ML20206T133

Application for Amends to Licenses NPF-11 & NPF-18, Relocating TS Section 3/4.4.4, Chemistry, to UFSAR to Be Consistent with NUREG-1433,rev 1

ML20206T133
Person / Time
Site:	LaSalle
Issue date:	05/19/1999
From:	Benjamin B COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206T138	List: ML20206T133 ML20206T140
References
RTR-NUREG-1433 NUDOCS 9905240079
Download: ML20206T133 (8)

Text

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Commonw calth I-:dison Comlun) lasalle Generating Station

. 2601 Nortit 21st Ruatl s . Niarseilles. ll. 613 il-9'S~

'Irl H1435 6"'61 May 19,1999 i United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Application for Amendment to Appendix A, Technical Specifications, Relocation of l Technical Specification 3/4.4.4, " Chemistry" I

Reference:

See Attachment A,Section I.

In accordance with 10 CFR 50.90, Commonwealth Edison (Comed) Company i proposes a change to Appendix A, Technical Specifications (TS), Facility l Operating Licenses NPF-11 and NPF-18. The application for amendment proposes a change to Technical Specification (TS) Section 3/4.4.4, Chemistry.

The requested changes relocate the Chemistry TS requirements to the Updated Final Safety Analysis Report (UFSAR) and Administrative Technical Requirement that has been incorporated into the UFSAR by reference and '

controlled by the 10CFR50.59 process. This change is consistent with the {

Improved Standard Technical Specifications (ISTS) as documented in NUREG-1433, Revision 1, and as previously approved for the James A. Fitzpatrick Nuclear Power Plant, (Reference 1.1). It is also similar to ) 1 the change submitted by Quad Cities Nuclear Power Station (Reference 1.2) and I recently approved the NRC (Reference 1.3). Tho TS for reactor coolant chemistry limits contain requirements for reactor coolant conductivity, chloride concentration, and pH. The TS for chemistry limits do not meet an screening p c\o criteria for retention in the TS in accordance with the NRC's Final Policy i Statement on Technical Specification improyements (Reference 1.4).

I 9905240079 990519 PDR ADOCK 05000373 L P PDR _l ,.,

4 i mcom Company 1 L j

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May 19,1999

. U,S. Nuclear Regulatory Commission Page 2 The purpose of this amendment is to support injection of noble metal compounds into the reactor vessel to prevent crack initiation and to mitigate any existing crack growth in the reactor vessel surfaces, intemal components and piping due to Intergranular Stress Corrosion Cracking (IGSCC). The noble metal solutions injected into the reactor coolant are expected to temporarily increase reactor coolant conductivity and pH levels.

This increase is only expected during the metal application period, which is .

planned to occur in operational mode 3. The reactor water cleanup system )

will be used to reduce the conductivity and pH levels to normal I l

pre-application operation levels. This process has been previously reviewed and approved by the USNRC for use at the Duane Amold Energy Center (Reference 1.5). Comed's long range plan included the application of this process for the Unit 1 refueling outage scheduled for the fourth quarter of i this year. Therefore, Comed requests approval of this amendment prior to I October 1,1999 to support the planned refueling Unit 1 outage scheduled to begin October 23,1999.'

This proposed amendment request is subdivided as follows:

-1. Attachment A gives'a description and safety analysis of the proposed changes in this amendment.

2.' Attachment B includes the marked-up Technical Specification pages with the requested changes indicated.

3. Attachment C describes Comed's evaluation performed in accordance with 10 CFR 50.92(c), which confirms that no significant hazards consideration is involved.

.4. Attachment D provides information supporting an Environmental Assessment.

