ML20100H884

Submits Suppl Info Re Application for Amends to Licenses NPF-37,NPF-66,NPF-72 & NPF-77,respectively,proposing to Revise Ten of Line Item TS Improvements Recommended by GL 93-05

ML20100H884
Person / Time
Site:	Byron, Braidwood
Issue date:	02/21/1996
From:	Lesniak M COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-93-05, GL-93-5, NUDOCS 9602280109
Download: ML20100H884 (9)

Text

CommonwcElth FAiwn Compary 1400 Opus Place t

Downers Grove,IL 605155701 February 21,1996 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Supplemental Information regarding the Application for Amendment to Appendix A, Technical Specifications for Facility Operating Licenses:

Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Generic Letter 93-05 Line Item Improvements

References:

Ladies and Gentlemen:

In Reference (3), Commonwealth Edison Company (Comed) proposed to amend Appendix A, Technical Specifications, for Facility Operating Licenses NPF-37, NPF-66 NPF-72, and NPF-77 for Byron Nuclear Power Station, Units 1 and 2 (Byron), and Braidwood Nuclear Power Station, Units 1 and 2 (Braidwood), respectively. Comed proposed to revise 10 of the line item technical specification (TS) improvements i

recommended by Generic Letter (GL) 93-05 (Reference 2).

j GL 93-05, Enclosure 1, provided guidance for implementing line item TS improvements to reduce testing during power operation. In part, the United States Nuclear Regulatory Commission (NRC) staff requested that "each licensee should include in the license amendment request that all proposed TS changes are compatible with plant operating experience and are consistent with this guidance." Comed believes that the plant operating experience at both Byron and Braidwood are j

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PDR A Unicom Company

NRC Document Control Desk February 21,1996 5

i consistent with the guidance provided in NUREG-1366 (Reference 1) and GL 93-05.

A brief summary of the plant operating experience at Byron and Braidwood for each of the requested line item improvements is included in Attachment 2.

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To the best of my knowledge and belief, the statements contained in this document are.

i true and correct. In some respects these statements are not based on my personal knowledge, but on information furnished by other Comed employees, contracter 4

employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.

Please address any comments or questions regarding this matter to this office.

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5 Very truly yours, t

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i Marcia T. Lesniak Nuclear Licensing Administrator 1

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!"UFRCIAL SEAL............._

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l : References j

, : Summary of Byron / Braidwood Operating Experience j

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cc:

H.'J. Miller, Regional Administrator - RIII I

l G. F. Dick Jr., Byron Project Manager - NRR j

R. R. Assa, Braidwood Project Manager - NRR i

H. Peterson, Senior Resident Inspector - Byron C. J. Phillips, Senior Resident Inspector - Braidwood Office of Nuclear Facility Safety - IDNS

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l ATTACHMENT 1 1

1 References 1.

NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements," dated December 1992 2.

United States Nuclear Regulatory Commission Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing during Power Operation," dated September 27,1993 l

3.

Harold D. Pontious, Jr. (Comed) letter to NRC Document Control Desk,

" Application for Amendment A, Technical Specifications, for Facility Operating Licenses NPF-37,66,72, and 77, regarding Generic Letter 93-05 Line Item Improvements," dated October 3,1995 I

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c ATTACHMENT 2 SUMM ARY OF BYRON / BRAIDWOOD OPERATING EXPERIENCE 1.

Surveillance Requirement 4.1.3.1.2 (Generic Letter Item 4.2)

A review of the surveillance history for the rod control system at Byron and Braidwood has shown that the movable control assemblies monthly surveillance has been performed at least 100 times on each of the units. There have been no instances in which an untrippable control rod was detected as a result of this surveillance. However, there have been instances in which immovable control rods, as a result of electrical failures within the rod control system (e.g., failed cards, blown fuses, etc.) were detected.

A review of the corrective and preventative maintenance history for the rod a

control system at Byron and Braidwood has shown that there have been no 3

component failures identified during maintenance activities that could have resulted in an untrippable control rod.

