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Category:SAFETY EVALUATION REPORT--LICENSING & RELATED ISSUES
MONTHYEARML20217C9121999-10-12012 October 1999 SER Input Authorizing Licensee Proposed Request to Modify Definition of Core Alteration in Section 1.0 of TS & Update Sections 3/4.1,3.4.3 & 3/4.9 to Reflect Proposed Definition Change ML20198B3801998-12-14014 December 1998 SER Accepting one-time Request for Relief from Certain Provisions of Section XI of ASME Boiler & Pressure Vessel Code,Per 10CFR50.55a for Certain Plant Safety/Relief Valves ML20196B1441998-11-23023 November 1998 Safety Evaluation Accepting Licensee Response to GL 95-07, Pressure Locking & Thermal Bindings of Safety-Related Power-Operated Gate Valves ML20153C7621998-09-18018 September 1998 Safety Evaluation Acceping NRC Bulletin 95-002, Unexpected Clogging of RHR Pump Strainer While Operating in Suppression Pool Cooling Mode ML20236L8041998-07-0606 July 1998 Safety Evaluation Granting Licensee 980304 Request for Second 10-yr Interval Pump & Valve IST Program Plan,Rev 2, Including Changes to 2 ASME Boiler & Pressure Vessel Code Relief Requests Previously Submitted in Rev 1 ML20217Q7041998-05-0404 May 1998 Safety Evaluation Accepting Util Request to Leave Leak Chase Channels Plugged During Performance of Containment ILRT ML20203B1941997-12-0404 December 1997 Supplemental SE Accepting Proposed Changes Which Are Consistent W/Recognized Battery Stds & Station Blackout Rule ML20148T8571997-07-0303 July 1997 SER Accepting Temporary Use of Current Procedure for Containment R/R Activities Instead of Requirements of Amended 10CFR50.55a Rule to Be Reasonable ML20137D4961997-03-24024 March 1997 Safety Evaluation of Second 10-year Interval Inservice Insp Program Plan Requests for Relief CR-17 & CR-18 Commonwealth Edison Co,Lasalle County Station,Units 1 & 2 ML20135D4661996-12-0606 December 1996 Safety Evaluation Granting Relief Request RP-01 & Alternative Testing Imposed Per 10CFR50.55a(f)(6)(i) Based on Impracticality of Performing Required Testing ML20129D9401996-09-26026 September 1996 SER Accepting Licensee Cycle 8 Core Reload Design Submittal Re Application of Anfb Critical Power Correlation to Coresident GE9 Fuel as Described in TR EMF-96-021(P),Rev 1 ML20059E2871993-12-30030 December 1993 Safety Evaluation Supporting Amends 57,57,45,45,93,77,152 & 140 to Licenses NPF-37,NPF-66,NPF-72,NPF-77,NPF-11,NPF-18, DPR-39 & DPR-48 Respectively ML20128E4101992-12-0101 December 1992 Safety Evaluation Accepting Relief Requests RI-22 & RI-23 from ASME Code Requirements from Hydrostatic Pressure Testing Following Replacement of RCIC Steam Supply Inboard Isolation Valve as Part of ISI Program ML20059N0301990-08-22022 August 1990 Safety Evaluation Accepting Util Response to Generic Ltr 88-01, NRC Position on IGSCC in BWR Austentic Stainless Steel Piping ML20154E5461988-09-0707 September 1988 Safety Evaluation Supporting Amends 60 & 40 to Licenses NPF-11 & NPF-18,respectively ML20151X0121988-08-16016 August 1988 Safety Evaluation Re Inservice Testing Program & Requests for Relief ML20237C8761987-12-16016 December 1987 Safety Evaluation Supporting Facility IGSCC Insp,Per Generic Ltr 84-11 ML20237C9091987-12-16016 December 1987 Safety Evaluation Supporting Licensee Response to IE Bulletin 79-26,Rev 1, Boron Loss from BWR Control Blades, Per License Condition 2.C(6) ML20205R6681987-04-0101 April 1987 Safety Evaluation Supporting Continued Use of Static O-Ring Differential Pressure Switches ML20211P2551986-12-15015 December 1986 Safety Evaluation Supporting Util Compliance W/License Condition 2.C.