ML20126F301

Application for Amends to Licenses NPF-37,NPF-66,NPF-77 & NPF-72,revising TS 3/4.7.4,3/4.7.4.1 & 3/4.7.4.2 for Byron & 3/4.7.4,3/4.7.4.1 & 3/4.7.2 for Braidwood,To Address Concerns of Generic Ltr 91-13 Re Esws Failures at Sites

ML20126F301
Person / Time
Site:	Byron, Braidwood
Issue date:	12/22/1992
From:	Simpkin T COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20126F303	List: ML20126F301 ML20126F310
References
GL-91-13, TAC-M73975, TAC-M73976, TAC-M81167, TAC-M81168, NUDOCS 9212300228
Download: ML20126F301 (7)

Text

U

. / \ C:mm:nwealth Edis:n

. * ( _ /1400 opus Placs

(

• j Downers orove, Illinois 60515 v December 22,1992 Dr. Thomas E. Murley, Director Office Of Nuclear Roactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk '

Subject:

Byron Station Units 1 and 2 Braldwood Station Units 1 and 2 Application for Amendment to Facility 03erating License NPF-37, NPF-66, NPF-72, and NPF 77 N 10 Docket.Nos. 50 45_4.A55.A56_anL457.

Reference:

TAC # M73975, M73976, M81167, M81168  :

Dear Dr. Murley:

Pursuant to 10 CFR 50.90, Commonwealth Edison (CECO) proposes to amend A mondix A, Technical Specification of Facility Operating License NPF-37, NPF-66 N PF 72 and NPF-77. The proposed amendmen; revises s aecifications 3/4.7.4,3/4.7.4.1, and 3/4.7.4.2 for Byron and 3/4.7.4 for Braldwooc . Also for Braidwood new specifications 3/4.7,4.1 and 3/4.7.4.2 are proposed. The purpose of-the revision is to address the concerns of Generic Letter 91-13 concerning Essential Service Water System failures at multi unit sites.

Detailed descriptions of the proposed changes at e presented in Attachments A and E. The revised Technical Specification pages are contained in Attachment B and F for Byron and Braidwood, respectively.

The proposed change has been reviewed and approved by both on site and :

off site review n accordance with CECO procedures. CECO has reviewed this.

proposed amendment in accordance with 10 CFR 50.92(c) and has determined that no L significant hazards consideration exists. These evaluations are documented in l Attachments C and G, Environmental Assessments have been completed and are.

l contained in Attachments D and H.

ZNLD/2382/1 i

I '921230022e 921222 4 {l DR ADOcK 0500

'b

4

^

Dr. Thomas E. Murley 2- December 22,1992

. CECO is notifying the State of Illinois by transmitting a copy of this letter and its attachments to the designated State Official, ,

To the best of my knowledge and belief the statements contained herein are true and correct. In some respects, these statements are not based on my personal knowledge but upon information received from other Commonwealth Edison and contractor empioyees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

Please direct any questions regarding this matter to this office.

Respectfully, YWO) Terrence W. Simpkin Nuclear Licensing Administrator i

Attachment A: Byron Description of Proposed Changes Attachment B: Byron Marked Up Pages Attachment C: By_ron No Significant Hazards Consideration Attachment D: Byron Environmental Assessment Attachment E: Braidwood Description of Proposed Changes Attachment F: Braidwood Marked Up Pages _

Attachment G: Braidwood No Significant Hazards Consideration Attachment H: Braidwood Environmental Assessment cc: R. Elliott, Project Manager - NRR J. Hickman, Project Manager - NRR S. DuPont. Resident inspector - Braidwood W. Kropp, Resident inspector - Byron r /

iDocument1 Control Desk:- NRR Region ill Office I I " '( '

Office of Nuclear Facility Safety - IDNS //0LggGF - JJ _ g

=::_:::::::- ~

OFFICI AL SEAL MARYELLEN D.LONG NOTA 3Y FU2U151ME ^F ILL!NCS MY C;WlSU N E.GRES SnV93q.

__:::::::::=>

ZNLD/2382/2

ATTACHMENT A DESCRIPTION AND IMPACT OF PROPODED CHANGES DAQASIERnd In responso to Gonoric Letter 91-13, Byron reviewed the recommended Technical Specification and procedure improvements.

We concluded that the issues in the Lottor woro applicable to Byron and that we had previously adopted appropriate Technical Specifications to address the concern of Ensuntial Servico Water system (SX) failuros. In Commonwealth Edison's response to the Genoric Lottor, dated March 16 1992, Byron committed to mako refinomonts to the existing spe,cifications. Since thoro was no now information to support adopting the Specifications proposed in the Lotter, we chose to koop the specifications that the NRC-had already approved to address SX failures.

