ML20116F451
| ML20116F451 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 11/02/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20116F454 | List: |
| References | |
| NUDOCS 9211100315 | |
| Download: ML20116F451 (7) | |
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MFETY EVALVATIOff BY THE OFFICE OLNVCLEAR REACTOR REGUL ATIQN REL ATED TO AMENDMENT f40. 49 TO FACILITY OPERATitlG LICENSE N0. NPF-37, AMENDMENT NO. 49 10 fAClllTY OPERATING LI[1NSE NO. NPF-66, 6!iENDriENT fiL 38 TO FACILITY OPERAllNG llCENS.f. NO. NPF-72, AND AME!4DMENT f40. 38 TO FACllliY OPERATING LICENSE NO. NPF-77
[MMONWEAllH EDISON COMPAf]Y BYRON STATLQN. Vf11T_1.'05. 1 AND 2 BPAIDWOOQ_ STATION. UN17 NOS 1 AND 2 DOCKET 305. STf4 50-454. STN Sn >,S L STN 50-456 Af10 STN 50-457 1
1.0
]NTRODE.T10f1 By letter dated November 30, 1968, as supplemented on May 30, 1990, April 19, 1991, and February 27, 1992, Commonwealth Edison Company (CECO, the licensee) requested amendments to Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Unit Nos. I and 2, and Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Unit Nos. 1 and 2, respectively.
The proposed amendment would change the plant Technical Specifications (TS) based on the recommendations provided by the staff in Generic letter (GL) 87-09 related to the applicability of limiting conditions for operations (LCO) and the surveillance requirements of TS 3.0 and 4.0.
Specifically, the licensee i
has requested the following revisions to TS 3.0.4, 4.0.3 and 4.C.4 as follows:
Specification 3.0.4 is revised to define when '.ts provisions apply; i.e., when the affected action statements permit continued operaticn for an unlim " ed i
l period of time, instead of defining when the provisions of Specification 3.0.4 do not apply.
Specif cation 4.0.3 is revised to incorporate a 24-hour delay in iuplementing Action Requirements due to a missed surveillance when the Action Requirements provide a restoration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
St.ification 4.0.4 is revised to clarify that "This provision shall not pr n ent psssage through or to OPERATIONAL CONDITIONS as required to comply with Action Requirements."
2.0
[MLUATION The changes proposed by the licensee have been reviewed considering the limitations set forth in GL 87-09 for TS 3.0.4, 4.0.3, n.a 4.0.4 as follows:
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2-2.1 Specification 3.0.4 GL 87-09 recognizes, in part, that TS 3.0.4 unduly restricts facility operations when conformance to the Action Requirements provides an acceptable leve! of safety for continued operation in any mode.
For an LCO that has Action Requirer.ents permitting continued operation for an unlimited oeriod of time, entry into an operational mode or other specified condition of operation should be permitted in..ccordance with those Action Requirements. The restriction on change in operational modes or other specified conditions should apply orly when the Action Requirements establish a specified time interval in which the LC0 must be met or a shutdown of the facility would be required or where entry into that operational mode would result in entry into an Action Statement with such time constraints.
However, nothing in the staff position stated in GL 87-09 should be interpreted as endorsing or encouraging plant startup with inoperable equipment.
The GL 87-09 itself states that startup with inoperable equipment should be the uception reth. ' than the rule.
The licensee has provided confirmation that the remedial measures prescribed by the AC110N STATEMENT for each change involving TS 3.0.4 is consistent witt the updated Safety Analysis Report and its supporting safety analyses.
Further, the licensee has pwided confirmation and certification that appropriate administrative controls and procedures are in place for limiting the use of TS 3.0.4 exceptions in conjunction with its proposed TS change submitted in response to GL 87-09. Additionally, no changes are proposed that affect plant configurations, setpoints, operating parameters, or the operator / equipment interface.
Based on review of the licensee's proposal, and confirmations related above, we conclude in granting the exceations proposed in response to GL 87-09 that:
- 1) the remedial measures prescriaed by the ACTION STATEMENT for each change involving the applicability of the TS 3.0.4 exception should provide a sufflcient level of protection to )ermit sperational mode changes and safe t
long-term operaticn consistent wit 1 the plant's Updated Safety Analysis Report; and 2) the licensee has in place adequate administrative controls and procedures which will ensure that it will be the exception rather t'an the rule that startup of the plant with important safety features inopei ble will occur.
