100046
Download: ML20116E843 (8)

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Commonw:alth Edison LaSalle Couny fJuclear Station 2001 f J. 21st. Rd.

lAarseilles, tilinois 01341 10 CFR 50.90 Telephone 015!357-0701 November 2, 1992 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulet!on U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Dorument Con il Desk

Subject:

LaSi a County Station Unit 2 Emergency Roquest to Amend Facility Operating License N?F-18, Appendix A, Technical Specifications HEC _J2R ket No. 50-374 Refercncess (a) October 29, 1992 letter from J. Shields to Dr. Murley, Requesting Temporary Waiver of Compliance (TWOC) from Technical Specification 3.6.3 action a.2 (b) October 30, 1992 letter from R. Barrett to T. Kovach, Approval of Temporary Waiver of Compliance from Technical Specification 3.6.3 action a.2

Dear Dr. Murley,

In Reference (a), Commonwealth Edison (CECO) requested a Temporary Walver of Compliance from Technical Specification 3.6.3 action a.2 due to a nonconservative 10 CFR 50 Appendix J Type C test performed on the Reactor Water Cleanup Return to Feedwater Valve, 2G33-F040. Reference (b) provided the NRC's approval of the TWOC. As discussed in Reference (a), CECO committed that an Emergency Technical Specification Amendment Request would be transmitted to NRR no later than November 4, 1992. This document fulfills that commitment. The TWOC will remain valid until approval of the Emergency Technical Specification Amendment.

Technical Specification Table 3.6.3-1, Primary Containment Isolation Valves, is requested to be amended to add a footnote to valve ?G33-F040 stating that for the remainder of Cycle 5, or until t.1 first outage in which the unit is in Cold Shutdown for two weeks or greater duration, the 10 CFR 50 Appendix J Type C test is ot required to be current for the 2G33-F040 valve, and its leakage is not required to be included in the total 10 CFR 50 Appendix J Type B sad C leakage specified by Specific % tion 3.6.1.2.b.

The proposed Emergency Technical Specification amendment request is subdivided as follows:

1. Attachment A provides a deteription and evaluation of the proposed changes.

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2. Att achtnent D Includes the marked-up Technical Specificatlon pages.

3. Attachment C describes CECO's evaluation performed in accordance with 10 CrH $0.92(c), which confirms that no significant hazards consideration is involved.

4. Attachment D provides the Environmental Assessment.

5. Attachment E provides additional support material which will aide in

• the review of the proposed amendment request. '

This proposed amendment has been reviewed and approved by CECO On-Site and Off-Site Review in accordance with Commonwealth Edison procedures.

Commonwealth Edison is notifying the State of Illinois of this applicatlor, for amendment by transmitting a copy of thic letter and its attachments to the designated state official.

To the bent of my knowledge and belief, the statements contained within are true and correct. In some respect these statement.s are not based on my personal knowledge, but obtained-information furnished by other Commonwealth Edison employees, contractos employees, and consultants. Such information hos been reviewed in accordance, with company practice, and i bo11 eve it to be rollable.

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Please direct any questions you may have concerning this submittal to this office.

Respectfully, f

Y jf d Jo Ann M. Shields

• Nuclear Licensing Administratoc A ..t achments : ,

A. Description and Evaluation of the Proposed Changes D. Marked Up Technical Specification Pages C. Evaluation of Significant Hazards Consideration-D. Environmental Assessment

! E. Additional Support Information l

cc: A.B. Davis, Regional Administrator - Rill D.L. Hills, Senior Resident Inspector - LSCS

• B.L~. Slegel, Project Manager - NRR Office cf Nuclear Facility Safety - IDNS Subscribed and sworn t o bofe re me this 02 day of / ,

Noa?mber of 1392 % 9 , 6 s-'j&a% W X b?d( j _y Q Ms?lv;

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(OFFICIAL SEA [.

LYNN ELLEN GASSMt N NOTARY PUBUC, STATE OF !WNOU

! l l ':MY COMMISSON EXPIRES n M4e t

i ATTACID4ENT A

! Deocript lon and Evaluation of Proposed Change to Appendix A, Technical SpecifIcatit of Facility Operating bicense NPF-18 De r, cIl pti o n_.o L1he_h opos elfhange Thin amendment request proposes an emerger,cy change to the Technical fipecification concerning Oe Primary Containment Isoletion Valve _ 2033-F040.

