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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217H6341999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for Kh Curran,Lm Gerlach,Rc Weber & Bt Rhodes Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC Form 396 Encl.Proprietary Info Withheld ML20217H6251999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for MR Kahn,Aj Mclaughlin,De Montgomery & Kr Murphy Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC from 396 Encl.Proprietary Info Withheld ML20217F4301999-10-14014 October 1999 Responds to 991012 Rai,Based on 991001 Telcon Re Suppl to Request for TS Change to Revise MCPR Safety Limit & Add Approved Siemens Topical Rept for LaSalle County Station, Unit 1 ML20217D3191999-10-12012 October 1999 Submits Request for Addl Info Re Licensee 990707 Proposed License Amend to Revise Min Critical Power Ratio.Listed Questions Were Discussed with Util in 991001 Telcon ML20217C1671999-10-0808 October 1999 Provides Suppl to RAI for Approval of Unreviewed Safety Question Re Assessment of Certain safety-related Concrete Block Walls at LaSalle County Station,Units 1 & 2 ML20217A7601999-10-0606 October 1999 Forwards Insp Repts 50-373/99-15 & 50-374/99-15 on 990729-0916.One Violation of NRC Requirements Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy ML20212M0931999-10-0404 October 1999 Refers to 990922-23 Meeting Conducted by Region II at LaSalle Nuclear Power Station.Purpose of Visit,To Meet with Licensee Risk Mgt Staff to Discuss Util Initiatives in Risk Area & to Establish Dialog Between SRAs & Risk Mgt Staff 05000373/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl1999-10-0404 October 1999 Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20217A6201999-09-30030 September 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC Feedback on Any Planned Insps Which May Conflict with Plant Activities.Plant Issue Matrix & Insp Plan Encl ML20212E7171999-09-22022 September 1999 Forwards RAI Re Requesting Approval of License Amend to Use Different Methodology & Acceptance Criteria for Reassessment of Certain Masonry Walls Subjected to Transient HELB Pressurization Loads 05000374/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl1999-09-20020 September 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl ML20212C0591999-09-17017 September 1999 Informs That NRC Reviewed Licensee Justifications for Deviations from NEDO-31558 & Determined That Justifications acceptable.Post-accident Neutron Flux Monitoring Instrumentation Acceptable Alternative to Reg Guide 1.97 ML20212A3581999-09-13013 September 1999 Confirms That Fuel MCPR Data for LaSalle County Station,Unit 1,Cyle 9,sent by Ltr Meets Condition 2,as Stated in 970509 NRC Ltr ML20211Q9911999-09-10010 September 1999 Informs That License SOP-4048-4,for Wp Sly May Be Terminated Due to Individual Retiring ML20212A1141999-09-10010 September 1999 Forwards RAI Re Licensee 990519 Amend Request,Which Proposed to Relocate Chemistry TSs from TS to licensee-controlled Documents.Response Requested by 990930,so That Amend May Be Issued to Support Upcoming Unit 1 Refueling Outage ML20211P2211999-09-0808 September 1999 Forwards Insp Repts 50-373/99-14 & 50-374/99-14 on 990809- 13.No Violations Noted.Insp Concluded That Emergency Preparedness Program Maintained in Good State of Operational Readiness ML20212A8571999-09-0707 September 1999 Informs That Proprietary Document, Power Uprate SAR for LaSalle County Station,Units 1 & 2, Rev 2,Class III, NEDC-32701P,submitted in ,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20211Q6861999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Plant License Applicants During Wks of 001113 & 20. Validation of Exam Will Occur at Station During Wk of 001023 05000374/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl1999-09-0303 September 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl ML20211M1151999-08-31031 August 1999 Requests That Following Eleven Individuals Take BWR Gfes of Written Operator Licensing Exam to Be Administered on 991006 ML20211G1831999-08-27027 August 1999 Provides Addl Clarification of Proposed Refueling Practices Under Proposed