ML20090A254

Revised TS Pages 3/4 2-9 Re Measurement of RCS Total Flow Rate

ML20090A254
Person / Time
Site:	Byron, Braidwood
Issue date:	02/27/1992
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20090A251	List: ML20090A245 ML20090A254
References
NUDOCS 9203020212
Download: ML20090A254 (8)

Text

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ATTACHMENT A PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS FOR FACILITY OPERATING LICENSES NPF 37,66,72, and 77

]

Revised Pages 3/4 2 9 -

P P C O 454

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- . . _ _ - -,_ - ~ . - .- - . - _ _ - ~ . ~ _ _ _

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IlifiTING t.OND!?!Ofi10R p [ G!!c:'

AC110N (Continued)

b. Within 24 houet of initially being outside the above limits, verify through incore flui n'apping and RCS total flow rate comparison that O

the combination of ]f4H and RCS total flow rate are restored to

within the above limits, or reduce THERMA < POWER to less than Si of g RATED 1HERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; and

+ 0 c. Identify and correct the cause of the out-of-limit condition prior j'N y to increasing THERMAL POWER above the reduced THERMAL POWER limit required by ACTION a.2. and/or b. above; subsequent POWER OPERAT10!i U

Lbp may proceed provided that the combination of F"h o and indicated RCS (c

F J o

total flow rate are demonstrated, through incore flux mapping and RCS total flow rate comparison, to be within the region of acceptable

'.11. operation defined by Specification 3.2.3 prior to exceeding the fol-f). j $ lowing THERMAL POWER levels:

3 [d j

1.

2.

A nominal 50% or RATED THERMAL POWER, A nominal 75% of RATED THERMAL POWER, and T. 3. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining greater than or equal to 95% of IL f0 8 RATED THERMAL POWER.

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SURVEILLAtiCE REQUIREMENTS j d'I 4.2.3,1 The provisions of Specification 4.0.4 are not applicable.

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L 4.2.3.2 The combination of indicated RCS total flow rate and F g shan be deter,nined to be within the region of acceptable operation of 4

[ do d Specification 3.2.3:

O 'b N a. 'ior-to operation above 75% of RATED THERMAL POWER after each fuel luading, and 43 b. At least once per 31 Effective Full Power Days.

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g 4.2.3.3 The indicated PsC5 total flow rate shall be verified to be within the region of acceptable operation of Specification 3.2.3 at least once per 12 nours b when the most recently obtained value of F g, obtained per Specification 4.2.3.2, is assumed to exist.

4.2.3.4 The RCS total flow rate indicato s shall be subjected to a CHANNEL CAllBRATION at least once per 18 months. l l _ 4.2.3.5....The RCS total flow rate shall be determined by precision heat balance l measurementb i lesst s ce pcr 10 nnthe. The measurement instrumentation shall

! be calibrated within seven days prior to the performance of the calorimetric flow measurement. Prior to the precision heat balance measurement, at least two of the four feedwater flow meter venturis shall be visually inspected and, if fouling is found, all venturis shall be cleaned.

3The :,peci' icd IS ,anth 2,te = 1 'ny bt -te^ded to 3 -

mem@r Cyd e 1 nais. I BYRON - UNITE ' & 2 - 3/4 2-9 AMENDMENT NO I

- - _ _ _ _ _ _ _ _ ____m r - --

POWER DISTRIBUTION LIMITS LIMITING CONDITION FOR OPERATION ACTION (Continued)

b. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of initially being outside the huove limits, verify through incore flux mapping and RCS total flow rate comparison that thecombinationofFhandRCStotalflowratearerestoredto G within the above limits, or reduce THERMAL POWER to less than 5% of.

dS 0 y RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; and g_g c. Identify _and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced THERMAL POWER limit

=4 o gg required by ACTION a.2. and/or b. above; subsequent POWER OPERATION ,

N d -g may proceed provided that the combination of F and indicated RCS

& I, total flow rate are demonstrated, through incore flux mapping and 5.T RCS total flow rate comparison,.to be within the region of acceptable operation defined by Specification 3.2.3 prior to exceeding the fol-

{,, . lowing THERMAL POWER levels:

p .f. L 1.- A nominal 50% of RATED' THERMAL POWER, W%

9 2. A nominal 75% of RATED THERMAL POWER, and

.O" 'E 4-

3. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining greater than or equal to 95% of~

hg*9 RATED THERMAL POWER.