We therefore, find the following change to TS 3.0.4 proposed by the licenste to be acceptable:
" Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the-Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they.re nct met within a specified time interval.
Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued cption of the facility for an unlimited period of time."
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2.2 Specification 4.0.3 In GL 87-09, the staff stated that it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed, because the vast majority of surveillances demor. strate that systems or compcnents in fact are operable.
Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements apply, the TS should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance.
Thh time limit should be based on considerations of plant condition:,,
adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety signifi:ance of the delay in completion of the surveillance. After reviewing possible ?imits the staff concluded that, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed surveillance when outage times of the Action Requirements are less than that time limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the surveillance can be completed.
This limit does not waive compliav.e with TS 4.0.3.
llnder TS 4.0.3, the failure to perform a surveillanct requirement will continue to constitute noncompliance with the operability requirements of an LCO and to bring into play the applicable Action Requirements.
Based on the above, the following change to TS 4.0.3 is acceptable:
Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0. ', shall constitute noncnmpliance with the OPERABILITY requirements for a Limiting Condition for Operation.
The time limits of the ACTION Requirements are applicable at the time it is identified that a Survaillance Requirement has not been performed. The ACTION Requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION Requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2.3 Specification 4.0.4 TS 4.0.4 prohibits entry into n OPERATIONAL CONDITION or other specified condition until all required surveillances have been performed.
This could cause an interpretation problem wher. OPERATIONAL CONDlif 0N changes are required in ordered to comply with ACTION statements.
Specifically, two possible conflicts between TS 4 J.5 and 4.0.4 could exist.
TLe first conflict arises because TS 4.0.4 prohibits entry into an operational mode or other
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4 specified con 11 tion when swveillance requirements have not been performed within the spu ffhd s m u 11ance interval.
The CECO proposed modification to resolve this ccidlict thvalves the revision to TS 4.0.3 to permit a delay of u) to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application of the Action Requirements, as explained a)ove, and a clarification of TS 4.0.4 to allow passage through or to operational modes es required to comply with Action Requircments. The second potential conflict between TS 4.0.3 and 4.0.4 arises because an exception to the requirements of TS 4.0.4 is allowed when surveillance requirements can only be completed after entry into a mode or condition.
However, after entry into this mode or condition, the requirements of TS 4.0.3 may not be met because the surveillance requirements may not have been performed within the allowable surveillance interval.
The licensee proposes to resolve these conflicts by providing the following clarifying statement to TS 4.0.4:
- This provision shall not prevent passage t,6. rough or to OPERATIONAL MODES as required to comply with ACTION requirements."
The NRC staff has provided in GL 87-09 a clarification that:
(a) it is not the intent to 4.0.3 that the Action Requirements preclude the performance of surveillance allowed under any exception to TS 4.0.4; and (b) that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in TS 4.0.3 for the applicability of Action Requirements provides an appropriate time limit for the completion of surveillance requirements that become applicable as a consequence of any exception to TS 4.0.4.
The NRC staff finds the proposed changes to TS 4.0.4 acceptable.
2.4 Specific tion 4.2.1.3 This change proposes that the initial determination of target axial flux difference following a refueling outage will be based on design predictions.
This is necessary because it is desirable to have some limits in place for the time period between unit restart from refueling and the establishment of proper plant conditions nectssary to complete surveillance.
Equilibrium xenon conditions with the control rods at or near the normal full power location are necessary before doing the axial target flux-surveillance. This Technical
. Specification change does not represent a change in present procedures.
It is merely a clarification and, thus, is acceptable.
2.5 Specification 4.2.2.2.a This change will establish a defined window between 5% and 50% Rated Thermal Power in which the surveillance must be accomplished.
This change establishes an upper bound in power ascension rather than a time limit.
A time limit is inappropriate because the time required to achieve the plant conditions necessary to accomplish this surveillance is dependent on several factors:
the time taken for low power testing, duration of holding periods necessary to achieve secondary side chemistry, and availability of secondary side equipment m'- =-v--
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to support aperation at higher power. The 50% power level was chosen because it is a convenient plateau to do the power distribution map in parallel with other tests and it is appropriate because meaningful results will be obto ned.
Further, at this power significant margin exists between peaking factors and limiting values.
This change will provide a definite window for performing the flux map and will provide baseline data prior to the unit approaching full power where the peaking fWctors are limiting. Thus, this change is acceptable.