Core Alterations Definition Re 990813 Application for Amend to TS ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211F8731999-08-25025 August 1999 Forwards Insp Repts 50-373/99-13 & 50-374/99-13 on 990804-06 & 09-11.No Violations Noted.Fire Protection Program Strengths Includes Low Number of Fire Protection Impairments & Excellent Control of Transient Combustibles ML20210U3201999-08-17017 August 1999 Forwards Insp Repts 50-373/99-12 & 50-374/99-12 on 990623-0728.No Violations Noted ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed 05000373/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed1999-07-23023 July 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed ML20210E0501999-07-22022 July 1999 Submits Summary of 990630 Management Meeting Re Licensee Performance Activities Since Start Up of Unit 2.List of Attendees & Matl Used in Presentation Enclosed ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20209H5171999-07-15015 July 1999 Discusses 990701 Telcon Re Arrangements for NRC to Inspect Licensed Operator Requalification Program at LaSalle County Nuclear Generating Station for Weeks of 990913,1018 & 1129 ML20209G4031999-07-14014 July 1999 Forwards Insp Repts 50-373/99-11 & 50-374/99-11 on 990614-18.No Violations Noted ML20209E1211999-07-14014 July 1999 Submits mid-cycle Rev of COLR IAW LaSalle County Tech Spec 6.6.A.6.d.Rev to COLR Was Necessary Due to Implementation of TS Change Approved by Ltr Dtd 990212,which Changed Turbine Stop Valve & Turbine Control Valve Scram ML20209F6931999-07-13013 July 1999 Forwards Insp Repts 50-373/99-04 & 50-374/99-04 on 990513-0622.No Violations Noted.Determined That Multiple Challenges to Main Control Room Operators Occurred During Insp Period Due to Human Performance Weaknesses ML20210C1521999-07-0909 July 1999 Forwards Post-Outage (90 Day) Summary Rept for ISI Examinations & Repair/Replacement Activities Conducted from Beginning of First Insp Period of Second ten-yr Insp Interval Through L2R07 Refueling Outage ML20209G3901999-07-0909 July 1999 Informs NRC of Status of Commitments & Requests NRC Concurrence for Use of ASME Section III App F Acceptance Criteria to Permanently Qualify Units 1 & 2 Penetrations M-49 & M-50 ML20209E0341999-07-0909 July 1999 Provides NRC with Siemens Power Corp (SPC) Fuel & GE Fuel MCPR Data for LaSalle Unit 1 Cycle 9.LaSalle Unit 1 Is Currently Scheduled to Start Cycle 9 in 991101 ML20209E0361999-07-0808 July 1999 Forwards LaSalle County Station Unit 2 Cycle 8 Startup Test Rept Summary,Iaw TS NPF-18,Section 6.6.A.1.Startup Test Program Was Satisfactorily Completed on 990501 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes ML20196J4711999-06-30030 June 1999 Discusses Closure of GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity, Issued on 950519 to Plant,Units 1 & 2 ML20212J0311999-06-21021 June 1999 Informs of Actions Taken to Close Remaining Open Items in .Attachment Provides Detailed Justification for Closure of Open Items in Sections 5.2.2 & 5.2.8 ML20196B1951999-06-18018 June 1999 Informs NRC That Do Werts,License OP-30373-2,no Longer Requires Use of NRC License for LaSalle County Station. License May Be Terminated ML20195J7761999-06-15015 June 1999 Submits Request Relief CR-23,requesting Relief from Code Required Selection & Examinations of Noted Integral Attachments & Proposes to Utilize Alternative Selection & Examination Requirements Similar to Code Case N-509 ML20196G8021999-06-15015 June 1999 Requests Renewal of SRO License for Vv Masterson.Current License for Vv Masterson Will Expire Jul 1999.NRC Forms 398 & 396,encl.Without Encls ML20195G7101999-06-11011 June 1999 Informs That Effective 990514,GH Mccallum,License SOP-31412, No Longer Requires Use of NRC License for LaSalle Station. License Should Be Terminated ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs ML20207D2821999-05-27027 May 1999 Requests That Implementation Date for Unit 1 Be Changed Prior to Startup for L1C10 to Allow Best Allocation of Resources to Implement Unit 1 Amend Prior to Startup for Either L1C9 or L1C10.Unit 2 Will Implement Mod IAW Request 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217H6251999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for