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SURVEILLANCE REQUIREMENTS 4.2.3.1_ The provisions of Specification 4.0.4 are not applicable.

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• N 0- 4.2.3.2 The combination of indicated RCS tothl flow rate and F g shall be deter-4 mined to be within the region of acceptable operation of Specification 3.2.3:

4

a. Prior to operation above 75% of RATED THERMAL POWER after each fuel 5.*

_g

- loading, and 0G b. At least once per 31 Effective Full Power Days, i- -o h 4.2.3.3 The indicated RCS total flow rate shall be verified to be within the

-M 3 g region of acceptable operation of Specification 3.2.3 at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> al when the most recently obtained-value of Fh, obtained per Specification 4.2.3.2,

- thg I is assumed to exist.

c y- 4.2.3.4 The RCS total flow rate indicators shall be subjected to a CHANNEL  %

CALIBRATION at least once per 18 monthsf4 4.2.3.5 The RCS total flow rate shall be determined by precision heat balance measurementTet 1:::t once p;r 18 = th:- The measurement instrumentation shall be calibrated within seven days prior to the performance of the calorimetric flow measurement. . Prior to the precision heat balance measurement, at least two of the four feedwater flow meter venturis shall be visually inspected' and, l- .if_ fouling is found -all venturis shall be cleaned, ir

-month inte 5&y-be444dd M M-4onO@My@ l y-

. i .,,;cif

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BRAIDWOOD - UNITS 1 & 2- 3/4 2-9 AMENDMENT NO.

9 ATTACHMENT B DETAILED DESCRIPTION BASIS FOR THE EXISTING TECHNICAL SPECIFICATION:

The existing Specification 4.2.3.5 requires that the "The RCS total flow rate shall be determined by precision heat balance measurement at least once per 18 months."

The purpose of this surveillance is to assure that the RCS flowrale is verified after

- each refueling. This testing is performed as part of PHYSICS TESTS during the startup following each refueling outage. The existing surveillance does not specify any power restrictions for performance of this test. The testing was previously performed at approximately 75% RATED THERMAL POWER (RTP). Currently, this testing is performed at greater than 90% RTP por CECO Engineering recommendations based on Westinghouse report WCAP-12523.

BASIS FOR THE PREVIOUS TECHNICAL SPECIFICATION CHANGE REQUEST:

The previous request added the statement " prior to exceeding 75% of RATED THERMAL POWER" to Surveillance 4.2.3.5. This phrase was added to put a limitation on when the surveillance could be performed. The concern is that it is not prudent to operate at power for an extended period of time prior to verifying the precision of the RCS flowrate. The power level of 75% was chosen primarily because it is consistent with the RCS flow check required by surveillance 4.2.3.2 and the plant procedures current at the time of our submittal.

The statement "The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time provisions of Specification 4.0.3 are not applicable" was added. Due to the preparation time and required plant conditions, this surveillance cannot be completed in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, therefore, the relief granted by Specification 4.0.3 was not considered a viable alternative. This statement also emphasizes the importance of performing this surveillance prior to extended power operations since no relief for performing the surveillance is allowed l

through Specification 4.0.3.

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DESCRIPTION OF THE PROPOSED TECHNICA!_ SPECIFICATION CHANGE REQUEST:

The proposed changes deletes the words "at least once per 18 months" and adds the phrase " prior to completion of PHYSICS TESTS after each fuel loading " This phrase will ensure that the RCS flow precision heat balance measurement is performed prior to resuming normal power operations foilowing each refueling. The 18 month requirement is redundant since requiring the surveillance to be performed prior to completion of PHYSICS TESTS assures performance at approximately this interval. This wording also allows flexibility if the sarveillance cannot be performed within 18 months due to extended refueling or maintenance outages. Since the purpose of the 18 month requirement is to ensure that the surveillance is performed prior to extended power operations, we believe the new wording still meets the intent of the original specification. The proposed wording also allows the performance of this surveillance at any power level. This is also consistent with the original specification. This change would allow us to perform the surveillance at greater than 90% RTP por Engineering's recommendations.

