ML20245L041

Suppl to Application for Amend to Licenses NPF-11 & NPF-18, Revising Tech Specs to Conform W/Diesel Generator Test Schedule Recommendations of Generic Ltr 84-15

ML20245L041
Person / Time
Site:	LaSalle
Issue date:	06/23/1989
From:	Morgan W COMMONWEALTH EDISON CO.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20245L044	List: ML20245L041 ML20245L058
References
GL-84-15, NUDOCS 8907050354
Download: ML20245L041 (5)

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Y' , Commonw.rlth Edison

! . .- [ / 72 West Adams Stroot Chicago, Illinois f' I

\ 7 ddress Reply to: Post OTEe~8FfBT i-k/ Chicago, Illinois 60690 0767 June 23, 1989 l

Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

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Subject:

LaSd le County Station Units 1 and 2 Suppe; r ment to Application for Amendment to Facility Operating Licenses NPF-11 and NPF-18, Technical Specification -

Implementation of Generic Letter 84-15 Diesel Generator Recommendations MRC_ Docket Nos. 50-373 and 50-374 References (a): W.E. Morgan letter to U.S. NRC dated March 16, 1989, Application for Amendment to FOL NPF-11 and NPF-18.

(b): W.E. Morgan letter to T.E. Murley dated June 16, 1989, Proposed Waiver of Compliance (c): B.L. Siegel letter to T.J. Kovach dated June 16, 1989, Approval of Temporary Waiver of Compliance request.

Dear Dr. Murley:

Reference (a) submitted Commonwealth Edison's request for an amendment to Facility Operating Licenses NPF-11 end NPF-18, Appendix A, Technical Specifications. The purpose of this snendment request was to revise the Technical Specifications to conform with the diesel generator test schedule recommendations given in NRC Generic Letter 84-15.

Subsequent to this request, Commonwealth Edison became aware that the guidance in Generic Letter 84-15 could be extended to include changes to the Technical Specification which would further increase the reliability of the diesel generators by eliminating unnecessary surveillance requirements.

Commonwealth Edison LaSalle County Station (Reference (b)) requested and was granted (Reference (c)) a temporary W'aiver of Compliance to eliminate surveillance requirements that placed an undue burden on the Diesel Generators that could potentially affect their operation when required.

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Dr.:T.E.LMurley ' June 23, 1989 It was agreed in Reference-(c)'that Commonwealth Edison would supplement.their existing Diesel Generator Technical Specification amendment requestL(dated March 16, 1989). eliminating the unnecessary surveillance requirements.

The following attachments provide the supplement to the original proposed snendment request.

Attachment.A contains background information and justification for the proposed change. Attachment B contains_the proposed changes to the Technical: Specifications. The proposed Technical Specification changes have been reviewed and approved by both on-site'and off-site review in accordance with Commonwealth Edison Company procedures. We have reviewed this snendment in accordance with 10'CFR 50.92(c)'and have determined.that no significant hazards consideration exists. Our evaluation is documented in Attachment C.

' Attachment'D provides Clinton Nuclear Power Station Unit 1 Technical Specifications,'which this submittal is patterned after.

. Commonwealth Edison is-notifying the State of Illinois of our supplemental application for this amendment by transmitting a copy of this letter and its attachments to.the designated State Official.

Please direct any questions you may have regarding this matter to this office.

Very truly yours, 4 41 W. . Morgan _ {

Nuclear Licensing Administrator i 1m Attachments A: Background and Discussion B Proposed Technical Specification Change C: Evaluation of Significant Hazards Consideration D: Clinton Nuclear Power Station Unit 1 Tech Specs cc: Regional Administrator - Region III Senior Resident Inspector - LaSalle County Office of Nuclear Facility' Safety - IDNS P.C. Shemanski - Project Manager, NRR 0183T:1-2 1

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61 ' e-e ATIACHMRILA IICHli1 CAL SPECIFICATION CHANGE REWESI LASALLE COUNTY STATION UNITS 1 AND 2

'i J EACEGROUND l

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On March 16, 1989, Commonwealth Edison submitted a request (Reference 1

(a)) to the NRC ta) upgrade the LaSalle Station Technical Specifications _to meet the recommendations of Generic Letter 84-15. -Subsequent to the LaSalle Station Technical Specification mnendment request submittal, Commonwealth Edison became aware that the guidance in Generic Letter 84-15 could be extended to include. changes to the action statements for Specification 3/4.8.1.1 which would further increase diesel generator reliability. The AC Sources l

specification was rewritten to. limit the number of diesel generator starts resulting from application of the action statement requirements. This submitt'al has been prepared in response to Reference (c).