MR Kahn,Aj Mclaughlin,De Montgomery & Kr Murphy Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC from 396 Encl.Proprietary Info Withheld ML20217H6341999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for Kh Curran,Lm Gerlach,Rc Weber & Bt Rhodes Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC Form 396 Encl.Proprietary Info Withheld ML20217F4301999-10-14014 October 1999 Responds to 991012 Rai,Based on 991001 Telcon Re Suppl to Request for TS Change to Revise MCPR Safety Limit & Add Approved Siemens Topical Rept for LaSalle County Station, Unit 1 ML20217C1671999-10-0808 October 1999 Provides Suppl to RAI for Approval of Unreviewed Safety Question Re Assessment of Certain safety-related Concrete Block Walls at LaSalle County Station,Units 1 & 2 05000373/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl1999-10-0404 October 1999 Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr 05000374/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl1999-09-20020 September 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl ML20211Q9911999-09-10010 September 1999 Informs That License SOP-4048-4,for Wp Sly May Be Terminated Due to Individual Retiring 05000374/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl1999-09-0303 September 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl ML20211M1151999-08-31031 August 1999 Requests That Following Eleven Individuals Take BWR Gfes of Written Operator Licensing Exam to Be Administered on 991006 ML20211G1831999-08-27027 August 1999 Provides Addl Clarification of Proposed Refueling Practices Under Proposed Core Alterations Definition Re 990813 Application for Amend to TS ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed 05000373/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed1999-07-23023 July 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed ML20209E1211999-07-14014 July 1999 Submits mid-cycle Rev of COLR IAW LaSalle County Tech Spec 6.6.A.6.d.Rev to COLR Was Necessary Due to Implementation of TS Change Approved by Ltr Dtd 990212,which Changed Turbine Stop Valve & Turbine Control Valve Scram ML20210C1521999-07-0909 July 1999 Forwards Post-Outage (90 Day) Summary Rept for ISI Examinations & Repair/Replacement Activities Conducted from Beginning of First Insp Period of Second ten-yr Insp Interval Through L2R07 Refueling Outage ML20209E0341999-07-0909 July 1999 Provides NRC with Siemens Power Corp (SPC) Fuel & GE Fuel MCPR Data for LaSalle Unit 1 Cycle 9.LaSalle Unit 1 Is Currently Scheduled to Start Cycle 9 in 991101 ML20209G3901999-07-0909 July 1999 Informs NRC of Status of Commitments & Requests NRC Concurrence for Use of ASME Section III App F Acceptance Criteria to Permanently Qualify Units 1 & 2 Penetrations M-49 & M-50 ML20209E0361999-07-0808 July 1999 Forwards LaSalle County Station Unit 2 Cycle 8 Startup Test Rept Summary,Iaw TS NPF-18,Section 6.6.A.1.Startup Test Program Was Satisfactorily Completed on 990501 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes ML20212J0311999-06-21021 June 1999 Informs of Actions Taken to Close Remaining Open Items in .Attachment Provides Detailed Justification for Closure of Open Items in Sections 5.2.2 & 5.2.8 ML20196B1951999-06-18018 June 1999 Informs NRC That Do Werts,License OP-30373-2,no Longer Requires Use of NRC License for LaSalle County Station. License May Be Terminated ML20196G8021999-06-15015 June 1999 Requests Renewal of SRO License for Vv Masterson.Current License for Vv Masterson Will Expire Jul 1999.NRC Forms 398 & 396,encl.Without Encls ML20195J7761999-06-15015 June 1999 Submits Request Relief CR-23,requesting Relief from Code Required Selection & Examinations of Noted Integral Attachments & Proposes to Utilize Alternative Selection & Examination Requirements Similar to Code Case N-509 ML20195G7101999-06-11011 June 1999 Informs That Effective 990514,GH Mccallum,License SOP-31412, No Longer Requires Use of NRC License for LaSalle Station. License Should Be Terminated ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs ML20207D2821999-05-27027 May 1999 Requests That Implementation Date for Unit 1 Be Changed Prior