(25)(d) Requirements Re Mods to Six Fire Door Stops ML20214U8501986-12-0404 December 1986 Safety Evaluation Re Util 861006 Response to IE Bulletin 79-26,Rev 1, Boron Loss from BWR Control Blades, to Satisfy License Condition 2.C(13).Response Acceptable ML20214T3991986-12-0202 December 1986 Supplemental Safety Evaluation Accepting Licensee 860613 Analysis & Justification for Cable Separation Criteria to Resolve Deficiencies Described in Sser 7,App D ML20213G3181986-11-12012 November 1986 Safety Evaluation Accepting local-to-bulk Temp Difference of 12 F.Draft Technical Evaluation Rept Encl ML20215K8741986-10-21021 October 1986 Safety Evaluation Accepting Offsite Dose Calculation Manual Updated Through Rev 12.Changes Incorporated in Revs 11 & 12 Comply W/Tech Spec 6.8.2 ML20215K9631986-10-16016 October 1986 Safety Evaluation Granting Interim Acceptance of Process Control Program Updated Through 850718 ML20212Q7191986-08-29029 August 1986 Safety Evaluation Supporting Amend 27 to License NPF-18 ML20205F0791986-08-11011 August 1986 Safety Evaluation Supporting 860213 Procedures for Design of Single Angle Members for HVAC Hanger Frames for Plant. Related Info Encl ML20205C4051986-08-0707 August 1986 Safety Evaluation Supporting Facility Restart Following 860601 Feedwater Transient.Licensee Action Plan,Supplemented by Listed Actions,Adequate Basis for Restart & short-term Operation.Supporting Drawings & Matls Encl ML20206M6161986-06-23023 June 1986 Safety Evaluation Supporting Responses to Generic Ltr 83-28 Item 2.1 (Part 1) Re Equipment Classification ML20195D4121986-05-27027 May 1986 Safety Evaluation Summary of Inservice Testing Program for Pumps & Valves.Program Acceptable Subj to Listed Conditions in Encl SER ML20195D4171986-05-27027 May 1986 SER Re Pump & Valve Inservice Testing Program NUREG-0519, Safety Evaluation of Final in-plant Safety/Relief Valve Test Evaluation Rept Per SER (NUREG-0519).Design Adequate to Accommodate Loads Associated W/Activation of One or More Safety Relief Valves1986-05-19019 May 1986 Safety Evaluation of Final in-plant Safety/Relief Valve Test Evaluation Rept Per SER (NUREG-0519).Design Adequate to Accommodate Loads Associated W/Activation of One or More Safety Relief Valves ML20198B4221986-05-15015 May 1986 Supplemental Safety Evaluation Supporting Util Cable Separation Criteria Per Sser (NUREG-0519),App D.Addition of Zipper Tubing to Divisional Cables for Automatic Depressurization Sys Relief Valves Resolved NRC Concern ML20203N5531986-04-30030 April 1986 Safety Evaluation Concluding That Util IGSCC Insp Performed in Accordance W/Generic Ltr 84-11 & Satisfactory.Small Concerns Re long-term Growth of Small IGSCC Cracks Present But Not Detected During Insp Remain ML20140D6501986-03-19019 March 1986 SER Supporting Test Program,Results & Commitment for Nonqualified GE Control Switches.License Conditions 2.C.(21)(c) & 2.C.(12)(a) for Units 1 & 2,respectively,will Be Satisfied When GE Switches Removed from Engine ML20210E0961986-02-0404 February 1986 Safety Evaluation Accepting Util 851113 Proposal for Amend Changing Tech Specs to Include Previously Approved Trip Setting on Low CRD Pump Discharge Water Header Pressure & to Delete Associated Surveillance Requirement ML20137D8081985-11-18018 November 1985 Safety Evaluation Supporting Use of Mechanical Stress Improvement Process in Primary Sys Stainless Steel Piping to Modify Residual Stress Pattern at Piping Butt Welds NUREG-0889, SER Conditionally Supporting Response to Procedures Generation Package1985-10-18018 October 1985 SER Conditionally Supporting Response to Procedures Generation Package ML20137S6391985-09-30030 September 1985 Safety Evaluation Supporting Elimination of Arbitrary Intermediate Pipe Breaks.Deviation from SRP Acceptable for Piping Sys Identified in Ref 2 Except Portion of RHR Sys Made of 304SS Matl ML20129D9511985-07-16016 July 1985 Safety Evaluation Supporting Acceptance Criteria for Firecode CT Gypsum Fire Stops ML20126K9121985-07-12012 July 1985 Revised SER Re Util 831105 & 850605 Responses to Generic Ltr 83-28,Item 1.1, Post-Trip Review Program. Program & Procedures Acceptable ML20129E8881985-05-24024 May 1985 SER of Util 831105 Response to Generic Ltr 83-28,Item 1.2 Re post-trip Review Data & Info Capabilities.Capabilities Acceptable 1999-10-12