This proposed amendment has been reviewed and approved by Comed Onsite and Offsite Review in accordance with Comed procedures, j I-l 1

1 1

c j

May 19,1999

. U.S. Nuclear Regulatory Commission Page 3 Comed is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If there are any questions or comments conceming this letter, please refer )

them to Frank Spangenberg Ill, Regulatory Assurance Manager, at (815) 357-6761, extension 2383.

i Respectfully, Jeffrey A. Benjamin Site Vice President LaSalle County Station Attachments: A. Description and Safety Analysis for Proposed Changes I B. Marked-up Pages for Proposed Changes O. Significant Hazards Consideration D. Environmental Assessment cc: Regional Administrator - NRC Region 111 NRC Senior Resident inspector - LaSalle County Station Office of Nuclear Facility Safety - IDNS I

l

, STATE OF ILLINOIS )

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

COMMONWEALTH EDISON COMPANY )

LASALLE COUNTY STATION - UNITS 1 & 2 )

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

l A % - -

VWA. BenjamiQ Site Vice President i LaSalle County Station Subscribed and swom to before m,9, a Notary Public in and for the Sja,tp above named, this /9W/ day of MfX9t/ . /999 7 My Commission expires on

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0FFICIAL SEAL LYNN ELLEN GASSMAN NOTARY PUBUC, STATE OF ILUNOIS MY COMMIS$10N EXPtRES 1-24-2001

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l ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS

, . FOR PROPOSED CHANGES A.

SUMMARY

OF PROPOSED CHANGES In accordance with 10 CFR 50.90, Commonwealth Edison (Comed) Company proposes a change to Appendix A, Technical Specifications (TS), Facility Operating ,

Licenses NPF-11 and NPF-18. The application for amendment requests a change to l TS Section 3/4.4.4, Chemistry. The requested changes relocate the TS

. requirements to the Updated Final Safety Analysis Report (UFSAR) and Administrative Technical Requirement which has been incorporated into the UFSAR  !

by reference and controlled by the 10 CFR 50.59 process. This change is consistent l with the improved Standard Technical Specifications (ISTS) as documented in i NUREG-1433, Revision 1, and as previously approved for the James A. Fitzpatrick l Nuclear Power Plant, Reference 1.1 and the Quad Cities Nuclear Power Station, l Reference 1.3. The TS for reactor coolant chemistry limits contain requirements for I reactor coolant, conductivity, chloride concentration, and pH. The TS for chemistry limits do not meet any screening criteria for retention in the TS in accordance with the NRC's Final Policy Statement on Technical Specification Improvements, Raference 1.4.

l The proposed changes are described in Section E of this Attachment. The marked j up TS pages are shown in Attachment B.  !

B. DESCRIPTION OF THE CURRENT REQUIREMENTS TS Section 3/4 4.4 provides chemistry limits for the reactor coolant system for all i OPERATIONAL MODE (s). Table 3.4.4-1 provides limits on chlorides, conductivity i and pH. Appropriate action requirements and surveillance requirements are also provided.  !

Action (a) permits temporary operation with chemistry limits outside of the limits j required in OPERATIONAL MODE 1 without requiring NRC notification.

Action (b) applies to OPERATIONAL MODES 2 and 3 and also permits temporary operation with chemistry limits outside of the limits in Table 3.4.4-1 without requiring NRC notification.

Action (c) applies to all other times and also permits actions to restore chemistry

' limits without requiring NRC notification.

The surveillance requirements provide adequate assurance that concentrations in excess of the limits will be detected in sufficient time to take corrective action.

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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS

, .,- FOR PROPOSED CHANGES C. BASES FOR THE CURRENT REQUIREMENTS The chemistry limits for the reactor coolant system are established to prevent damage to the reactor materials in contact with the coolant. Chloride limits are specified to prevent stress corrosion cracking of the stainless steel. The effect of chloride is not as great when the oxygen concentration in the coolant is low, thus the

- higher limit on chlorides is permitted during power operation. During shutdown and refueling operations, the temperature necessary for stress corrosion to occur is not ,

present so high concentrations of chlorides are not considered harmful during these periods.

Conductivity is monitored on a continuous basis since changes in this parameter are an indication of abnormal conditions. When the conductivity is within limits, the pH, chlorides and other impurities affecting conductivity must also be within their acceptable limits.