to Startup for L1C10 to Allow Best Allocation of Resources to Implement Unit 1 Amend Prior to Startup for Either L1C9 or L1C10.Unit 2 Will Implement Mod IAW Request ML20195B2301999-05-19019 May 1999 Requests Approval of Proposed Changes to QA Topical Rept CE-1-A,rev 66a.Attachment a Describes Changes,Reason for Change & Basis for Concluding That Revised QAP Incorporating Proposed Changes Continues to Satisfy 10CFR50AppB ML20206R4561999-05-12012 May 1999 Provides Notification That Ws Jakielski,License SOP-30168-3, Is Being Reassigned & No Longer Requires Use of NRC License, IAW 10CFR50.74 05000373/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii).Attachment a Provides Commitments for Submittal1999-05-0707 May 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii).Attachment a Provides Commitments for Submittal ML20206K7081999-05-0707 May 1999 Forwards 10CFR50.46(a)(3) Rept Re Significant Change in Calculated Pct.Loca Analyses for Both GE Fuel & Siemens Power Corp Fuel Demonstrates Results within All of Acceptance Criteria Set Forth in 10CFR50.46 ML20206K1861999-04-30030 April 1999 Informs That in Comed Submitted Annual Exposure Rept for Personnel Receiving Greater than 0 Mrem/Yr Rather than 100 Mrem/Yr.Updated Rept Limiting Data to Personnel Receiving Greater than 100 Mrem/Yr,Attached ML20206R0751999-04-30030 April 1999 Forwards License Renewal Applications & Certification of Medical Examinations for LaSalle County Station Personnel Whose Licenses Expire in Nov.Personnel Listed.Without Encls ML20206F0931999-04-30030 April 1999 Forwards LaSalle County Nuclear Power Station,Units 1 & 2 Effluent & Waste Disposal Semi-Annual Rept for 1998. LaSalle County Station Tech Specs Recently Revised to Reduce Periodicity of 10CFR50.36a ML20206D5921999-04-28028 April 1999 Forwards Annual Environ Operating Rept for 1998 for Environ Protection Plan, for LaSalle County Station,Units 1 & 2. Rept Includes Info Required by Listed Subsections of App B to Licenses NPF-11 & NPF-18 ML20206B2471999-04-20020 April 1999 Informs That SE Kuczynski Has Been Transferred to Position No Longer Requiring SRO License.Cancel License SOP-31030-1, Effective 990412 ML20205L8161999-04-0808 April 1999 Advises NRC of Util Review & Approval of Cycle 8 Reload Under Provisions of 10CFR50.59 & Transmit COLR for Upcoming Cycle Consistent with GL 88-16.Reload Licensing Analyses Performed for Cycle 8 Utilize NRC-approved Methodologies ML20205J9451999-04-0505 April 1999 Submits Petition Per 10CFR2.206 Requesting That LaSalle County Nuclear Plant Be Immediately Shut Down & OL Suspended or Modified Until Such Time That Facility Design & Licensing Bases Are Properly Updated ML20205K5841999-03-31031 March 1999 Submits Rept on Status of Decommissioning Funding for Reactors Owned by Comm Ed.Attachment 1 Contains Amount of Decommissioning Funds Estimated to Be Required Pursuant to 10CFR50.75(b) & (C) ML20205B4241999-03-23023 March 1999 Provides Results of drive-in Drill Conducted on 990208,as Well as Augmentation Phone Drills Conducted Since 981015,as Committed to in Util ML20207J9841999-03-0505 March 1999 Informs That Effective 990212,KC Dorwick Has Resigned & No Longer Requires Use of NRC License for LaSalle County Station ML20207F9581999-03-0101 March 1999 Requests That Initial License Examination Currently Scheduled for Weeks of May 15 & 22,2000 Be Changed to Weeks of Nov 13 & 20,2000.Class Size Is Projected to Be Twelve RO & SRO Candidates ML20207C7251999-03-0101 March 1999 Forwards Annual Rept for LaSalle County Station, for Period of 980101-981231.App E to Rept Provides Info on All Personnel Receiving Exposures of More than 0 Mrem/Yr Rather than 100 Mrem/Yr Requirement of TS 6.6.A.2 ML20207D6831999-03-0101 March 1999 Forwards fitness-for-duty Program Performance Data for Each Comed Nuclear Power Station & Corporate Support Employees for Six Month Period Ending 981231,per 10CFR26.71(d) ML20207C8401999-02-25025 February 1999 Forwards Rev 60 of Comed LSCS Security Plan,Iaw 10CFR50.4(b) (4).Rev Eliminates Requirement for Annual change-out of Vital & PA Keys & Locks & re-configuration of PA Fence Around North Access Facility.Rev Withheld ML20207A9361999-02-24024 February 1999 Forwards Rev 4 to Restart Plan,To Reflect Review,Oversight & Approval Process Necessary to Restart Unit 2.Review & Affirmation Process Will Focus on Station Capability to Support Safe Dual Unit Operations 1999-09-30
