ML20137F279
| ML20137F279 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/20/1985 |
| From: | Miosi A COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 0920K, 920K, NUDOCS 8512020010 | |
| Download: ML20137F279 (36) | |
Text
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\\ Commonwalth Edison
/
' ) One First National Plaa Chicago, Illinois k O 7 Address Reply to: Post Office Box 767 Q Chicago. tilinois 60690 November 20, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC. 20'555
Subject:
Braidwood Station Units 1 and 2 First Draf t Technical Specifications Response NRC Docket 50-456/457 Reference (a):
July 17, 1985 A.D. Miosi Letter to H.R. Denton (b):
Occober 7, 1985 B.J. Youngblood Letter to D. L. Farrar
Dear Mr. Denton:
j We have completed our review of the first draft of the Technical Specifications and associated comments.
Included with the NRC transmittal were several enclosures which identified deficiencies and proposed resolutions.
These enclosures are included as attachments to this response which are identified as Attachments A, B, & C.
Attachment A lists the proposed Technical Specification changes and the NRC's resolution.
Attachment B lists apparent deficiencies identified during the NRC review and recommendations for resolution of these deficiencies.
Attachment C.
lists SER review comments und proposed resolutions.
Our response to these comments / recommendation is presented below, using a consistent numbering scheme to facilitate the NRC review.
- Also included are attachments O through F which provide answers to specific issues raised during the review process.
Finally certification of the Braidwood Technical Specifications that accurately reflect the FSAR, SER, and the "as-built" conditions of the plant will be accomplished prior to issuance of an operating license.
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+ Please direct any questions you may have regarding this matter to this office.
One signed original and fif teen copies of this letter and enclosure are provided for your review.
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Antha Miosi Nuclear Licensing Administrator
/klj cc:
J. Stevens G. L. Plumlee 0920K 1
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4 ENCLOSURE Response-to Attachment A:
7@e concur with the NRC's resolution of items 1 through 6, 8, 97 10, 12, 13, 14, 15 and 17 - 22, and 24 "35.
We are not prepared to respond to items 7 and 16 at this time.
The fire protection instrumentation and hose station Iequirements are currently being reviewed..These items will be addressed upon completion of this review.
For item 11, the Westinghouse PWR-STS specification for chlorine detection is generic in nature and does not reflect the equipment utilized at Braidwood.
A proposed revision and supporting rationale are included as Attachment D.
s For item 23, the NRC specification for Radiological Environmental Monitoring is acceptable with one exception.
' A proposed revision of this specification is provided in
' Attachment G.
Response to Attachment B:
~
Rec mmendation A-1:
We do not agree that the proposed technical specification change is necessary.
The language
.as written is clear.
Recommendation A-2 through A-6:
The subject FSAR tables are currently undergoing review.
If they are determined to s " be deficient, we will pursue their revision through the Project Engineering Department.
s
' Recommendation B-1:
The subject sensor is noted in FSAR Section 3.7.4.2.4 and also in the response to FSAR Question 130.2.
Recommendation B-2:
It is our position that the current seismic instrumentation and draft Technical Specification y
are essentially in compliance with Reg. Guide 1.12, and further revision of the specification is not warranted.
4 Recommendation-D-1:
FSAR Sections 2.4.11.6 and 2.5.6.6.3 are currently in agreement.
Recommendation D-2:
We do not concur with addressing the Reg.LGuide 1.127 inspection requirements in the Technical Specifications.
A comparable inspection program is required by the State-of Illinois and the Reg. Guide allows these requirements to be fulfilled through the State enforced program.
To comply with the requirements of the SER, a proposed revision of this specification is provided l
as addressed in-Attachment E.
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.s.
Recommendation D-3:
We concur with this recommendation.
Recommendation E:
As previously noted, a proposed revision to this specification is included in Attachment D.
Recommendation F:
We concur with this recommendation.
Recommendations'G-1 and G-2:
We concur wir.h these
{
recommendations.
Response to Attachment C:
Comment 1:
See response to Attachment B, Recommendation D-2.
Comment 2:
The pond screenhouse is currently being
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monitored for settlement.
See FSAR Question 362.1
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(Amendment 45)
Comment 3:
Braidwood commitment 20-84-029 was issued on l
~ 4-27-84 to track the development of this surveillance.
