ML20137C791
| ML20137C791 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/14/1997 |
| From: | Graesser G COMMONWEALTH EDISON CO. |
| To: | NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137C794 | List: |
| References | |
| BYRON-97-0001, BYRON-97-1, NUDOCS 9703250126 | |
| Download: ML20137C791 (14) | |
Text
l Conunonwealth I'diwn Company II) run Generating 6 tation 4150 North German Chun h Road
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Td H142R5 6 41 March 14,1997 LTR: BYRON-97-0001 FILE:- 2.01.0301 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Document Control Desk
SUBJECT:
Application for Amendment for Facility Operating Licenses Byron Nuclear Power Station Units 1 and 2 l Facility Operating Licenses NPF-37 and NPF-G6 NRC Docket Nos. 50-454 and 50-455 l
Pursuant to 10 CFR50.90, Commonwealth Edison Company (Comed) proposes to amend Facility Operating Licenses NPF-37 and NPF-66 for Byron Nuclear Power Station, Units I and 2. Comed proposes to delete 12 license conditions from the Unit I operating license and two license conditions from the Unit 2 operating license. The license conditions to be deleted have been satisfied and are no longer required to be listed in the operating license. Other license l conditions are revised to delete parts that no longer apply. Certain items in the licenses have been revised to reflect !
revisions to the referenced documents. Throughout the licenses, editorial changes are proposed for clarity and consistency.
The amendment request consists of the following:
Attachment A: Description and Safety Analysis of the Proposed Changes Attachment B-1: Proposed Changes to the Unit i Operating License (NPF-37)
Attachment B-2: Proposed Changes to the Unit 2 Operating License (NPF-66)
Attachment C: Evaluation of No Significant Hazards Consideration i
Attachment D: Environmental Assessment The proposed changes have been reviewed and approved by the On-site and Off-site Review Committees in accordance with Comed procedures. Comed has reviewed this proposed amendment in accordance with 10 CFR 50.92(c) and has determined that no significant hazards consideration exists.
Comed is notifying the State ofIllinois of our application for this amendment by transmitting a copy of this letter and the associated attachments to the designated State Official.
Comed requests that the NRC Staff review and approve this amendment request in a timely manner.
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To the best of my knowledge and belief, the statements contained in this document are true and correct. In some respects, these statements are not based on my personal knowledge, but on information furnished by other Comed employees, contractor 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 Marcia Lesniak, Nuclear Licensing Administrator, at
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(630) 663-6484.
Sincerely, j K. L. Graesser Site Vice President Byron Nuclear Power Station Subscribed and sworn to before me, a Notary Public, this l day of
-Meu& ,1931 Mh MnSA W-Notary Public l
KLG/LL l "OPPICIAL SEAL" ;
p Pewme Riseery Pubhc Attachments W Comuuseen Esomes Moseh 30 5 l cc: A.B. Beach, NRC Regional Administrator - Rlli G.F. Dick, Jr., Byron Project Manager - NRR S. D. Burgess, Senior Resident inspector - Byron OtTice of Nuclear Safety - IDNS l
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGES Descriotion of the Proposed Chanaes Commonwealth Edison (Comed) proposes to delete 12 license conditions from the Byron Unit 1 operating license and two license conditions from the Byron Unit 2 operating license. Other license conditions are revised to delete parts that no longer apply. Certain items in the licenses have been revised to reflect revisions to the referenced documents. Throughout the license, editorial changes are proposed for clarity and consistency.
The license conditions to be deleted have been satisfied and are no longer required to be listed in the operating license. The conditions to be deleted from the Unit 1 license are 2.C.3, " Post-Fuel Loading Initial Test Program," 2.C.4, " Seismic and Dynamic Qualification," 2.C.5, " Equipment Qualification," 2.C.7, " Control Room Human Factors," 2.C.8, "TMI Item II.F.1, lodine / Particulate Sampling," 2.C.9,
" Emergency Response Capability," 2.C.10, " Reliability of Diesel Generators,"
2.C.11, " Generic Letter 83-28 (Required Actions based on Generic implications of Salem ATWS Events)," 2.C.12, " Formal Federal Emergency Management Agency Finding," 2.C.13, " Control Room Ventilation System," 2.C.14, " Turbine Missiles,"
and 2.C.15, " Operating Staff Experience Requirements." The conditions to be deleted from the Unit 2 license are 2.C.3, " Initial Test Program," and 2.C.4,
" Regulatory Guide 1.97, Revision 2."