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C:mm:nwealth Ediscn s 1400 Opus Place =
q'_ J Downers orove,liiinois 60515 October 22,1992 -
p Dr. Thomas E. Murley, Director Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
LaScl;a County Station Units 1 and 2 Failure of 2CM025A Valve NRC_Doche1NosJ0-313. anis 0-31_4
Reference:
(a) B.L. Siegel letter to Commonwealth Edison Company, dated October 5,1992; Summary of Meeting on Post-Accident Sampling S stem (PASS) Isolation Valves, August 27,1992, and Follow up D scussions with the Licensee, Received by Commonwealth Edison October 14, '.992.
Dear Dr. Murley; This provides Commonwealth Edison Company' (CECO) response to concerns raised by the Nuclear Regulatory Commission (NRC egarding the o)eration of Post-LOCA Containment Monitoring Valves. The va e are suppress on chamber return valves for the Containment monitoring skids. Valve 2CM025A is representative of those valves and has been the subject of several discussions with your staff. At the conclusion of those discussions, CECO committed to formalizing its intent to take certain actions regarding the subject valves. Those actions are described in this letter.
ECo intends to take actions which it believes preserve the originalintent of the ,
plant s design ability to adequately protect the public health and safety. That intent is clear from tae circumstance which led to installation of the Containment Monitoring skids- the post-TMI realization that it was necessary to public health and safety to be able to sample containment atmosp"ere for oxygen and hydrogen after a Loss of Coolant Accident (LOCA . This design was reviewed and approved as aart of the FSAR review resulting i the issuance of the_SER, NUREG 0519. The idea that containment integrity should override the need for post-LOCA monitoring is contrary to the original des n of the skids and the Technical Specifications which implement that monitoring func ion. Therefore, the actions proposed will enhance plant operation but -
continue to permit post-LOCA monitoring of containment atmosphere, in the unlikely event that it should become necessary.
260124 h ;
7NI D/2246/1 I
921o26o4oo 921o22 PDR ADOCK 05ooo373 P PDR
13ackground To appreciate CECO's understanding of the safety role of the 2CM025A valve,it is first useful to review the system which contains it. Valve 2CM025A is part of the post LOCA etmosphere sampling system. That system is connected to the drywell and suppression chamber air volumes by sampling system lines which penetrate the containment. The alping for those lines is considered to be an extension of the containment bounc ary since it must be available for long term usage following a design-basis LOCA. Accordingly, the piping is designed and fabricated to the same quality standards as the containment. (See UFSAR section 6.2.4.2.2, Evaluation Against General Design Criterion 56.)
Valve 2cm025A is a normally closed solenoid operated valve, which energizes to close, and falls in the open position upon loss of electrical power. (See attached Figure 1.) There are two other similar valves for each Containment Monitoring skid. During accident conditions, Primary Containment isolation System (PCIS) initiation logic oper.s the drywell supply valve (2CM022A) and suppression chamber return valve (2CM025A), and prevents manual operator actions from closing either valve until the PCIS signal is reset. Because these valves are required to remain oaen after a LOC %,
they are part of a system which constitutes a closed loop outside of tie containmr Accordingly, they are left open for Type A testing, and are not presently subject to .
Type C test. (See UFSAR Table 6.2 21, Note 40.) These circumstances further reinforce the view that the ability to sample post-LOC A containment atmosphere wa' j the primary concern and that containment integrity would be preserved through pipirs ,
des gn and Type A testing.