The current Technical Spect!!cution requires that the 2G33-F040 ' be OPERABbE, which includes all required surveillances to be current in Operational Condiilons 1, 2 and 3. This amendment request will allow baSalle Unit 2 to continue operat.ing until the end of fuel cycle 5, or until the first outage in

< which the unit is in Cold Shutdown for . : o weeks or greater duration.- The arnendment request is requi reto because the anost recent 2G33-F040 Type C bocal Look Rate Test results are potentia]Iy nonconservative because the vent path for 2033-F040 was separated by check valve 2 0 ' 3.-F0 3 9 from the leak rate test boundary ulve. The Walver of Compliance submitted October 29, 1992 (approved Octobe 30, 1992) grants continued operation of baSalle _ Unit 2 until this.

amendment request is approved.

DescIlptiottof _CurrenLEcquirement Tnchnical Specification 3.6.1.2.b currently states:

"The P 1 mary contaltunent lea' sge rates shall be limited tot

b. A combined leakage rate of less than or equal to 0.60 b, for -all penetrations and all valves listed in Table 3.6.J-1, except for main steam isolation valves and valves which are hydrostatically leak.

tested per Table 3.6.3-1, subject to Type B and C tests when pressurized to P,, 39.6 p7.lg."

Surveillance Hequirement 4.6.1.2.d currently states:

"Tne primary containment leakage rates shall be demonstrated _ at the-following test schedule and shall be dete rrnined - Iri conformance with - the criteria specitled in Appendix J of 10 CFR Part 50 using the methods and provisions of ANSI N46.4-1972:

d. Type D and C tests shall be conducted wit.h gas at Pa , 39.6 psig*, at intervals no greater than 24 rnonths except for tests involving:

1. Air locks,

2. Main steam line isolation valves,  !

3. /alves - essurized with fluid f rom a seal systern, and

4. ECCS and RCIC containment isolation _ valves In hydrostatically tested lines which penetrate the primary containment.

• linless a tydraulle test is r sired per Table 3.6.3-1."

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Technical Spt,cification 3,6.3 Limiting Condition for Operation requires l

"The primary containment isolation valves and the reactor l Anstrumentation line excess flow check valves shown in Table 3.6.3-1 shall  !

be OPERADLE with 1 solation times less than or equal to those shown in Table 3.6.3-1." j Table 340.3-1 Includes the Reactor Water Cleanup (RWCU)- Return to Feedwater Valve, 2033-F040, as an "other isolation valve" with no exceptions to the Type C test required per surveillance requirement 4.6.1.2.d. The 2G33-F040 is designed to be able to be closed remetely from the main control room following a 'tWCU return line break outside the primary containment to ensure long term luolation capability of the cleanup system. The Feedwater Inbontd and Outbcard Isolatlon Check Valves provide the automatic containment 7 1 solation feature. The appropriate pages of the UFSAR, which describe the system an discussed in this submittal, and a figure show1ng the simplified piping configuration, are included in Attachment E to this submittal.

Deses_foLLhe_CurrenLRequirement The primary containment isolatlen valves need to be operable during_ normal operation to ensure no open pathways from primary containment to the reactor-building, other _ structures, or the environment exist. The fission _ product barrier, i.e., the primary containment function for these lines, is maintained by two redundant isolation check valves in each feedwater line. Long term- i isolation capability is established by manual closure of the 2G33-F040 and 2821-F065A nnd F0658 from the Control Room. The Type B and C test combined ,

leakage is limited to 0.60 L a In rdor to assure that the total containment leakage volume will not exceed the value assumed in the accident analysis at the peak accident pressure of 39.6 psig, P,. Since the 2G33-F040 valve is not an automatic isolation valve, its leakage, as determined by a Type C test, is included in the combined leakage rate for all penetrations; but, its leakage is not inc3uded in the Type A, Containment Integrated Leak Rate, test. The  ;

Type A test vents the piping outboard of the feedwater isolation check valves. -

to satisfy this requirement. Without this ~ amendment, LaSalle Unit 2 will be required to shutdown to Cold Shutdown per specification 3.6.3.

Descrip11on_oLtheAccLLoL1 wending the IechainLSpecifieation f

LaSalle County Station Unit 2 Technical Specification 3.6.3 requires that-Primary Containment Isolation. Valves remain operable in Operational Conditions 1, 2, and 3. Due to concerns over the validity of the results of 10 CFR 50 i Appendix J Type C testing previcusly performed on the Resctor Water Cleanup .

Return to feedwater Valve 2G33-F040, this valve was declared inoperable.

Primary Containment Isolation is accomplished on the feedwater lines by two

' check valves on each feedwater line. Valves 2G33-Y040, 2821-F065A and F065B provide a long term isolation capability. With the 2G33-F040 inoperable, it is not pcssible to laolate the penetration per action statement a.1. without a Unit shutdown, and Unit shutdown is therefore required by action statement a.2.