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML20217C9121999-10-12012 October 1999 SER Input Authorizing Licensee Proposed Request to Modify Definition of Core Alteration in Section 1.0 of TS & Update Sections 3/4.1,3.4.3 & 3/4.9 to Reflect Proposed Definition Change ML20217F9091999-09-30030 September 1999 Monthly Operating Repts for Sept 1999 for LaSalle County Stations,Units 1 & 2.With ML20217A1691999-09-22022 September 1999 Part 21 Rept Re Engine Sys,Inc Controllers,Manufactured Between Dec 1997 & May 1999,that May Have Questionable Soldering Workmanship.Caused by Inadequate Personnel Training.Sent Rept to All Nuclear Customers ML20212C4501999-08-31031 August 1999 Monthly Operating Repts for Aug 1999 for LaSalle County Station,Units 1 & 2.With ML20210R0671999-07-31031 July 1999 Monthly Operating Repts for July 1999 for LaSalle County Station,Units 1 & 2.With ML20210C1681999-07-0909 July 1999 Seventh Refueling Outage ASME Section XI Summary Rept ML20209H1501999-06-30030 June 1999 Monthly Operating Repts for June 1999 for LaSalle County Station,Units 1 & 2.With ML20195J7871999-05-31031 May 1999 Monthly Operating Repts for May 1999 for LaSalle County Station,Units 1 & 2.With ML20209E1431999-05-31031 May 1999 Cycle 8 COLR, for May 1999 ML20195B2591999-05-19019 May 1999 Rev 66a to CE-1-A,consisting of Proposed Changes to QAP for Dnps,Qcs,Znps,Lcs,Byron & Braidwood Stations ML20206N2071999-04-30030 April 1999 Monthly Operating Repts for Apr 1999 for LaSalle County Station,Units 1 & 2.With ML20205L8421999-03-31031 March 1999 Rev 2 to EMF-96-125, LaSalle Unit 2 Cycle 8 Reload Analysis ML20205L8301999-03-31031 March 1999 Administrative Technical Requirements App B (Amend 26) LaSalle Unit 2 Cycle 8 COLR & Reload Transient Analysis Results, for Mar 1999 ML20205R2721999-03-31031 March 1999 Monthly Operating Repts for Mar 1999 for LaSalle County Station,Units 1 & 2.With ML20205L8391999-03-22022 March 1999 Rev 2 to 960103, Neutronics Licensing Rept for LaSalle Unit 2,Cycle 8 ML20204C8141999-02-28028 February 1999 Monthly Operating Repts for Feb 1999 for LaSalle County Station,Units 1 & 2.With ML20199E4601998-12-31031 December 1998 Monthly Operating Repts for Dec 1998 for LaSalle County Station,Units 1 & 2.With ML20207C7371998-12-31031 December 1998 Annual Rept for LaSalle County Station for Jan 1998 Through Dec 1998 ML20205M7061998-12-31031 December 1998 Unicom Corp 1998 Summary Annual Rept. with ML20198B3801998-12-14014 December 1998 SER Accepting one-time Request for Relief from Certain Provisions of Section XI of ASME Boiler & Pressure Vessel Code,Per 10CFR50.55a for Certain Plant Safety/Relief Valves ML20206N2261998-12-0909 December 1998 LER 98-S03-00:on 981116,protected Area Was Entered Without Current Authorization for Unescorted Access Due to Programmatic Deficiency Error.Changed Badge Control Process ML20197K0981998-11-30030 November 1998 Monthly Operating Repts for Nov 1998 for LaSalle County Station,Unts 1 & 2.With ML20196B1441998-11-23023 November 1998 Safety Evaluation Accepting Licensee Response to GL 95-07, Pressure Locking & Thermal Bindings of Safety-Related Power-Operated Gate Valves ML20196A4191998-11-19019 November 1998 Safety Evaluation Accepting QA TR CE-1-A,Rev 66 Re Changes in Independent & Onsite Review Organization by Creating NSRB ML20195D3191998-10-31031 October 1998 Monthly Operating Repts for Oct 1998 for LaSalle County Station.With ML20154H6781998-09-30030 September 1998 Monthly Operating Repts for Sept 1998 for LaSalle County Nuclear Power Station,Units 1 & 2 ML20153D0191998-09-18018 September 1998 Part 21 Rept Re Defect in Gap Conductance Analyses for co- Resident BWR Fuel.Initially