Questions about the correct post-inoperability position of the 2CM025A valve arose after June 22,1992 when the valve was declared inoperable based upon surveillance testing which required the valve to be opened. in accordance with Station procedures, an Operability Evaluation and a Technical Specification / License Clarification INo. 04-92) were performed on June 23,1992. This evaluation determined that if valve aCM025A was inoperable, it should be taken out-of service in the isolation position, meaning the valve position after receiving a PCIS isolation signal. For this valve, that position is open. With the valve out-of-service open the Technical Specification Limiting Conditions for Operation for Containment Isolation Valves (3.6.3) and for Accident Monitoring instrumentation (3.3.7.5) are both satisfied. ,
7 b
ZNLD/2246/2 1
On August 5,1992, tha NRC informed Commonw::lth Edison that th3y belbved ;
that the 2CM025A valve was a Primary Containment Isolation System (PCIS) volve and i that it should be in the closed position when declared inoperable. Therefore, the NRC l believed that LaSalle was not in compliance with Technical Saecification 3.6.3. The '
NRC was given copies of the Operability Evaluation and the Technical Specification Clarification, and LaSalle further described their rational as follows:
The 2CM025A valve was believed to have been incit :sd in Table 3.6.3-1 for the sole purpose of ensuring that the PCIS logic interlock was tested. Thic belief was partially based upon the fact that valves 2CM025A and 2CM022A, which had PCIS interlocks, wrire included in the Table, whilo valve 2CM024A, which did not have the PCIS Interlock but was similar in design function to valve 2CM022A, was not included in the table. This belief is further supported by the August 18,1984 A. Schwencer letter to D. Farrar approving Amendment 18 to Coerating License NPF 11, in which the SER states that " Valves 1CM023B &
2CM024A (sic) would be deleted from the list of containment isolation valves since these are, in fact, not containment valves."
The LaSalle Safety Evaluation Report, NUREG 0519, Section 6.2.3, Containment isolation System, implies that the current design is in compilance with alternate acceptance criteria for GDC 56.
The CM piping can be considered an extension of the primary containment, as discussed in UFSAR section 6.2.4.2.2.
The CM piping, which forms a closed loop outside of containment, is a barrier to prevent the release of radionucildes from the primary containment. The integrity of this barrier is verified by the Appendix J Type A test. During the test, the CM valves in question are in the open position, implying that the valve is not a pad of the barrier.
Footnote (h) to Technical S 3ecification Table 3.6.3-1 states that no Appendix J Type C test is required for t1ese valves.
The NRC aoreed to consider LaSalle's position, and requested no further action on August 5,1992.
NBC_Newfosition On August 6,1992, discussions between the NRC and CECO resulted in a tentative agreement that LaSalle was in compliance with Technical Specifications 3.6.3 and 3.3.7.5, and that the safety significance of the issue warranted no immediate action. Despite finding that CECO met all regulatory requirements, the NRC continued to maintain that the valves were PCIS valves, and therefore, did not concur with the present, approved design, which allowed the valves to automatically open upon receipt of a PCIS signal. Rather, widout addressing how the originalintent to ensure post-LOCA monitoring throughout an event would be maintained, the NRC requested CECO to develop options which would provide the control room operator with manual control of these valves. Despite CECO s concern that closure of these valves could prevent their reopening under accident conditions, three potential design changes tubich would enable operator action to close the valves during accident conditions were t apled to NRR on August 14,1992. A fourth option, defeating the PCIS interlock in t 'alve logic, was verbally discussed with NRR on August 17,1992.
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1 On August 20,1992, CECO and tha NRC h:Id a conforcnca call, and we understand the NRC final position to be the following:
The post-LOCA Hydrogen / Oxygen Sample system is not an extension of the Primary Containment.
The three valves for each CM skid are considered Primary Containment isolation Valves.
GDC 56 requires one PCIS valve per penetration for closed loops outside containtnent.
LaSalle is in compliance with the Technical Specifications, and the operability decision made was based in good f aith and was reasonable based upon NRC review of the dec!gn documents.