The marked up operating licenses for each unit indicating the proposed changes are provided in Attachment B. A discussion of each affected license condition follows.
- 1. Unit 1 License Condition 2.C.3, " Post-Fuel Loading Initial Test Program" Descriotion and Bases of the Current Reauirement Operating license special condition 2.C.3 requires Comed to report any changes to the Initial Test Program described in Chapter 14 of the Final Safety Analysis Report (FSAR) within one month of such change.
Descriotion and Bases of the Requested Revision Comed proposes to delete the license condition since the license condition has been satisfied. The initial startup testing program is complete.
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- 2. Unit 1 License Condition 2.C.4, " Seismic and Dynamic Qualification" Description of the Current Reauirement Operating license special condition 2.C.4 requires Comed to completely qualify the Westinghouse 7300 Process Protection System prior to startup following the first refueling outage.
Description and Bases of the Reauested Revision Comed proposes to delete the license condition because the seismic qualification of the process protection system circuit cards has been completed. Comed notified the NRC that the license condition was satisfied in a letter from K.A. Ainger (Comed) to T.E. Murley (NRC) dated April 20,1987. The NRC documented that this license condition was satisfied in an inspection report covering activities between May 2-29, I 1987. The report was transmitted to Comed with a letter to C. Reed from W.L. Forney dated June 12,1987.
j in addition, a related item is deleted from Part 2.D. The exemption identified in item b of the list is no longer required. A footnote directing the reader to Part 2.D also is deleted, since it is no longer required.
- 3. Unit 1 License Condition 2.C.5, " Equipment Qualification" Description and Bases of the Current Reauirement Operating license special condition 2.C.5 requires Comed to qualify all electrical equipment within the scope of 10 CFR 50.49 by November 30, 1985.
Description and Bases of the Reauested Revision Comed proposes to delete the license condition because it has been satisfied. Comed informed the NRC that all equipment within the scope of 10 CFR 50.49 is qualified in a letter from K.A. Ainger to H.R. Denton dated October 15,1986. In addition, in Supplement 2 to the Braidwood Safety Evaluation Report (SER) (NUREG-1002), the NRC described Byron's program for the environmental qualification of electrical and mechanical equipment. The NRC staff reviewed and evaluated the Byron Station program to ensure that the systems selected for qualification, the environmental conditions resulting from design-basis accidents, and the methods used for qualification are in compliance with applicable regulations 2
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J and standards. The NRC also confirmed that the Byron Unit 1 license l condition had been met.
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- 4. Unit 1 License Condition 2.C.7, " Control Room Human Factors" i
Description and Bases of the Current Reauirement
] Operating license special condition 2.C.7 requires Comed to move certain ,
controls in the main control room prior to startup following the first refueling outage. l
! Description and Bases of the Reauested Revision 4
Comed proposes to delete the license condition since the license condition has been satisfied. Comed had notified the NRC that the Byron Unit 1
! modification would be installed in a letter from K.A. Ainger (Comed) to H.R.
Denton (NRC) dated September 26,1986. In an inspection report covering activities between May 2-29, 1987, the NRC documented that this license
, condition will have been satisfied upon completion of modification M 6-1 260. The report was transmitted to Comed with a letter to C.
Reed from W.L. Forney dated June 12,1987. The modification was l completed on February 7,1988, therefore, the condition has been satisfied.
- 5. Unit 1 License Condition 2.C.8 TMI Item II.F.1, " lodine / Particulate ,
Sampling"
- Description and Bases of the Current Reauirement Operating license special condition 2.C.8 requires Comed to demonstrate l that the iodine / particulate sampling system will perform its intended function prior to startup following the first refueling outage. I Description and Bases of the Reauested Revision 1
Comed proposes to delete the license condition since Comed has met the requirement. Comed described a modification that would be necessary
.before the license condition could be satisfied in a letter from K.A. Ainger to H.R. Denton of the NRC dated November 5,1986. The NRC responded in a letter to D.L. Farrar dated January 8,1987, that the proposed
, modification would be acceptable, and that the license condition will have
, been satisfied when the modification is complete. In addition, the NRC documented that this license condition will have been satisfied in an 3
inspection report covering activities between May 2-29, 1987. The report was transmitted to Comed with a letter to C. Reed from W.L. Forney dated June 12,1987. Modification M6-1-84-261, which was described in the 1986 letter, was completed on November 20,1987. Therefore, the license condition has been satisfied.
- 6. Unit 1 License Condition 2.C.9, " Emergency Response Capability" Description and Bases of the Current Reauirement Operating license special condition 2.C.9 requires Comed to complete emergency response capabilities required by Attachment 2 of the license.