The statement "The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time provisions of Specification 4.0.3 are not applicable" is retained but placed in a different position in the paragraph to flow better with the text. This change is purely editord 'n nature. In addition, we would like to delete the note at the bottom of page 3/4 r 9 since it no longer applies. This change is also editorial.

BASIS FOR THE PROPOSED TECHNICAL SPECIFICATION CHANGE REQUEST:

Westinghouse Electric Company issued WCAP-12523 in October 1990. In this report, Westinghouse analyzed the design basis for the reactor protection system setpoints.

Specific guidance was given on the proper methods for accounting for instrumentation -

uncertainties. After reviewing this document, CECO Engineering performed calculations to verify the adequacy of current testing methodology. Engineering determined that in order to assure Technical Specifications acceptance criteria were conservative with respect to the analysis, the provision heat balance should be performed at greater than 90% RTP. Engineering calculations showed that if the precision heat balance was performed at less than 75% RTP, procedural acceptance criteria for RCS flow rate would have to be higher than the Technical Specifications limit. This would be necessary in order to account for the increased instrument uncertainties. In order to avoid this situation, CECO wishes to revise our previous request that would require performing the precision heat balance at less than 75% RTP.

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• l ATTACHMENT C 10CFR 50.92 SIGNIFICANT HAZARDS CONSIDERATION The Commission may make a final determination that an amendment does not involve a significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

1. Involve a significant increase in the probability or 3 consequences of an accident previously evaluated; or

2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3. Involve a significant reduction in a margin of safety.

Commonwealth Edison has reviewed the proposed changes for significant hazards consideration in accordance with these criteria. The results of this review are given below.

The proposed change provides clarification on when the precision heat balance will be performed. Performance of the surveillanco as indicated will ensure that all assumptions made in the accident analysis are valid. Therefore, this change does not result in an increase in the probability or consequences of a previously analyzed accident.

All initial accident assumptions remain valid. No new operating conditions are proposed by this change. Current Technical Specifications allow operation in the manner proposed by this change. Therefore, this change will not create the possibility of a new or different accident.-

This change is primarily administrative in nature. The change will not permit operation in a manner prohibited by the current Technical Specifications. This change provides clarification on the performance of Surveillance 4.2.3.5 based on the latest evaluation of instrument uncertainties. The proposed method of testing ensures that initial conditions are maintained and assumed in the analysis. No change is being made to the intent of the Technical Specification. Therefore, this change does not result in the decrease of any margin of safety stated in the Bases of the Technical Specification.

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. Based on the above this change will not increase the probability or consequences of a  ;

previously analyzed accident, Introduce the possibility of an accident not previously evaluated or decrease the margin of safety. The proposed change is primarily administrativo in nature and does not chango the Slgnificant Hazards Consideration ovaluation provided in Reference a.

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i ATTACitMENT D ENVIRONMENTAL. ASSESSMENT t c

Commonwealth Edison has ovaluated the proposed amendment agalnot the critoria for an identification of licensing and regulatory actions requiring environmental assessment  !

in accordance with 10 CFR 51.21, It has boon dolormlned that the proposed chango moots the critoria for a categorical exclusion as provided for under 10CFR51.22(c)(9).

The propvsed changes provides clarification on the performance of the proclsion heat balanco. This chango does not affect the requlromonts or Intent of the Technical Specifications.  !

The proposed chango does not involve a significant hazards consideration as discussed in Attachment C to this letter. Also, this proposed amendment will not involve significant changes in the types or amounts of any radioactive offluents nor does it affect any of the permittod release paths. In addition, this chan00 deos not involve a sl0nificant increase ,

in individual or cumulative occumtional exposure. Thorofore, this change moots the catoDorical excittsion partnitted oy 10CFR51.22(c)(9).

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