Reported on 980917.Corrective Analyses Performed Demonstrating That Current Operating Limits Bounding from BOC to Cycle Exposure of 8 Gwd/Mtu ML20153C7621998-09-18018 September 1998 Safety Evaluation Acceping NRC Bulletin 95-002, Unexpected Clogging of RHR Pump Strainer While Operating in Suppression Pool Cooling Mode ML20153C6771998-09-17017 September 1998 Part 21 Rept Re Defect Relative to MCPR Operating Limits as Impacted by Gap Conductance of co-resident BWR Fuel at Facilities.Operating Limit for LaSalle Unit 2 & Quad Cities Unit 2 Will Be Revised as Listed ML20151W0241998-08-31031 August 1998 Monthly Operating Repts for Aug 1998 for LaSalle County Station.With ML20237E2921998-08-21021 August 1998 Special Rept:On 980811,channel 5 of Lpms Became Inoperable. Caused by Channel Failed pre-amplifier Located Inside Primary Containment at Inboard Side of Electrical Penetration E-19.Initiated Repairs of Channel ML20237E2331998-08-21021 August 1998 Revised Pages of Section 20 of Rev 66 to CE-1-A, QA Topical Rept ML20237B4861998-07-31031 July 1998 Monthly Operating Repts for July 1998 for LaSalle County Nuclear Power Station Units 1 & 2 ML20236V7701998-07-31031 July 1998 Revised LaSalle Unit 1 Cycle 8 COLR & Reload Transient Analysis Results ML20236P8231998-07-14014 July 1998 Special Rept:From 980614-17,various Fire Rated Assemblies Were Inoperable for Period Greater than Seven Days.Caused by Test Equipment Being Routed Through Fire Doors.Established Fire Watches & on 980619 Assemblies Were Declared Operable ML20236N6751998-07-0909 July 1998 Part 21 & Deficiency Rept Re Notification of Potential Safety Hazard from Breakage of Cast Iron Suction Heads in Apkd Type Pumps.Caused by Migration of Suction Head Journal Sleeve Along Lower End of Pump Shaft.Will Inspect Pumps ML20236L8041998-07-0606 July 1998 Safety Evaluation Granting Licensee 980304 Request for Second 10-yr Interval Pump & Valve IST Program Plan,Rev 2, Including Changes to 2 ASME Boiler & Pressure Vessel Code Relief Requests Previously Submitted in Rev 1 ML20236P3611998-06-30030 June 1998 Monthly Operating Repts for June 1998 for LaSalle County Nuclear Power Station,Units 1 & 2 ML20249C4891998-06-22022 June 1998 Special Rept:On 980522,Fire Detection Zone 1-31 Was Noted out-of-service for More than 14 Days.Detection Sys Was Taken out-of-service on 980508 to Prevent False Alarms During Hot Work Activities.Sys Was Returned to Operable Status 980528 ML20248M3101998-05-31031 May 1998 Monthly Operating Repts for May 1998 for LaSalle County Nuclear Power Station,Units 1 & 2 ML20236V7771998-05-31031 May 1998 Rev 1 to 24A5180, Supplemental Reload Licensing Rept for LaSalle County Station Unit 1 Reload 7 Cycle 8 ML20217Q7041998-05-0404 May 1998 Safety Evaluation Accepting Util Request to Leave Leak Chase Channels Plugged During Performance of Containment ILRT ML20247M4491998-04-30030 April 1998 Monthly Operating Repts for Apr 1998 for LaSalle County Station ML20216F4941998-03-31031 March 1998 Monthly Operating Repts for Mar 1998 for LaSalle County Station,Units 1 & 2 ML20217N6581998-03-30030 March 1998 Special Rept on Fire Detection,Deluge Sys & Fire Rated Assemblies During Period of 980303-25.Established Fire Watches Until Affected Equipment Is Returned to Operable Status ML20216D9511998-02-28028 February 1998 Monthly Operating Repts for Feb 1998 for LaSalle County Station,Units 1 & 2 ML20247M4631998-02-28028 February 1998 Rev Monthly Operating Rept for Feb 1998 for LaSalle County Station ML20203D7241998-02-20020 February 1998 Special Rept:On 980118,Fire Detection Zones 1-18 & 2-18 Taken out-of-svc to Prevent False Alarms During Hot Work Activities on Auxiliary Electric Equipment Room Ventilation Sys.Fire Watches Will Remain in Place ML20202G9851998-01-31031 January 1998 Monthly Operating Repts for Jan 1998 for LaSalle County Station,Units 1 & 2 ML20199K1651998-01-23023 January 1998 Rev 65h to Topical Rept CE-1-A, Comm Ed QA Tr 1999-09-30