Description and Bases of the Reauested Revision Comed proposes to delete the license condition since the 5 items in Attachment 2 have been completed. They have been closed out as follows:
- 1. Detailed Control Room Desian Review (DCRDR)
The final DCRDR report was transmitted to the NRC in a letter from K.A. Ainger to H.R. Denton on November 26,1986. The NRC issued an SER on July 25,1989 and concluded that Byron Station meets the DCRDR requirements.
- 2. Reaulatorv Guide 1.97 Comoliance The final report and a schedule for implementation was transmitted to the NRC in a letter from S.C. Hunsader to T.E.
Murley on September 1,1987.
- 3. Emeraencv Operatina Procedures (EOPs)
The emergency operating procedures based on Revision 1 of the Westinghouse Owners Group EOPs were implemented in December 1985.
- 4. Emeraencv Response Facilities The Emergency Response Facility meteorological A-Model program has been in use since December 1985.
- 5. Safety Parameter Disolav System (SPDS)
The SPDS has been operational since March 29,1985.
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Comed also proposes to delete Attachment 2 since the items have been i completed and the corresponding license condition would be deleted. The I
text for license condition 2.C.9 and the list of attachments are also revised to reflect the deletion.
- 7. Unit 1 License Condition 2.C.10, " Reliability of Diesel Generators" 4
Description and Bases of the Current Reauirement l Operating license special condition 2.C.10 requires Comed to qualify
, controls and instrumentation or install them on a free standing floor mounted panel. ;
Description and Bases of the Reauested Revision Comed proposes to delete the license condition since the license condition i has been satisfied. In Supplement 8 to the Byron SER (NUREG-0876), the NRC concluded that the dynamic qualifications of the diesel generator control panels, including instrumentation and control devices, is satisfactory. The NRC concluded that the license condition has been i satisfied.
In addition, the original exemption is listed as item c in Part 2.D of the operating license. It is deleted from this list since the exemption is no longer required. A footnote directing the reader to Part 2.D also is deleted, l since it is no longer required. '
- 8. Unit 1 License Condition 2.C.11, " Generic Letter 83-28 (Required Actions based on Generic implications of Salem ATWS Events)"
Description and Bases of the Current Reauirement Operating license special condition 2.C.11 requires Comed to submit responses to and implement the requirements of Generic Letter 83-28.
Description and Bases of the Reauested Revision Comed proposes to delete the license condition since the license condition has been satisfied. Certain items from Generic Letter 83-28 were discussed in Supplement 7 to the Byron SER (NUREG-0876), dated November 1986. Section 15.6 provides a list of the items that were complete along with the dates of the letters that transmitted the approvals 5
i and safety evaluations. Supplement 7 also identified specific items that were still open.
2 The NRC subsequently issued several SERs accepting Comed's responses j for the remaining items. The SERs were issued as follows: January 14, 1987 for item 2.1, January 23,1987 for item 4.5.2, June 16,1989 for item 4.5.3, and March 26,1990 for item 2.2.1; The NRC approved the !
Technical Specification change required by item 4.3 as Amendment 28 on May 22,1989. !
l In Supplement 1 to Generic Letter 83-28, the NRC Staff concluded that ,
licensee actions in response to items 4.2.3 and 4.2.4 are not necessary. l Therefore, all of the required actions have been completed at Byron.
- 9. Unit 1 License Condition 2.C.12, " Formal Federal Emergency Management Agency (FEMA) Finding" Description and Bases of the Current Reauirement 1 Operating license special condition 2.C.12 requires Comed to implement the FEMA final rule for emergency preparedness. l Description and Bases of the Reauested Revision Comed proposes to delete the license condition since the condition has been satisfied. In a letter to C. Reed dated July 30,1986, the NRC stated that FEMA determined that Byron satisfies the criteria of NUREG-0654/ FEM A-REP-1. i
- 10. Unit 1 License Condition 2.C.13, " Control Room Ventilation System" Description and Bases of the Current Reauirement Operating license special condition 2.C.13 requires Comed to modify the control room ventilation system to meet General Design Criterion (GDC) 19 j prior to July 1,1985. '
Description and Bases of the Reauested Revision Comed proposes to delete the license condition since the modifications have been completed. In Supplement 6 to the Byron SER (NUREG-0876) dated November 1985, the NRC documented its review of the proposed 6
system modifications and concluded that they are acceptable and would assure compliance with GDC 19 when completed. Modification M6-0-85-003, which implemented the changes that the NRC reviewed, was completed on December 2,1987. Therefore, the license condition has been satisfied.
