ML20058C090

Forwards Supplemental Info Re Application for Exigent Amends to Licenses NPF-11 & NPF-18,adding Primary Containment Isolation Valves to Tech Spec 3.6.3,Table 3.6.3.1, Primary Containment Isolation Valves, Per NRC Bulletin 93-003

ML20058C090
Person / Time
Site:	LaSalle
Issue date:	11/15/1993
From:	Schrage J COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
IEB-93-003, IEB-93-3, NUDOCS 9312020338
Download: ML20058C090 (6)

Text

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I e ) Ccmm:nwn!th Edison

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O '- 1400 Opus Place Downers Grove. lllinois 60515 i

t November 15,1993 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation l

U.S. Nuclear Regulatory Commission l

Washington D.C.

20555 l

Attn.: Document Control Desk i

Subject:

LaSalle County Nuclear Station Units 1 and 2 Supplementalinformation Concerning Application for Exigent i

Amendment to Facility Operating Licenses NPF-11 and NPF-18 Appendix A, Technical Specifications NRC Docket Nos. 50-373 and 50-374 l

References:

(a)

NRC Bulletin 93-03, ' Resolution of issues Related to Reactor Vessel Water Level Instrumentation in BWRs", dated May 28, 1993.

l (b)

L.O. DelGeorge to T.E. Murley letter dated September 15,1993.

(c)

P.L. Piet to T.E. Murley letter dated October 8,1993.

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(d)

W.E. Morgan to T.E. Murley letter dated October 18,1993.

(e)

Meeting between Commonwealth Edison and the NRC on October 21,1993.

(f)

P.L. Piet to T.E. Murley letter dated October 29,1993.

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Dr. Murley, In Reference (f), Commonwealth Edison (CECO) submitted a proposed exigent amendment to Facility Operating Licenses NPF-1_1 and NPF-18, Appendix A - Technical Specifications. The proposed amendment added primary containment isolation valves to Technical Specification 3.6.3, Table 3.6.3-1 " Primary Containment isolation Valves."

This exigent Technical Specification amendment is necessary to allow the completion and operation of the reactor vessel level indication reference leg backfill modification by the end of the current LaSalle Unit 2 refueling outage. The backfill modification is being installed to enhance safety performance of the reactor vessel level instrument system in accordance -

with NRC Bulletin 93-03 (Reference (a)).

9312O20338 931115 PDR ADOCK 05000373 M01 P

PDR, a y0

Dr. T.E. Murley November 15,1993 The purpose of this letter is to provide additional information to form the basis for exigency. This information is provided in the Attachment.

Commonwealth Edison respectfully requests review and approval of the exigent amendment to the LaSalle County Station Units 1 and 2 Technical Specifications by November 24,1993. This schedule will allow startup of the Unit 2 reactor following the fifth refuel outage (L2ROS).

The additional information pertaining to the proposed exigent Technical Specification -

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

To the best of my knowledge and belief, the statements contained above are true and correct, in some respect these statements are not based on my personal knowledge, but obtained information fumished by other Commonwealth Edison employees, contractor employees, and consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.

Commonwealth Edison 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.

Very traly yours,

~

/

John L.

rage bt ear Licensing Administrator

Attachment:

Basis for Exigency; Proposed Exigent Amendment to Facility Operating Licenses NPF-11 and NPF-18, Appendix A, Technical Specifications cc:

J.B. Martin, Regional Administrator - Rlli J.L. Kennedy, Project Manager - NRR D. Hills, Senior Resident inspector - LaSalle R. Hague, Branch Chief - Rit]

Office of Nuclear Facility Safety - IDNS Signed before me on this /f day

~ g*g"*{~gf h4 MARYELLEN D LONG by %f^er

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tm Any r"JBUC, ST ATr of tWNo[S Notary /Public py couwesion txMRf S 09/01/97

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ATTACHMENT Basis for Exigency Proposed Exigent Amendment to Facility Operating Licenses NPF-11 and NPF-18 i

Appendix A, Technical Specifications LaSalle County Station SUBJECT i

This attachment provides supplemental information pertaining to a proposed exigent amendment to Facility Operating Licenses NPF-11 and NPF-18, Technical Specifications.

This application for an exigent license amendment was submitted on October 29,1993 (Reference (f)), and is related to the Reactor Vessel Water Level instrumentation System (RVWLIS) backfill modifications being installed on Unit 2 during the current refuel outage.

1 REFERENCES (a)

NRC Bulletin 93-03 dated May 28,1993 (b)

L.O. DelGeorge letter to T.E. Murley dated September 15,1993 (c)

P.L. Piet letter to T.E. Murley dated October 8,1993 (d)

W.E. Morgan letter to T.E. Murley dated October 18,1993 (e)

Meeting between Commonwealth Edison and the NRC Staff, dated October 21, 1993 (f)

P.L. Piet letter to T.E. Murley dated October 29,1993 i

DISCUSSION The subject application for an Amendment regarding the installation of the RVWLIS backfill modifications was submitted by Reference (f) as an " Exigent" Technical Specification amendment request. This supplement provides additionalinformation to form t

the basis for exigency. A normal Technical Specification Amendment would require

(

submittalin time to allow the NRC to provide for a 30-day public comment period. The '

l Time Line provided in this attachment demonstrates Commonwealth Edison's (CECO)

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continued efforts, subsequent to August 13,1993, to provide the NRC with the information required to support approval of the license amendment transmitted by Reference (f). The August 13,1993 date corresponds to the date that CECO received information that ultimately led to design changes which required NRC concurrence for-

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implementation.