D. NEED FOR REVISION OF THE REQUIREMENT Comed requests approval of this amendment prior to October 1,1999, to support activities associated with the planned Unit i refue!ing outage scheduled to begin October 23,1999. The purpose of this amendment is to support injection of noble .

metal compounds into the reactor vessel to prevent crack initiation and to mitigate j any existing crack grciteth in the reactor vessel surfaces, internal components and  ;

piping due to Intergranular Stress Corrosion Cracking (lGSCC). The noble metal i solutions injected into the reactor coolant will produce reaction byproducts that will ,

temporarily cause reactor coolant conductivity and pH levels to increase. This l

increase is only expected during the metal aoplication that is planned to occur in  ;

operational mode 3. The reactor water cleanup system will reduce the conductivity  ;

and pH levels to normal pre-application operation levels following the application. 1 This process has been previously reviewed and approved by the NRC for use at the Duane Arnold Energy (Reference 1.5), and Quad Cities Nuclear Generating Station (Reference 1.3).

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l ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS

, . FOR PROPOSED CHANGES t

E. DESCRIPTION OF THE PROPOSED CHANGES The requested change will relocate TS Section 3/4 4.4, Chemistry, to the UFSAR and to applicable plant procedures that are controlled by the 10CFR 50.59 process. 1 The marked up TS pages are shown in Attachment B.

F. SAFETY ANALYSIS OF THE PROPOSED CHANGES

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The NRC's final policy statement on TS Improvements for Nuclear Power Reactors, Reference 1.4), concluded that the purpose of the TS is to impose only those conditions or limitations upon reactor operations necessary to obviate the possibility )

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of an abnormal situation or event giving rise to an immediate threat to the public health and safety. The policy statement recommends that TS that do not meet the ,

screening criteria for retention as TS may be relocated to another licensee controlled document. The criteria is applied to the current TS for reactor coolant chemistry  ;

parameters as follows:

1. Chemistry parameters are not used to detect, and indicate in the control 1 room, a significant abnormal degradation of the reactor coolant pressure boundary.

2. Chemistry parameters are not used as an initial condition of a Design Basis Accident or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

3. Chemistry parameters are not used as part of the primary success path I l

and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. Operating experiences or probabilistic safety assessment related to Chemistry has not shown to be significant to public health and safety.  ;

(Section 3.5, Table 4-1 and Section 6 of Reference 1.6.) l The reactor coolant chemistry TS proposed to be relocated does not meet the screening criteria of 10 CFR 50.36 therefore does not warrant being in the TS. For these reasons, the proposed changes are administrative in nature. In addition, the proposed changes are consistent with the ISTS.

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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES G. IMPACT ON PREVIOUS SUBMITTALS Comed has reviewed the proposed Operating License Amendment request regarding impact on any previous submittals, and has determined that there is no impact on any outstanding previous submittals.

H. SCHEDULE REQUIREMENTS Comed requests approval of this amendment prior to October 1,1999, to support activities in the upcoming Unit 1 refueling outage scheduled to begin October 23, 1999.

1. REFERENCES

1) Letter from J. Williams (USNRC) to J. Knubel (Power Authority of the State of New York), dated December 1,1998, " Issuance of Amendment for James A. Fitzpatrick Nuclear Power Plant"

2) Letter from J.P. Dimmette (Comed) to U.S. NRC dated January 21, 1999," Application for Amendment to Appendix A, Technical Specifications, Relocation of Technical Specification 3/4.6.1, Primary System Boundary - Chemistry"

3) Letter from R.M. Pulsifer (USNRC) to O.D. Kingley dated March 31, 1999.," Issuance of Amendments"(Approving the amendment request submitted in Reference 2).

4) USNRC Final Policy Statement on Technical Specifications improvements for Nuclear Power Reactors,58 FR 39132, dated July 22,1993

5) Letter from G.B. Kelly (USNRC) to Lee Liu (Duane Arnold Energy Center), dated October 3,1996, " Amendment No. 218 to Facility Operating License DPR-49"

6) General Electric Topical Report NEDO-31466 dated November 1987,

" Technical Specification Screening Criteria Application and Risk Assessment."

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