In addition, a related item is deleted from Part 2.D. The exemption identified in item d of the list is no longer required. A footnote directing the reader to Part 2.D also is deleted, since it is no longer required.
- 11. Unit 1 License Condition 2.C.14, " Turbine Missiles" Description and Bases of the Current Reauirement Operating license special condition 2.C.14 requires Comed to inspect all three low pressure turbine rotors by every third refueling outage until the maintenance program is approved by the NRC.
Description and Bases of the Reauested Revision Comed proposes to delete the license condition since the license condition has been satisfied. In a letter from B.J. Youngblood to D.L. Farrar dated May 20,1985, the NRC agreed that Comed committed to follow the acceptable Westinghouse methodology to determine the low pressure turbine rotor inspection interval. The NRC also stated that the license condition has been satisfied.
- 12. Unit 1 License Condition 2.C.15, " Operating Staff Experience Requirements" Description and Bases of the Current Reauirement Operating license special condition 2.C.15 describes contingencies when plant staff do not fully meet the operating experience requirements.
Description and Bases of the Reauested Revision Comed proposes to delete the license condition since all staff are now required to meet the operating experience requirements, so the shift advisors are no longer necessary. Advisors were used until the permanent on-shift licensed senior reactor operators were qualified. As documented in Supplement 7 to the Byron SER (NUREG-0876), the shift advisors were !
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1 released from further service on February 15,1986, and the license i condition has been satisfied.
- 13. Attachment 1 to the Unit 1 Operating License Description and Bases of the Current Reauirement Condition 2.C.1, " Maximum Power Level," refers to Attachment 1, which describes preoperational tests, startup tests and other items that shall be completed as specified as a condition of the license.
l Description and Bases of the Reauested Revision The items in Attachment 1 were completed. The NRC indicated that each '
of the three items is closed in a report on inspection of activities conducted ;
between May 22,1985, and June 28,1985. A report from J.J. Harrison (NRC) to C. Reed (Comed) dated July 10,1985 provides details in item 3, ;
Licensee Action on License Conditions.
Comed also proposes to delete the references to Attachment 1 from license condition 2.C.1 and the attachment list, since the attachment is deleted.
- 14. Unit 2 License Condition 2.C.3, " Initial Test Program" >
Description and Bases of the Current Reauir9 ment Operating license special condition 2.C.3 requires Comed to report any changes to the Initial Test Program described in Chapter 14 of the FSAR i within one month of such change.
Description and Bases of the Reauested Revision l
Comed proposes to delete the license condition since the license condition has been satisfied. The initial startup testing program is complete.
Changes to the program as described in the FSAR have been reported as I necessary. l 1
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- 15. Unit 2 License Condition 2.C.4, " Regulatory Guide 1.97, Revision 2 Compliance" l Description and Bases of the Current Reauirement ;
Operating license special condition 2.C.4 requires Comed to submit a report describing how the requirements in Regulatory Guide 1.97 have been met i by September 1,1987.
i Description and Bases of the Reauested Revision Comed proposes to delete the license condition since the action has been completed. Comed's Final Report for Regulatory Guide 1.97, Revision 3, i was transmitted via a letter from S.C. Hunsader to T.E. Murley dated l
September 1,1987. '!
- 16. Attachment 1 to the Unit 2 Operating License Description and Bases of the Current Reauirement Condition 2.C.1, " Maximum Power Level," refers to Attachment 1, which describes 3 items that shall be completed as specified as a condition of the license.
Description and Bases of the Reauested Revision Comed proposes to delete Attachment 1 because the three items listed in the attachment have been completed, item A, which involves preoperational tests and testing deficiencies, was described in item 2.e of a report on inspection of activities conducted between January 2-29,1987.
The report from C.W. Hehl (NRC) to C. Reed (Comed) dated March 10, 1987 states that the preoperational tests have been completed and were l reviewed by the NRC except for 3 items. These items were closed out in ]
item 2.1 of an inspection report of activities from January 13 through March !
17,1988. The report was transmitted via a letter from G.C. Wright (NRC) ;
to C. Reed (Comed) dated March 29,1988.
Item B requires completion of auxiliary building ventilation system tests, including post test review and approval by PED (Project Engineering I Departm3nt). Figure 1 provided interim power level limits based on ECCS equipment leakage. This item was closed out in item 2.1 of an inspection report of nctivities from January 13 through March 17,1988. The report was transmitted via a letter from G.C. Wright (NRC) to C. Reed (Comed) 9
1 dated March 29,1988. Since the testing has been completed and the limits no longer apply, the figure is also deleted.