[Table view] |
Text
. _ . - -_. . . .. .. - - - - . _ . ._ .-
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p NUCLEAR REGULATORY. COMMISSION WASHINGTON, D.C. 20086 4001 i
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO REQUEST FOR RELIEF CR-19 LASALLE COUNTY STATION. UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50 '}74 j i
1.0 INTRODUCTION
Subsections IWE and IWL of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) provide the require- !
ments for inservice inspection (ISI) of Class CC (concrete containments) and Class MC (metallic containments) pressure retaining components. By notice in the Federal Reaister dated August 8.1996, the U.S. Nuclear Regulatory Commission amended its regulations (rule) to incorporate, by reference, the 1992 edition with 1992 addenda of Subsections IWE and IWL. The effective date for the amended rule was September 9,1996, and it required licensees to l incorporate the new requirements into their ISI plans and to complete the first containment inspection within five years, that is, by September 9, 2001.
Since the amended rule became effective on September 9.1996, any repair or ,
replacement activity to be performed for the containments after that date must '
be in accordance with the respective requirements of Subsections IWE and IWL.
However, a licensee can submit a recuest for relief for the date of implemen-tation of its containment repair anc replacement (R/R) activities with proper justification. The provision for granting relief is incorporated in the regulation.
2.0 DISCUSSIDN 2.1 RELIEF REOUEST NO. CR-19 10 CFR 50.55a(g)(4)(v) requires Class MC and CC pressure retaining components and their integral attachments to meet the applicable R/R requirements of the i ASME Code.Section XI. 1992 Edition with the 1992 Addenda. Subsections IWA-4000 & 7000. IWE-4000 & 7000, and IWL-4000 & 7000. Relief is requested from immediate compliance with the applicable R/R requirements of the 1992 Edition of the Code until December 31. 1997. ,
2.2 BASIS FOR RELIEF (As stated) !
Relief is requested from immediate compliance with the repair and replacement requirements of Subsections IWE and IWL. Pursuant to _
10 CFR 50.55a(a)(3)(ii), relief is requested on the basis that immediate compliance with the aforementioned requirements would result in unusual difficulty without a conpensating increase in the level of quality and safety.
l 1
9707090352 970703 PDR ADOCK 05000373 -
P PDR l
l
r A revision to 10 CFR 50.55a was published on August 8. 1996, which endorses Subsections IWE and IWL of the ASME Boiler and Pressure Vessel Code Section XI 1992 Edition with the 1992 Addenda. This revision i
requires the completion of an ex> edited examination by September 9.
4 2001. However, in a letter to tie Nuclear Energy Institute (NEI) dated November 6.1996, the NRC staff clarifies that all repair and replace-ment activities within the scope of Subsection IWE and IWL which are conducted after September 9. 1996 must be conducted in accordance with j the applicable rules of Subsections IWE and IWL of ASME Section XI.1992 i Edition with the 1992 Addenda.
, Immediate compliance with the repair and replacement rules of ASME Section XI 1992 Edition with the 1992 Addenda for IWE and IWL !
components is impractical because substantial time and resources must be expended for the following major efforts:
1
- 1. CONTAINMENT STRUCTURE COMPONENT CLASSIFICATION: The Station materials, erection, fabrication procedures and testing of i i containment structures at LaSalle County are in general l l conformance to the following rules ,
, a. Containment steel liner, backed by concrete, containment ;
steel boundaries, not backed by concrete. and penetrations I
were constructed to the rules of ASME Section III.