GECMlesponse The NRC rec uired CECO to make a verbal ccmmitment within 7 days describing the actions to be Laken to resolve this issue. They further required that a written commitment be provided within 30 days of the verbal cornmitment. During an August 27,1992 meeting, CECO provided verbal commit. . Ys to resolve the issue. At that time, one issue was identified that required further resolution, as discussed in reference (a). During follow up discussions,'ho date for submittal of written commitments was extended to approximately October 9,1992. This letter formalizes the commitments from the August 27,1992 meeting.
The inoperable 2CM025A valve will be repaired during the first outage of sufficient duration after parts availability. (The inoperable 2CM025A valve was subsequently repaired during the Unit 2 forced outage (L2F18) which began on August 27,1992,)
Contingent uaon approval of the Technical Specification Amendment Request, the isolai;on ogic for valves 1/2CM022A,1/2CM025A,1/2CM021B, and 1/2CM026B will be modified to remove the PCIS Intsilock from the logic circuit.
After modification, these valves will o aerate in an identical f ashion to 1/2CM024A and 1/2CM023B in that tielr only method of operation will be remote manual operation from a control switch in the Main Control Room. The design change will be implemented on Unit 2 prior to the startup from the Unit 2 fifth refuel outage, L2R05, tentatively scheduled to begin in the Fail of 1993, and on Unit 1 prior to the startur from the Unit 1 sixth refuel outage, L1R06, tentatively scheduled to begin in the Spring of 1994.
l The valves will continue to fall open upon loss of power.
i l
The three isolation valves per skid will be in the open position for the Appendix J Type A test to teet the piping integrity.
The three isolation valves per skid will be Appendix J Type C tested from the reverse direction (skid toward containment). Both the 1CM025A and 2CM025A L valves are presently installed such that the valve inlet port is away from the containment, providing a non-conservative Type C test. The orientation of both 1CM025A and 2CM025A will be changed such that the inlet port is towards the containment. This re-orientation will be implemented on both Unit 1 and Unit 2 during the first outage requiring a Type A test after each Units fifth refuel outage.
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Th3 cxisting Primary Containm:nt isolation Valvo Technical Spxific:. tion 3.6 3
. specifically states that these valves did not require a Appendix J Type C test. A Type C test will now be required. Prior to the first Appendix J Type C test for the three valves per skid, LaSalle may perform maintenance on the valves pdpI to performing the Type C leak rate. After the first Type C test, normal testing prococures would be followed for these valves.
The methodology ussd to determine the Type A minimum path leakage value will be resolved under existing NRC TAC itern M77481.
A Type C test will also be performed in the reverse direction (skid toward containment) on the two existing manual gate valves located on each CM skid.
The Technical Specifications will be amended to be consistent with the new design. The proposed Technical Specification amendment will be submitted to NRR by April 1,1993, and willinclude the following changes to Table 3.6.3-1:
Relocation of valves 1/2CM021B,1/2CM022A,1/2CM025A, and 1/2CM026B from the " Automatic Isolation Valve" section of the table to the
'Other Isolation Valves" section to reflect removal of the automatic isolation signal interlock.
Addition of valves 1/2CM024A and 1/2CM023B to the "O; hor Isolation Valves" section of the table.
Revision of footnote (h) to eliminate the reference to the valve opening on a PCIS c:ignal, to eliminato the exemption to Type C testing, and to add a reference to the valve fail position.
The UFSAR will be revked as a part of each Unit's logic modification to reflect the system changes and the revisions to the Technical Specification and the l Bases. The UFSAR will reflect the position that should one of these PCIS valves become inoperabte. the manual valves on the skid will be closed, and the Technical Specification for Primary Containment isolation Valves will be satisfiert.
o These changes will provide additional assu:ance that the vchres will maintain their T integrity while preserving the post-LOCA monitoring function of the Containment Monitoring System.