2.6. Specification 4.2.3 5.
The proposed change deletes the words "at least once per 18 months" and adds the phrase
- prior to completion of PfiYSICS TEST after each refueling".
This change will ensure that the P.CS flow precision heat balance measurement is pt-formed prior to resuming normal power operations following each refueling.
This wording meets the intent of the original specification because it ensures that the surveillance is perforned 3rior to extended power operations.
In addition it allows flexibility if tie interval is longer than 18 months due to extended refueling or maintenance outages.
Consistent with the original specification, no power level is specified for the test.
In WCAP-12523, Westinghouse analyzed the design basis for the reactor protection system setpoints, with specific guidance on the proper methods for accounting fir instrumentation uncertainties. On this basis, Ceco's Engineering determined that the precision heat balance should be performed at greater than 90% rated thermal power (RTP).
The test will be performed at greater than 90% RTP. This change is, therefore, acceptable.
2.7 Jable 4.3 Notations 3 and_1 The proposed change to Hotation 3 will provide further definition of the initial performance of the incore-excore comparison following a refueling.
The 75% power level was chosen because it is sufficiently high th:.t the power shape will closely represent that at full power conditions and there is substantial margin between the 75% level and the high flux trip.
The proposed change measures the surveillance interval in equivalent full-power days (EFPD) rather than simple calendar days-This is because of the burnup-de)endent l
nature of the measured parameter. This will allow for performing tle incore-i excore comparison at approximately equal exposure intervals over the duration of the cycle.
For similar reasons Notation 6 is being changed to have the.
surveillance interval measured in terms of EFPD.
This change is, therefore, acceptable.
2.8 Mmj.nistrative C;iances Specification 4.2.3.4 note indicated by an "*" on page 3/4 2-9 and notation
"#" on page 3/4 3-12 were deleted because they are no longer applicable for both Byron and Braidwood Stations.
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Specification 4.9.7 note indicated by an **" was deleted for Byron Station and Specification 3.3.3.1 note indicated by an *** was deleted for Braidwood Station.
These are no longer applicable.
The last sentence in Table Notations (14) and (16) on page 3/4 3-12a for Byron and Braidwood were deleted. These notes are no longer applicable.
The staff finds these administrative changes acceptable.
Section:, 3.11.2.1, 3.11.2.2, 3.11.2.3, and 3.11.2.4 on page 3/4 11-2 had previously been deleted.
To provide continuity they were added to this page indicating that these sections are deleted.
3.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to the installation ur use of a facility component located within the restricted area as defined in 10 CFR Part 70 and change surveillance requirements.
The NRC staff has determined that the amendments invclve no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (56 FR 11775, 56 FR 22462, and 57 FR 24665). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set-forth in 10 CFR 51.22(c)(9).
Pursuant to 10 efR 51.22(b), no environmental impact statenent-or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assuranc.e that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
R. Pulsifer M. Chatterto'1 Date: August 11, 1992-.
Revised:
November 2, 1992 1
TABLE 3.3-6 5
q; RADIATION MONIl0 RING INSTRUMENTATION FOR PLANT OPERATIONS 5
ES -
MINIMUM c:
CHANNELS CHANNELS APPLICABLE ALARM / TRIP 25 FUNCTIONAL UNIT TO TRIP / ALARM OPERABLE MODES SETPOINT ACTION C
1.
Fuel Building Isolation-Radioactivity-High and Criticality (ORE-AR055/56) 1 2
<5 mR/h 29 2.
Containment Isolation-Containment Radioactivity-High a) Unit 1 (IRE-AR011/12) 1 2
All 26 b) Unit 2 (2RE-AR011/12) 1 2
All 26 3$
3.
Gaseous Radioactivity-RCS Leakage Detection
,,j, a) Unit 1 (IRE-PR011B)
N.A.
I 1, 2, 3, 4 N.A.
28 b) Unit 2 (2RE-PR0118)
N.A.
I 1, 2, 3, 4 N.A.
28 c) 4.
Particulate Radioactivity-RCS Leakage Detection a) Unit 1 (IRE-PR011A)
N.A.
I 1, 2, 3, 4 M.A.
28 b) Unit 2 (2RE-PR011A)
N.A.
I 1,2,3,4 N.A.
28 5.
Main Control Room Isolation-Outside Air Intake-Caseous Radioactivity-High e) Train A (ORE-PR031B/328) 1 2-All
< 2 mR/h 27 b) Train 8 (ORE-PR033B/348) 1 2
All
{2mR/h 27 5
x b
.