Division I. Subsection NE.1971 Edition with the Summer 1972
\
- b. Containment concrete and reinforcing steel was constructed
! to the rules of ACI-318.1971 and ASTM A615-1972.
t
' c. Containment Post Tensioning System is in general conformance l
' with the rules of ASME Section III. Division II. Subsections i CC-2400 CC-4400, and CC-5400. July 1.1977.
- d. Containment structural steel was constructed to the rules of I AISC Manual-1969.
l In order to comply with 10 CFR 50.55a(g)(4)(v), it will be <
necessary to identify and reclassify all containment components to Class MC and CC classification criteria. This effort will include a the retrieval and review of all applicable fabrication and
. installation documentation. the development of a basis document to ,
- identify the correct classification boundaries and tne eventual develo> ment of an inservice inspection program to govern all ,
IWE/IW_-related~ activities at LaSalle Station.
- 2. PROCEDURE REVISIONS: The requirements of Subsections IWE and IWL j must be incorporated into applicable station procedures. The current Inservice Inspection program. (which includes the repair and replacement program), for LaSalle Station is currently based
i on the rules of ASME Section XI, 1989 Edition, and only addresses i the inservice inspection requirements for Class 1, 2. and 3 pressure retaining components and component supports. Therefore. :
! various procedures that control Code repair and replacement-activities mast be revised to incorporate the unique requirements j of Subsec % r. IWE and IWL. j j 3. EXAMINER TRAINING AND CERTIFICATION: The unique examiner I
, qualification required by Subsections IWE and IWL must be l incorporated into the existing Commonwealth Edisori (Comed) certification and training program. The existing Comed certification and training program only addresses the j certification requirements for Class 1. 2 and 3 pressure retaining 1 components and component supports. The Comed certification and training program must be revised to incorporate the unique requirements of Subsections IWE and IWL.
. 4. LASALLE RESTART PLAN: Currently, both LaSalle units are in extended outages for refueling and maintenance. It is fully expected that both units will remain in these extended outages during the entire aeriod for which this relief is requested. Many of the resources tlat would need to be utilized for the sole purpose of meeting these new Code Requirements are also actively involved in implementing a variety of actions associated with-these dual unit outages, including implementation of the LaSalle Station Restart Plan. This effort further extends the time period !
needed to adequately address the Code Requirements in order to assure quality as well as compliance.
Since the containment structures at LaSalle Station were 4 constructed to the rules of ASME Section III. ACI-318-1971. l ASTM A615-1972 and AISC Manual-1969, all repair and replacement l activities conducted on these components have been subjected to
, the. Comed Quality Assurance Manual (Commonwealth Edison Company.
l Topical Report CE-1-A. Section 2, 3.1). The Comed Quality Assurance Manual requires repair and replacement activities to be conducted in accordance with the original design specifications using a) proved procedures. This approach assures applicable
~
design Jases are maintained. As stated in Comed Quality Assurance Program Topical Report CE-1-A Revision 65. approved by the October 20, 1994. George F. Dick, Jr. letter to D.L. Farrar, the Comed Quality Assurance Program complies with the quality recuirements of 10 CFR 50. Appendix B. ASME Section III NCA-4000. l anc ANSI /ASME NOA-1. Currently Comed is working to minor revision
- 65d dated February 10. 1997. (Minor revisions do not require NRC '
Review and approval since they do not involve a reduction in commitments). Additionally. the containment structure integrity l
4 is verified by: the periodic pressure tests in accordance with 10 CFR 50. Appendix J. Option B, and the surveillance of the post-tensioning system. Post-tensioning system testing and f
i
. I J
examinations are performed in accordance with Technical Specification required programs. LaSalle Administrative Procedure i LAP-100-51. " Inservice Inspection Program for Post-Tensioning Tendons". and implementing procedure. LaSalle Technical Surveillance LTS-1000-1. " Inservice Inspection of Post-Tensioning Tendons". These approved procedures incorporate the requirements of NRC Regulatory Guide 1.35 Revision 3. " Inservice Inspection of Ungrouted Tendons in Prestressed Concrete Containments".
For the above reasons, the immediate application of the requirements of Subsections IWA-4000 & 7000. IWE-4000 & 7000, and IWL-4000 & 7000 imposes added administrative burden (such as requirement for a repair / replacement plan and NIS-2 form) without a compensating increase in the level of quality or safety."