Therefore, Commonwealth -Edison requested a waiver _of compliance from .

Technical Specification 3.6.3 actic n a.2 to allow continued unit operation until approval of an emergency Technical Specification unendment as documented: ,

in Reference a. The waiver of compliance states that the amendment will

! request valve 2G33-F040 be excluded from the list of Primary Containment L

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Isolat ion Valves which require a current 10 CFR 50 Appendix J Type C test in -

order to be considered operable in Operating Conditions 1, 2, and 3.

Therefore, this amendment request is being submitted to comply with the conditions under whlch NRR granted the walver.

De a c c 19 tion _oLtheAe nded_7echnic nLSpec1Ilc a.tlon_Re q uirement LaSalle County Station p,r,oposes that Technical Specification Table 3.6.3-1 be amended to add footnote to page 3/4 6-35 to rnodify the requirements for the 2333-F040 valve for the remainder of LaSalle Unit 2 Cycle 5 or until the first outage in which the unit is las Cold Shutdown for two weeks or greater duration, as follows: i i

"d. Other_ Isolation _YAlves i

2. Re ac t o r_.fne dwatnI_and_RNCILSy.sienLRetu rn i 2B22-F010A, B 2B21-F065g B 2G33-F040 ,,For the remainder of Cycle 5, or until the fitat outage in which the unit is in Cold Shutdown for two weeks or greater duration, the Type C test is not required to be current for the 2G33-F040 valve and its leakage is not required to

'a included in the total Type B &

C 3eakage specified by Specification 3.6.1.2.b."

A marked up version of the current requirement indicating the requested changes in included in Attachment B.

B as e s.l at.1he_AmundedeshnienLSys.tificatione qu e s.t During the performance of 10 CFR 50 Appendix J Type C testing (Local Leak Hete Testing) on Unit I during its current refuel outage, a NRC Resident Inspector questioned the appropriateness of the vent path established for the

, Unit 1 Reactor Water Cleanup Return to Feedwater Valve, 1G33-F040. This valve is a four . Anch flex wedge gate valve manufactured by Anchor Darling. The reactor coolant pressure boundary piping configuration being tested consisted of two feedwater lines, bounded by valves IB21-F065A and - IB21-F065B, and a reactor water cleanup line bounded by valve 1G33-F040. (See , Figure 1.)

Commonwealth Edison has maintained that the vent path for 1G33-F040, although separated by a check valve (1G33-r039) from the leak rate boundary valve, was

adequate because check valves cannot be conridered leak-tight.- In addition, based upon verbal conversations during past \ppendix J inspections, CECO believed that this test configuration had been acceptable to the NRC . staf f .-

After discussionk with NRC Region III personnel and the Senior Resident

. Inspector, CECO believes that the nonconservative testing verified that the-l combination of the valves had acceptable leakage, not the individual valve.-

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1 The as-found leakage past valve IGL3-F040, when tested with the existing vent path, was determined to be 0.0 scfh. As a result of the concern over the vent locativn, the valve was leak tested in the reverse direction, with measured leakage of 0.0 scfh.

The comparable Unit 2 piping configuration was reviewed, and found to be identical to U '. i t 1. As Unit 2 was in Operational Condition 1, it was not possible to test valve 2G33-F040 in the reverse direction. As a result, valve 2G33-F040 was der . red inoperable, snd Technical Specification 3.6.3 action a.

was consulted. The Primary Containment Isolation Valves involved in this Type C test boundary consist of non-slam check valves 2B21-r010A and 2B21-T010B Jocated inside the primary containment, and air operated testable check valves 2B21-T032A and 2B21-Tr32B located outside the primary containment. In addition, motor operated gate valves 2G33-F040, 2B21-F065A and 2B21-F065B, located outside the primary containment are provided to ensure long term isolation capability. With 2G33-r040 inoperable, and using check valves- to satisfy Technical Specification 3.6.3 action a.1. not acceptable, it was necessary to comply with action a.2., and be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

j A verbal Walver of Compliance with Specification Action a.2_was granted by l NRR with concurrence of Region III on October 28, 1992. The written Walver of '

Compliance was transmitted to NRR on October 29, 1992, Ref erence - a. The approval of the Temporary Walver of Compliance was received from NRR on

• Oc tu'un ;0, 1772 and allows LaSalle Un.' t 2 to continue operation until the l approval of an emergency Technical Specification Amendment. This amendment <

request satisfies one of the conditions of the Halver of Compliance.

The following information provides the technical justification for the '

proposed amendment.