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ATTAC,Hre.NT (cont.)

In a meeting held on October 21,1993 with the NRC (Reference (e)), CECO clarified

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the basis for the proposed design and the resulting need for the change to the Technical Specifications. Based on new information from that meeting, the basis for the amendment i

to the License and Technical Specifications was changed, requiring re-submittal of the l

amendment request. The License / Technical Specification amendment request was re-submitted on October 29,1993 by Reference (f), which withdrew the' previous submittals,

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clarified the design, and explained how the design complies with the General Design i

criteria and applicable regulations. As stated in Reference (f), this License / Technical

.j Specification amendment request is required by November 24,1993 and does not allow sufficient time for a 30 day public comment period in accordance with 10 CFR 50.91. If this amendment request is not granted under 10 CFR 50.91.(a)(6), then the scheduled j

startup of LaSalle Unit 2 from L2R05 will be delayed.

ll Time Line-

-l Aug 13:

During a discussion about RVWLIS with PP&L (Susquehanna), LaSalle l

Engineering was made aware of a PP&L reviewer question about root valve l

closure. LaSalle review of plant drawings confirmed potential for a -

i significant transient involving multiple SRV lifts and abnormal partial l

actuations and trips.

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Aug 18:

CECO ran scenarios on the LaSalle County Station (LaSalle) BWR training j

simulator to evaluate the response to each potential root valve closure.

Simulator response confirmed actuations and indicated potential additional complications resulting from actual parameter measurements by unaffected systems.

l Aug 19-l Aug 20:

An NRC engineer and Brookhaven. National Laboratory (BNL) contractor for l

the NRC, visited the LaSalie site to obenv9 RVWLIS tests. CECO provided

=

the results of the simulator rum, to these two individuals. The discussion -

with these NRC individuals was short, but included a description of CECO concerns that the potential events were unacceptable, and that the design may need to be changed.

Aug 23:

A LaSalle design group meeting was held and a request was made to

,j evaluate what would be needed to support moving the injection point to -

the containment side of the root valve.

.)

j Aug 25-Aug 30:

The LaSalle design group discussed the results of the evaluation by the.

LaSalle design group, and determined:

ATTACHMENT (cont.)

1.

That an exemption from GDC-55 would be required; 2.

A question existed as to whether Appendix J testing or condensing pot inventory was the limiting leakage rate; and 3.

That significant piping changes would be required (to move flow stations up one level in Reactor Building from 761' to 786'). The full scope of repiping was not known at this time.

in addition, the design group determined the Leak Rate testing requirements which were required by Appendix J for new containment isolation valves.

From a review of General Design Criteria, past experience, and previously granted exemptions, it was clear that the requested exemption from GDC-55 could be justified. This was based upon the fact that normal check valves are superior to Excess Flow Check Valves (EFCV), and EFCV were already exempted.

Based upon the evaluation by the LaSalle design group, LaSalle Station Site Engineering recommended a change to the design.

Aug 30:

A conference call was held among CECO BWR sites to discuss the decision for LaSalle to go ahead with re-design of the modification.

Sept 13:

A draft Licensing Submittal was prepared by LaSalle Station. This draft submittal detailed the proposed exemption from GDC-55 and an Unreviewed Safety Question pertaining to leakage from the new containment isolation check valves.

Sept 20:

The final Licensing Submittal (Revision 0) was provided to LaSalle On-Site Review.

Sept 23:

The final Licensing Submittal (Revision 0) was approved by LaSalle On-Site Review.

Sept 27:

The final Licensing Submittal (Revision 0) was approved by Off-Site Review.

Sept 27-Sept 29:

Based on discussions with the CECO Nuclear Licensing department, Revision 0 was withdrawn by LaSalle and Revision 1 was initiated to clarify some of the issues presented in Revision O.

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1 ATTACHMENT (cont.)

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Oct 6:

The final Licensing Submittal, Revision 1, was approved by LaSalle On-Site-Review.

Oct 8:

1.

The final Licensing Submittal (Revision 1) was approved by Off-Site'-

Review.

2.

The completed submittal was transmitted to the NRC (Reference (c)).

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3.

Based on the reviews performed, CECO determined that a Technical.

Specification change was required.

Oct 8-Oct 18 NRC review of the submittal generated several NRC/ CECO phone calls.

between October 8 and October 19,1993_regarding the requested exemption and the Unreviewed Safety Question submitted. During this time a meeting was scheduled for CECO to meet with NRR to explain and clarify some aspects of the submittal (s) (References (c) and (d)).

Oct 12:

A Technical Specification amendment request was approved by On-sit'e l

Review.

Oct 13:

The Technical Specification amendment request was approved by Off-site Review.

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Oct 18:

The Technical Specification amendment request was submitted to the NRC (Reference (d)) on October 18,1993. This amendment request added the i

new containment isolation valves to Technical Specification Table 3.6.3-1.

Both of these submittals (References (c) and (d)) were submitted in time to j

allow review by the NRC with allowance for the normal 30-day public comment period.

Oct 21:

CECO met with NRR in Rockville, MD, to present reasons for the redesign of the system, and justification for GDC interpretation. Discussion i

centered on safety improvement of the design compared to the 1

containment design standards. CECO was also shown several places where the submittal was not logical or clear.

The meeting resulted in agreement for CECO to revise and resubmit the proposed License Amendment.

Oct 22-Oct 29:

CECO rewrote the proposed Technical Specification amendment,~ and following On-Site and Off-Site Reviews, transmitted it to the NRC in'-

Reference (f).

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