As for the appropriate response to valve inoperability, CECO further proposed that during future operation, shculd one of the PCIS valves become inoperab e, CECO will close and administratively control the manual valves located on the CM skid. This action maintains comoliance with Technical Specification 3.6.1.1, Primary Containment Integrity, and because the manual skid valves may be reopened on an intermittent basis under administrative control per the
maintains compliance with Technical Specification 3.3.7.5, Accident Monitoring Instrumentation. During the August 27,1992 meeting, the NRC requested turther review of this point prior to agreement. Subsequant to the meeting, CECO and NRR j discussed the following:
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CECO stated that if tho hydrogan/ oxygen monitor had a 1:ak, it would ba a 3rimary containment leak, would require either manual or remote valve solation, would require the skid to be declared inoperable, and the appropriate Limiting Condition for Operation to be entered.
In the absence of a leak, closing the manual valves is a contingency, and the valvec would only be reopened to protect the containment or to allow sampling. After the initiation of a LOCA, CECO would enter the appropriate L Emergency Operating Procedure, LGA 3, dispatch operators to the local skids, c'en the manual valves, and start the skids within the 30 minutes committed to in response to NUREG 0737. However, subsequent to that action, using a conservative dose calculation, the reactor building would not be habitable, and CECO would not dispatch an operator to reclose the valves. Nonetheless, NRR contends that it is necessary to re-close these valves to re-establish primary containment. CECO's different view follows.
During a LOCA,if hydrogen / oxygen monitors on both Divisions are unavailable, CECO Emergency Procedures provide contingencies, requiring venting the
- centainment. CECO believes that venting dunng a LOCA is a last resort which should not be the logical consequence of a deliberate but unnecessary action.
Rather than taking actions which could require venting the containment, CECO l
believes that it is in the interests of public health and safety to open the manual l
valves on the skid to allow containment sampling consistent with the intent behind its design as an extension of the containment.
For these reasons, CECO believes that the intent of the original, approved design, which allows hydrogen monitoring of the containment, provides the greatest safety when compared to the conservative containment isolation function of a system designed to containment standards. Nevertheless, the NRC's position in reference (a) appears to elevate the priority of containment integrity over post-LOCA monitoring by
! requiring the post LOCA containment monitoring skid to be considered inoperable l whenever a local valve is closed to compensate for leaving an inoperable isolation l valve in an open position, and that the skid will have to be restored to operability within 30 days.
The proposal could result in plant shutdown whenever the return to operability of i the skid can be achieved only by the repair of an isolation valve. CECO believes that l additional plant shutdowns and their adverse impacts on plant operation are not
!. warranted under these circumstances. Rather, because this potentia! for additional l shutdown is created by a new concem about containment integrity which is contra'y to the design of the skids, CECO suggests that an agreement which accommodates that concern also should avoid unnecessary shutdowns. Accordingly, CECO proposes that post LOCA containment monitoring be considered operable for Technical Specification purposes, despite the closure of a'iocal valves, provided that the post-LOCA containment monitoring skid on the other Division is fully operable (without reliance on local valve operations). Under these conditions and because the manual isolation valves on the skid can always be opened immediately after the on-set of a LOCA, the system retains its primary safety function of post-LOCA monitoring while accommodabng NRC concerns about containment integrity. In addition, CECO would also commit to restoring the operability of the containment valve no later than the next outage of sufficient duration after the valve became inopwable. In the event that post-maintenance testing requires containment pressurization to test the repair, the repairs will be conducted during the next refueling outage.
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s if there are any questions, please contact this office.
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Respectfully,
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JoAnn Shloids Nuclear Licensing Administrator
Attachment:
Figure 1 cc: A.B. Davis, Regional Administrator - Rlli B.L. Siegel, Project Manacter - NRR
, J. Pulsipher, Technical Sthtf - NRR D.L. Hills, Senior 9esident inspecto' - LSCS
/ Office of Nuclear Facility Safety -IDNS 4
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Txx-92009 Page 2 of 2 The PHR line has been monitored and data has been collected during the first operating cycle. Westinghouse has evaluated the data and concluded that further data collection is not necessary, The evaluation by Westinghouse is included in the enclosure. Therefore, we request that the continuation f data collection be suspended.
Sincerely.
William J. Cahill, Jr, By: f x Aw J. S. Marshall Generic Licensing Manager CEJ/vid Enclosure c - Mr. T. A, Bergman, NRR Mr. R. D. Martin, Region IV Resident inspectors, CPSES (2) l i
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