HMpparv of__the Proposed ChAngan A proposed change to 3.7.4 dolotos the two components of an Essential Service Water system. Surveillance requiroment 4.7.4.c is doloted (relocated). A proposed change to 3.7.4.1 clarifles when the specification is applicable. The proposed change to survoillanco 4.7.4.1 doos not specifically require that the Essential Service Water (SX) pump be crosstied. The proposed surveillanco also states that a flowpath is established or capable of being established; the specific valves required are doloted. An operator must be capablo of establishing this flow path and starting the availablo SX pump from the Main Control Room. Specification 3/4.7.4.2 is reworded for clarity. A discussion of the SX system crosatio is added to the Basos.

The marked up Technical Specification pages indicating the proposed changos are provided in Attachment D. A discussion of each change follows.

Dotalled Description of the Proposed Changig

1. Proposed changes to 3/4.7.4 e Current Requirement DescriptioD_And Dapes LCO 3.7.4 describes theofind th'opendent Essential Servico Water (SX) systems as having a loop and cooling tower.

Surveillanco requirement 4.7.4.c requires that the cooling tower fans be verified operable and that the cooling tower fill bo inspected. Those requirements ensure that the cooling tower operates as designed during an accident.

Rescription And1Dases of the Reauested Revision Byron previously proposed changes to Technical Specification 3/4.7.5 and the associated Bases to incorporate the results of the Ultimato lleat Sink (UHS) studios conducted for the Byron SX system. The proposed changes to 3/4.7.4 and 3/4.7.5 recognize that the cooling towers are part of the Ulis, which is a shared system The requirements for operability of the

y 0 .' , _

4 n

UHS are provided_in Specification 3/4.7.5. Specification:

3/4.7.4; currently _ includes requirements-for-the; cooling-towers and fans. The requirements'of SurveillanceJ4.7.4.c were duplicated in the proposed change.to 4.7.5 because they are more appropriate in-the UHS discussion. _Thearedundant -

-surveillance (4.7.4.c) is being deleted byLthis_ proposal. .

13Dact of the-ProDosed Chance _ _ _ ,

There are no changes to the requirementsfexcept for-the '

i numbering of the~ surveillance requirements. It,is more i appropriate to-include the cooling tower-fan operability.

requirements and cooling tower basin inspection requirements .

in the UHS Specification because they are not part of an independent system, as previously' described.

The proposed tms changes' move the requirements of Surveillance 4.7.4.c into-4.7.5.d and 4.7.5.j. Therefore,;to maintain the level of control, approval of'this (SX) amendment request is: contingent on approval of-the; UHS amendment request. There is no impact on"the safety: analyses as long as the requirements appear in either section.

2. Applicability of 3.7.4.1 DescriDtion and Bases of the Current Recuirement Specification 3.7.4.1 is applicable when Unit 2 (Unit 1) is_

in Modes 5 and'6, and Unit 1 (Unit 2) is in' Modes _1,-2, 3, and 4. This ensures that an SX-pump from a shutdown unit isL available'to support the operating. unit.

DescriDtion and Bases of the Recuested Revision-The proposed change reverses the order of the requirements to emphasize that the specification is to support the operating unit. .The proposed change adds that the specification is-applicable when there is no-fuel'in-the-reactor vessel.-'This 1s not a. defined mode in Table 1.2. ~The proposed bases change staten that the availability of"an SX pump in the shut' Gown unit ensares the availability of sufficient redundant-cooling. capacity for the operating unit. The shutidown condition-includes those times-wher. there is no--fuel in the

~

reactor' vessel.

InDact of the ProDosed Chance The proposed change is more restrictive _than the existing requirement because-the:SX pump-must be available under an additional condition. It is important to include the condition when.the shut down unit has no fuel-in the reactor vessel because the specification isfwritten for.a shutDdown.

unit to support ~an operating unit. It makes no' difference whether there is fuel in--the shut down unit's reactor. Byron recognizes thisoand performs the surveillances when-the shut:

or when the unitEis defueled.

-down The enhancedunit is inLMode wording is 5 or?6,istent cons with Table 1.2 and ensures tthat'the shut down unit's SX pump will be available to support the operating unit.

6 ' Eh w b , # . , , .m.. v+-<- - -e .,e- - - - r i

4 i .

3. Proposed Changes to Surveillance 4.7.4.1 pescr:LDtion and Bases of the Current Recuirement Surven11ance 4.7.4.1 demonstrates availability of the SX pumps by starting the pumps and verifying crosstie capability is available to the opposito unit's system. The surveillance lists specific valves that-must be open or capable of being-opened to establish a flowpath. The surveillance lists which bus must be energized to supply power to the available SX pump. The surveillances ensure that an SX pump can supply water to the opposite unit.