2.3 ALTERNATIVE TEST (As stated)
Until December 31. 1997, all repair and replacement activities conducted on applicable Class MC and CC pressure retaining components and their 1 integral attachments at LaSalle Station will be performed in accordance with the existing Comed 0A Program requirements. Compliance with ASME Section XI. 1992 Edition with the 1992 Addenda. Subsections IWA-4000 &
7000. IWE-4000 & 7000, and IWL-4000 & 7000 will begin on January 1. 1998.
Should the need arise to complete Repair / Replacement activities on any Class MC and CC pressure retaining components or their integral attachments prior to January 1.1998, these activities will be controlled using approved Nuclear Work Requests in accordance with LaSalle Administrative Procedure LAP-1300-1. " Action / Work Request Processing". These Nuclear Work Requests will be classified as " Nuclear Safety Related". and thus, their preparation, review, approval.
implementation and associated post Repair /Re)lacement testing is governed by the Comed QA Manual.(Commonwealt1 Edison Company. Topical Report CE-1-A. Section 2. 3.1). The Comed Quality Assurance Program complies with the quality requirements of 10 CFR 50 Appendix B. ASME Section III NCA-4000, and ANSI /ASME NOA-1. Post-tensioning system testing and examinations will be 3erformed in accordance with Technical Specification required programs. _aSalle Administrative Procedure ,
LAP-100-51 " Inservice Inspection Program for Post-Tensioning Tendons",
and implementing procedure. LaSalle Technical Surveillance LTS-1000-1.
" Inservice Inspection of Post-Tensioning Tendons. These approved procedures incorporate the requirements of-NRC Regulatory Guide 1.35.
Revision 3. " Inservice Inspection of Ungrouted Tendons in Prestressed
. Concrete Containments" 2.4 . EVALUATION The relief is requested on the basis that immediate compliance with the requirements of the rule for R/R activities would result in unusual difficulty without a compensating increase in the level of safety and quality. In its
. submittal Comed provided a number of reasons such as reclassification of components to Class CC and MC classification criteria, revisions to existing ;
procedures for R/R activities to incorporate the unique requirements of l Subsections IWE and IWL. and incorporation of unique examiner training and '
qualification requirements in the Comed procedures to demonstrate the impracticality of meeting the requirements of the rule for R/R activities.
In its letter dated May 13. 1997. Comed clarified and provided a summary description of the alternative that is used for the containment R/R activities. Until December 31. 1997, all R/R conducted on Class CC and Class MC components and their integral sup) orts will be performed in accordance with the existing LaSalle Administrative )rocedures for nuclear safety related components. These activities will be governed by the Comed Quality Assurance Manual. The Comed 0A program complies with the OA recuirements of 10 CFR Part 50. Appendix B: ASME Section III NCA-4000; and AhSI/ASME NOA-1. Also. {
the inspection and R/R activities related to the containment post-tensioning '
tendons for both units are governed by LaSalle Station Technical Specifications. The staff considers the alternative program for R/R activities reasonable and acceptable during the period of relief.
To justify relief beyond the Seriod that the staff considers as a reasonable period. Comed stated that bot 1 LaSalle units are in extended outages, and will remain in these outages during the entire period for which the relief is requested. Furthermore. Comed emphasizes that the resources required to implement the requirements of the rule are also involved in the 1mplementation of the LaSalle Station restart plan and the extended period will allow Comed to adequately address the Code (i.e., the rule) requirements that will assure I quality as well as compliance. The staff considers the reasoning provided for the extended relief period acceptable.
The licensee commits to implement the requirements of the rule for the containment R/R activities starting January 1. 1998.
3.0 CONCLUSION
Based on the review of the information provided in the relief request, the staff finds the temporary use of the current procedure for containment R/R activities instead of the requirements of the amended 10 CFR 50.55a rule to be j) reasonable and acceptable. Also, the staff concludes that immediate compliance with the requirements of the amended rule for containment R/R activities during the period September 9.1996, through December 31, 1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, request for relief CR-19 to delay implementation of the rule for R/R activities until January 1.1998, is )
acceptable for authorization pursuant to 10 CFR 50.55a(a)(3)(11). i Principal Reviewer: H. Ashar. DE/ECGB i Date: July 3, 1997 1
,