DIECUEEIM The importance of diesel generator reliability was recognized in Unresolved Safety Issue A-44, " Station Blackout", and as part of the technical evaluation of this issue, the NRC issued Generic Letter 84-15 which provided guidance for steps which could be taken to improve diesel generator reliability. This document provides a proposal for a technical specification surveillance testing schedule which is. designed to help ensure diesel generator reliability without requiring an excessive amount of testing. On March 16, 1989, Commonwealth Edison submitted an snendment request (Reference (a)) to bring the LaSalle Station Technical Specifications into conformance with these proposals. The NRC, upon review of the March 16, 1989 submittal, requested that Commonwealth Edison go one step further and limit the number of starts required in the Technical Specification action statements. Based on this request, Commonwealth Edison is providing this supplemental submittal to amend the action statements for Specification 3/4.8.1.1. The amendment is patterned after the Clinton Station Technical Specifications (Attachment D).

It has been noted that an apparent inconsistency exists between Actions a and c of the Clinton Station Technical Specification. Action a applies to the situation where one off-site circuit and either Division 1 or 2 diesel generator is inoperable. If one off-site circuit is found to be inoperable, all diesel generators not tested in the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> must be l tested under the provisions of Action a. However, if a diesel generator were out-of-service for preplanned maintenance and an of f site circuit is thca found to be inoperable, under the provisions of Action c the other diesel generators would not be required to be tested. While Action c does appear to be less l

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conservative than Action a in.this respect, it is in the opinion of LaSalle

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Station.that the inconsistency results from Action a being overly conservative -j rather than Action c being less conservative for the following reasons :

• . Action c.follows the logic of Action b with respect to diesel generator testing except.that Action c only allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for .

. testing while Action.b allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Since Action c involves a .i more serious. situation,'it.follows'that a shorter time for testing is  ;

appropriate. j

• . The testing of the diesel generators required in Action a is overly ~

conservative since a problem with an offsite circuit cannot involve a generic problem affecting'the diesel generators. If all scheduled-diesel generator surveillance are. current in accordance with the

-diesel generator. test schedules, it is reasonable to. assume that any testing. completed in response to Action a will merely confirm the operability of the diesel generators.

While Action a can be viewed as being overly conservative, it does not place unreasonable restrictions on.the station, and in the effort to

- maintain consistency with the Clinton technical specifications LaSalle Station accepts Action St%tement'a as it is written.

The proposed amendments will help to improve diesel generator reliability by. minimizing the number of diesel generator starts required by the Technical Specification action statements.

In the original, submittal to the NRC it was requested under Additional Administrative Changes (Attachment A, Page 4, Paragraph 1) that the footnote at the bottom of Page 3/4.8-l'and Page 3/34.8.la be deleted from the Technical Specifications. This request was made in error and both items identified in Paragraph 1 must remain in the Technical Specifications. It is, therefore, requested that the paragraph referenced above be deleted from the original submittal.

EUMBEX Based on the above discussion, it is requested that the Technical Specifications be amended to include the proposed amendments contained in Attachment B and the original submittal (Reference (a)) be amended as indicated above.

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ATIACIMaiI ll PROPOSED CHANGES _lQ_THE_,_IIfENICAL SPECIFICATIONS f.QB.__QfERATING LICENSES _XPF-ll AHD._RPL-JE BIYlSED_PAGES: 3/4 8-1 delete page 3/4 8-1 delete page 3/4 8-2 delete page 3/4 8-2 delete page 3/4 8-1 new page 3/4 8-1 new page 3/4 8-la 3/4 8-la 3/4 8-2 new page 3/4 8-2 new page 3/4 8-2a new page 3/4 8-2a new page 3/4 8-2b new page 3/4 8-2b new page i

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