Description and Bases of the Recuented Revision The purpose of proposed Surveillsace 4.7.4.1 is to demonstrate that the SX pump is available to support operation of the opposite unit. The reference-to the crosstic is deleted since it is addressed specifically in Specification 3/4.7.4.2.

The specific list of valves to be open or capable of being opened is replaced by-a requirement to have, or be able to establish, a flowpath.. It is still necessary to be able'to establish this flowpath from the Fain Control Room. The wording flowpath.

allows for operator flexibility in establishing the A new surveillance ensures that the available SX pump can be manually started from the Main Control Room. This requires several things, including energizing the bus, racking in the breaker, and having control powe: available. The new requirement, therefore, provides additional assurance that the SX pump will be able to perform its safety function because the surveillance is more inclusive.

A proposed editorial change replaces " day" with "24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to be consistent with Table 1.1 and other specifications.

Impact of the Proposed Chance The changes do not affect the system's ability to perform its safety function. The crosstie valves, ISX005 and 2SX005, are already covered in 3/4.7.4.2. The. proposed-changes to Surveillance 4.7.4.1.a allow alternate valves to be used in establishing a'flowpath. This does not affect any accident analyses because the flowpath.provided in the current surveillance is not specifically listed. As long as a flowpath exists, the analyses remain bounding.

An additional surveillance that-verifies that the SX pump can be started from the Main Control Room-assurance that the pump will function as provides additional designed. Merely having the bus energized does not guarantee that the pump can be started. A flowpath, control power and properly positioned breaker are also prerequisites to using the pump to supply cooling water. Requiring-that a pump be capable of being started from the Main Control Room includes all actions necessary to provide cooling water; therefore the pump would be capable of performing its safety function.

4. Editorial-changes to 3/4.7.4.2 '

Dascription and Bases of the current Requirement-Specification 3/4.7.4.2 is applicable in Modes 1, 2, 3, and

4. The crosatie serves as a flowpath between Units 1 and 2. l The crosstie valves, 1SX005 and 2SX005, are cycled or-  !

verified locked open with power removed to ensure that flow l from one unit to the opposite unit can be established.

Description _and Bases of the Requested Revision The proposed change adds that.the LCO applies with any unit  ;

in Modes 1, 2, 3, or 4, which is how Byron already performs the surveillance. The word change is for clarity.. The LCO has also been clarified requiring the valve to be open or capable of being open from the Main Control Room to provide an Essential Service Water flowpath between Unit 1 and Unit

2. This wording provides a more accurate description of the purpose of the crosstie valves.

The surveillance is clarified to state explicitly that M _

crosstle valve shall be cycled or verified locked open with power removed. An editorial change is proposed to replace

" verify" to " verifying the" to improve readability. The requirements themselves are not changed. The requirements ensure that the SX crosstic remains capable of providing flow from one unit to the other.

Ippact of the ProDosed Chance There are no changes to the requirements. These changes are editorial in nature and serve to improva readability. The-proposed wording changes more accurately reflect how this Technical Specification is applied, since there are no changes to the actions, there is no impact on the safety analyses involving the crosstie. In Commonwealth Edison's request for the original Technical Specification,-we-stated that the crosstic would be required whenever either or both units are in Modes 1, 2, 3, or 4. The SER issued with the amendment, dated Hovember-23, 1988, also noted this condition. The proposed wording change preserves this meaning.

5. Addition to Bases for 3/4.7.4 Description and Dases of the current Recuirement The Bases for 3/4.7.4 describes the safety function for the Essential Service Water (SX) system.

Description an_d Bases of the Recuested Revision The proposed change adds a sentence describing the SX system crosstie for redundant cooling capacity for two unit sites.

The sentence based on the Bases proposed in Generic Letter 91-13.

Impact of the Proposed chance The proposed Bases describe the SX crosstle, which the Generic Letter identifies as an important feature of Byron's design. To recognize the significance of the crosstie for

4 t

providing redundant cooling capacity, the Bases are amended.

There are no' changes to plant operation resulting from the Bases change. Specification 3 requirements for the crosstie./4.7.4.2 provides the Schedule Recuirements There are no specific schedule requirements for the requested changes. However, deleting Surveillance 4.7.4.c., as discussed in item 1 above, is contingent upon approval of our proposed amendment to Technical Specification 3/4.7.5. Therefore, to ensure that controls are in place to verify cooling tower fan operability and that there is no abnormal breakage or degradation of the cooling tower fill material,.this request should-not be issued prior to issuing revisions to Specification 3/4.7.5.

Identification _and discussion of any irreversible consecuences The proposed changes are mostly editorial wording changes that support the current interpretations of the specifications. The-additional requirement enhances the availability of the SX pump to operate as designed. No irreversible consequences will result from the proposed changes.

Conclusion Based upon the information presented above, it can be concluded that the question. proposed changes do not constitute an unreviewed safety