J A review of the operating history for the rod control system at Byron and Braidwood has shown that all control rods have fully inserted on each reactor trip of the Byron and Braidwood units except for one instance at Braidwood Unit 2. That instance occurred on April 5,1994, when one control rod, Control Rod K-2 in Control Bank B, failed to insert beyond 210 steps following a reactor trip due to an in-core thermocouple column funnel pin having worked itself loose, dropped down, and obstructed the movement of Control Rod K-2. This condition would have been undetectable by the j

performance of the movable control assemblies monthly surveillance. The details of this event are documented in the NRC Augmented Inspection Team (AIT) Inspection Report Nos. 50-456/94013(DRS); 50-457/94013(DRS).

2.

Table 4.3-3 (Generic Letter Item 5.14)

A review of the surveillance history for radiation monitors ORE-AR055/56, Fuel Building Isolation-Radioactivity-High and Criticality,1/2RE-AR011/12 j

Containment Isolation-Containment Radioactivity-High,1/2RE-PR01IB, j

Gaseous Radioactivity-RCS Leakage Detection,1/2RE-PR011 A, Particulate Radioactivity-RCS Leakage Detection, ORE-PR031B/32B/33B/34B, Main Control Room isolation-Outside Air Intake-Gaseous Radioactivity High, at Byron and Braidwood has revealed no failures of the monthly digital channel operational test.,

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SUMMARY

OF BYRON / HRAIDWOOD OPERATING EXPERIENCE (Continued) l A review of the corrective and preventative maintenance history for radiation monitors ORE-AR055/56, Fuel Building Isolation-Radioactivity-High and Criticality,1/2RE-AR011/12, Containment Isolation-Containment Radioactivity-High,1/2RE-PR011B, Gaseous Radioactivity-RCS leakage Detection,1/2RE-PR011 A, Particulate Radioactivity-RCS Leakage Detection, ORE-PR031B/32B/33B/34B, Main Control Room Isolation-Outside Air Intake-Gaseous Radioactivity High, at Byron and Braidwood has shown that there have been no component failures identified during maintenance activities that could have resulted in these radiation monitors failing to fulfill their intended safety function. These monitors are designed to " fail" to their

" safe" position. Historically, the first indication of a problem with these radiation monitors has been an alarm alerting the control room operators of a potential problem.

A review of the operating history for radiation monitors ORE-AR055/56, Fuel Building Isolation-Radioactivity-High and Criticality,1/2RE-AR011/12, Containment Isolation-Containment Radioactivity-High,1/2RE-PR011B, Gaseous Radioactivity-RCS Leakage Detection,1/2RE-PR0ll A, Particulate Radioactivity-RCS Leakage Detection, ORE-PR031B/32B/33B/348, Main Control Room Isolation-Outside Air i

Intake-Gaseous Radioactivity High, at' Byron and Brai,dwood has shown that these radiation monitors have always performed their intended safety function when challenged.

3.

Surveillance Requirement 4.4.3.2 (Generic Letter item 6.6)

I A review of the surveillance history for the pressurizer heaters at Byron and Braidwood has shown that there have been no failures of the heater group capacity quarterly surveillance.

A review of the corrective and preventative maintenance history for the pressurizer heaters at Byron and Braidwood has shown that there has been little maintenance required on this equipment. There have been no component failures identified during these maintenance activities that could have resulted in a failure of a pressurizer heater group to energize.

A review of the operating history for the pressurizer heaters at Byron and Braidwood has shown that the required pressurizer heater groups have always been available to support plant operations.

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SUMMARY

OF BYRON / BRAIDWOOD OPERATING EXPERIENCE (Continued) 4.

Surveillance Itequirement 4.4.6.2.2.b (Generic Letter Item 6.1)

A review of the surveillance history for the reactor coolant system (RCS) pressure isolation valves (PIVs), as specified in Table 3.4-1, at Byron and Braidwood has shown that there has been only one valve at Byron, ISI8905A, that has failed this surveillance. That valve has failed this surveillance twice. After the first failure, the valve was disassembled and inspected. Nothing abnormal was found. The valve was reassembled and passed the surveillance. Some time later, the valve began to exhibit signs of leakage. Initially, the valve was placed on increased frequency to monitor the leakage trend. Eventually, the valve was replaced due to excessive leakage.