1. Discussi.gn of CompAn6Atsry_Ac11nns During the last Unit 2 refuel outage, acceptable leakage we measured >

across the combination o' valve 2G33-F040 and check valve 2G3 3-} 03 9. To erisure the continued validity of this Incal leak rate test, neither' ,

maintenance nor surveillance activities will be performed on-check valve 2G33-F039 without additional testing to determine that valve 2G33-T040 is operable. This fulfills another condition of the Walver of Compliance.

2. E.v aluell QA._uLEn fAty_.Eig nific a nc e_nnLPAt.e.ntiALCo ntatqun accI A. No open pothways from primary containment to the reactor building, other structures, or the environment exist. The fission prduct barrier, i.e., the primary containment function, is maintained by two ' redundant isolation check valves in each feedwater _line, in conjunction with thc 2G33-T040 and the 2G33-F039 check valve. Dual feedwater check valves are provided so that containment leakage through the feedwater lines still-l meets containment leakage criteria in Appendix J in the event.of I a single failure. In addition, the combined leakage :of the 2G33-r040 and the 2G33-F039 check valve are within ~ allowable

.Jimits for the Reactor Water. Cleanup (RWCU) return line. The feedwater isolation check valve lea!sges are vithin limits for I

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the feedwater lines and fulfill the automatic isolation function for the feedwater cos.tainment penetrations. Therefore, there is r., significant reduction in the margin of safety.

The consequences of an accident previously evaluated is not significantly increased, because the feedwater line Isolation check valves form a leakage barrier and are the boundary for the Containment Integrated Leak Rate Test (Type A test). Also, the i RWCU return llne forms a tested leakage barrier for long term  !

leakage control.

EnedMAteI_Line Break Ec.enatin As discussed in UFSAR Section 15.6.6 the feedwater check valves will prevent a significant loss of reactor. coolant inventory by Immediately isolating the lines in the event of a Feedwater line break outside the primary containment. During a postulated LOCA, it is desirable to maintain reactor coolant makeup from any available source, and therefore valves 2P21-F065A and 2B21-F065B do not have automatic isolation capability.

As discussed in UFSAR Section 6.2.4.2.1, the design function of the feedwater check valves Is to prevent a significant loss of reactor coolant inventory by immediately isolating the lines in the 'avent of a Feedwater line break.

During a postulated LOCA, it is desirable to maintain reactor coolant makeup from any available source, and therefore valves 2B21-F065A and 2B21-F065B do not have- automatic isolation capability. These valves may be closed from the Main Control room to provide long-term leakage protection 'should ' feedwater system makeup be unavailabic or unnecessary.

E c.nct or. lint eL.Cle an up_kinn_DInnit_Sre natin As discussed in UFSAR Section 6.2.4.2.1, an additional design function of the feedwater check valves is to prevent a significant loss of reactor coolant inventory by immediately 1solating the lines in the event of a break in the Reactor dater Cleanup Return to Feedwater line. As with feedwater, during a postulated LOCA, it is desirable to maintain . reactor coolant makeup from any available source, and therefore valve 2G33 7040 dens not have automatic isolation capability. This valve . may alto be closed from the Main Control room to provide long-term lea age protection.

B. During the 10 CF" te Ay endix J Type A test, r.o credit is taken for valve 2G33-F040 since it is not an automatic isolation valve. The feedwater lines are vented outboard of the feedwater isolation check- valves, and inboard of- the motor operated Feedwater and Reactor Water Cleanup gate valves. Thus, the 2G33-F040 valve leakage is not a factor in the acceptability of Containment Integrated Leakage Test.

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9 C. An . adequate leakage boundary, a' combinat~an of valves 2G33-r040 and 2G33-r039, exists for this line based on the satisfactory leakage test performed on this line during the last Unit 2 refuel outage.

3. Justifintion_0Lthe_lhtIAtlon of the,_Reggest Continued power operation with the nonconservative leak rate test of the 2033-r040 valve is of minimal safety significance since the RWCU return line leakage meets t.he leak rate limits for that line.

The 2G33-F040 valve is in the Main Steam Tunt.el and not accessible during power operation. Appropriate testing of this valve will require the reactor to be in Cold Shutdown since primary containment . will be rendered inoperable during such testing, and the feedwater lines and RWCU return line must be drained.

The approved temporary waiver will remain valid until NRC approval of this emergency Technical Specification amendment request. This amendment request, when approved, . will allow . continued Unit 2 operation for - the remainder of this operating cycle, Cycle 5, currently scheduled to end in the Fall of 1993, or until the first outage in which the unit is in cold _-

shutdown for two weeks or greater duration.

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