Item C requires sealing construction design penetration openings in designated fire barriers, or providing compensatory measures for unsealed I openings, prior to exceeding 5% power. The referenced letter (S.C.
Hunsader to J.G. Keppler dated January 13,1987) addresses nine seals, all of which were installed or repaired under nuclear work requests in March, 1987, during refueling outage B1R01.
Comed also proposes to delete the references to Attachment 1 from license condition 2.C.1, since the attachment is deleted. l
- 17. Proposed Changes to Exemptions (Part 2.D) for Unit 1 and Unit 2 Description and Bases of the Current Reauirement i
Part 2.D of each unit's operating license describes exemptions to 10 CFR Part 50.
Description and Bases of the Reauested Revision Comed proposes to revise Part 2.D, which describes exemptions to 10 CFR Part 50, for both unit licenses to state that there are no exemptions to 10 CFR Part 50. Deleting the exceptions to 2.D.(b), 2.D.(c), and 2.D.(d) in the Unit 1 license is described in sections 2, 7, and 10, above, respectively.
Both unit licenses are revised to delete 2.D.(a), the exemption from Appendix J, concerning containment air locks. The exemption was deleted in Amendment 81 (10 CFR 50, Appendix J, Option B), which was issued on April 4,1996, and no longer needs to be included in this section of the operating license.
The exemption to Appendix E, described in item 2.D.(e) of the Unit 1 license, is also deleted. The first full participation emergency planning exercise was conducted on November 15,1983, prior to the issuance of the first operating license for full power. The following exercise, an off-hours exercise, was conducted June 11,1985 with state and local participation. The exemption to Appendix E is no longer required.
Exercises are conducted at a frequency in accordance with the applicable regulations; no further exemptions are required.
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- 14. Proposed editorial changes Description and Bases of the Reouested Revision '
Comed proposes to delete the reference to the specific amendment (Amendment 8) of the Fire Protection Report from license condition 2.C.6 of the Unit 1 Operating License and part 2.E of the Unit 2 Operating License. This provision was revised to its current form in Operating
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License Amendment 10, which implemented Generic Letter 86-10, '
" Implementation of Fire Protection Requirements." At the time the Operating License arnendment was issued, Amendment 8 was the current revision of the Fire Protection Report. Since the report is incorporated into the UFSAR by reference, it is updated at a frequency consistent with 10 CFR 50.71(e). The specific revision should not be listed since it is i periodically revised; the current revision would be implied. i Similarly, Comed proposes to delete the references to the specific dates of I the various security documents identified in 2.E of the Unit 1 Operating License and part 2.F of the Unit 2 Operating License. This provision was revised to its current form in Operating License Amendment 18, which reflected revisions to 10 CFR 73.55, " Requirements for physical protection i of licensed activities in nuclear power reactors against radiological I sabotage" and 10 CFR 73.70, " Records." At the time the amendment was issued, the current dates of the three referenced reports were put into the operating license. These have been updated in accordance with 10 CFR 50.90 and 10 CFR 50.54(p) since that time, and they will continue to be updated, as required, in accordance with the regulations. Since the license specifically mentions the regulations that control updates to these documents, it should not be necessary to include the current date of each document. Additionally, the statement regarding implementing changes to 10 CFR 73.55 is deleted since the rule changes has been fully implemented.
Asterisks were added in two places in the text to part 2.E of the Unit 1 Operating License to indicate where the note applies.
The references to the Final Safety Analysis Report are revised to reflect the current document, the Updated Final Safety Analysis Report. In the Unit 2 I license, the reference to " Byron /Braidwood" is changed to " Licensee" for consistency with Unit 1.
In the Unit 2 Operating License, the format of 2.B is changed slightly to match Unit 1. Instead of stating " Commonwealth Edison" in each item in the list, it is stated once in the opening sentence.
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- CECO is changed to Comed to reflect the current abbreviated company l name. i d
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The proposed changes are administrative in nature, and do not reduce the l
requirements of any Technical Specification. They improve readability and i provide consistency with station procedures and company programs.
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- Schedule Reauirements j There are no specific schedule requirements. The request is made in conjunction ;
with the improved Technical Specification implementation program so that the '
operating licenses would reflect only current information.
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l- Identification and discussion of any irreversible conseauences l l' There were no irreversible consequences identified.
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