A review of the corrective and preventative maintenance history for the RCS PIVs at Byron and Braidwood has shown that there has been no component failures identified during these maintenance activities that could have resulted in a failure of an RCS PIV to perform its intended safety function.

A review of the operating history for the RCS PIVs at Byron and Braidwood has shown that the RCS PIVs have always performed their intended safety function when challenged.

5.

Surveillance Requirement 4.5.1.1.b (Generic Letter Item 7.1)

There is no operational data relevant to verifying the boron concentration of the accumulator solution.

6.

Surveillance Requirement 4.6.2.1 (Generic Letter Item 8.1)

A review of the surveillance history for the containment spray system header ilow test at Byron and Braidwood has shown that there have been no failures.

A review of the corrective and preventative maintenance history for the containment spray system header at Byron and Braidwood has shown that there has been no maintenance required.

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SUMMARY

OF BYRON / BRAIDWOOD i

OPERA. TING EXPERIENCE (Continued) 1 A review of the operating history for the containment spray system headers at Byron and Braidwood has shown that these systems have not been challenged to perform

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their intended safety function.

7.

Surveillance Requirement 4.6.4.1 (Generic Letter Item 5.4)

A review of the surveillance history for the post-LOCA containment hydrogen I

monitors at Byron and Braidwood has shown that the monthly analog channel operational test has been performed at least 200 times on each of the units. There are 1I documented failures of this surveillance. A review of the surveillance history for the post-LOCA containment hydrogen monitors at Byron and Braidwood has shown that the quarterly channel calibration has been performed at least 150 times on each of the units. There are 4 documented failures of this surveillance.

A review of the corrective and preventative maintenance history for the post-LOCA containment hydrogen monitors at Byron and Braidwood has shown that there has been no additional components identified during these maintenance activities that would have resulted in the post-LOCA containment hydrogen monitors being unable to perform their intended safety function.

A review of the operating history for the post-LOCA hydrogen monitors at Byron and Braidwood has shown that these systems have not been challenged to perform their intended safety function. During the past year, there has been escalated enforcement action taken at both Byron and Braidwood regarding post-LOCA hydrogen monitor operability issues as a result of configuration control issues. In both cases, the improper configuration was not detectable through the performance of either the monthly analog channel operational test or quarterly channel calibration. The details l

l of these events can be found in Inspection Reports 50-454/95008(DRP); 50-l'

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455/95008(DRP) and 50-456/95005(DRP); 50-457/95005(DRP).

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i SUMM ARY OF BYRON / HRAIDWOOD OPERATING EXPERIENCE (Continued) 8.

Surveillance Requirement 4.6.4.2 (Generic Letter Item 8.5)

A review of the surveillance history for the post-LOCA containment hydrogen recombiners at Byron and Braidwood has thown that the functional test has been performed at least 20 times on each of the units. There are four documented failures of this surveillance. In three of the four cases. the surveillance was immediately reperformed and successfully completed.

t A review of the corrective and preventative maintenance history for the post-LOCA containment hydrogen recombiners at Byron and Braidwood has shown that there have been no additional component failures identified during maintenance activities that could have resulted in these systems failing to fulfill their intended safety function.

A review of the operating history for the post-LOCA containment hydrogen recombiners at Byron and Braidwood has shown that these systems have not been called upon to perform their intended safety function.

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Surveillance Requirement 4.7.1.2.1 (Generic Letter Item 9.1)

A review of the surveillance history for the auxiliary feedwater pumps at Byron and Braidwood has shown that these pumps have been run at least 100 times on each of the units for surveillance testing. There are two documented failures of this surveillance.

A review of the corrective and preventative maintenance history for the auxiliary feedwater pumps at Byron and Braidwood has shown that there have been no additional component failures identified during maintenance activities that could have resulted in these systems failing to fulfill their intended safety function.

A review of the operating history for the auxiliary feedwater pumps at Byron and Braidwood has shown that when these pumps were required to be operable, they have always performed their intended safety function when challenged..

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SUMMARY

OF BYRON / BRAIDWOOD OPERATING EXPERIENCE (Continued) i 10.

Surveillance Requirement 4.11.2.6 (Generic Letter Item 13)

There is no operational data relevant to determining the quantity of radioactive material contained in each gas decay tank.

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