Comments 4, 5:
We concur that these issues are not
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applicable.
Comment 6:
We do not concur..
It is odr position that the current seismic instrumentation is adequate to fulfill the requirements of Reg. Guide 1.12., namely that the response of the lake screenhouse foundation is not different from the containment.
Comments 7, 8:
We concur with the Staff's resolutions.
I t
I'..
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ATTACHMENT A Proposed Technical Specification Change and NRC Resolution.
s BRAIDWOOD FIRST DRAFT TECHNICAL SPECIFICATION REVIEW
SUMMARY
Proposed Change 1.
All Pages Change " Byron" to "Braidwood" 2.
Pages X, XI Re-number pages due to revision of Ultimate Heat Sink specification.
3.
Page 3/4 3-15 Change " Pressurizer Pressure-Low (Above P-7)" to " Pressurizer pressure-Low (AboveP-11)"-
typographical error.
4.
Page 3/4 3-41 Change " July 1, 1985 when there is no" to " storage of" - site specific change as July 1, 1985 holds no significance for Braidwood.
5.
Page 3/4 3-45 Table 3.3-7 Delete references to Byron River Screen house - Site specific.
O Change coordinates of Free Field 8
Sensor from "41+00E, 27+00N" to "39+00E, 41+005" - site specific.
Change Measurement Range for Triaxial Acceleration from "-2g to
+2g" to "-Ig to +1g" - to maintain consistency with Byron Technical Specifications; Byron's proposed revision is included as Attachment --
1.
6.
Page 3/4 3-48 Table 3.3-8, Change instrument elevations from Page 3/4 3-49 Table 4.3-5 "30 ft" to "34 ft" and from "250 ft" to "203 ft" on Wind Speed and Wind
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Direction; change Air Temperature -
at elevations from "30 ft/250 ft" to 30 ft/199 ft" - site specific.
7.
Pages 3/4 3-58 through Delete total number of instruments 3/4 3-63 Tables 3.3-11a, b these are site specific numbers and will be forwarded upon completion of the Marsh & McLennan Fire Protection Consultants survey. Delete zone 52, RSH - site specific, delete zone 26, elev. 864 - site specific.
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8.
Page 3/4 6-7 Delete periods after A, B, C. & D
- typographical error.
9.
Page 3/4 7-12 Delete surveillance requirement 4.7.4.c. - site specific Braidwood has no cooling towers.
- 10. Pages 3/4 7-13 through 3/4 7-15 Replace with Insert A - site specific; Braidwood utilizes a cooling lake as an ultimate heat sink. The proposed specification closely follows the Westinghouse Standardized Technical Specifications.
- 11. Page 3/4 7-17 Add Insert B - site specific. The additional surveillance is required because of the proximity of the Braidwood site to the Illinois Central - Gulf railroad tracks (Reference FSAR sections 6.4.4.2 and 7.3.11.9)
- 12. Page 3/4 7-19 Change " July 1, 1985" to " Mode I because of the low fission product inventory a'vailable at or below the limiting power level of 5%" - site
-.'. f specific, the July 1, 1985 date holds no significance for Braidwood.
- 13. Page 3/4 7-30 Change " flume" to " lake " site specific Delete surveillance 4.7.10.1.1.a -
site specific.
- 14. Page 3/4 7-30 Change surveillances "4.7.10.1.1.b "
i through g" to "4.7.10.1.1.a through l
f" - site specific.
i
- 15. Page 3/4 7-35 Delete reference to diesel-driven l
l Essential Service Wate.* make-up pumps and day tank rooms - site specific.
Redesignate specification from l
"3.7.10.3.e" to "3.7.10.3.d" site specific.
i Delete reference to river screen l-house C0 tank - site specifit:.
2
- 16. Pages 3/4 7-38 through Change " North" to " South", " South" to " North," " East" to " West," " West" to " East," " Northeast" to " Southwest,"
" Southwest" to " Northeast," Northwest" to " Southeast," " Southeast" to
" Northwest" - site specific.
Change "X-14" to "X-17" (p 3/4 7-41) -
site specific.
Change "M-11" to "N-11" (p 3/4 7-44) -
typographical error.
- 17. Page 3/4 8-5 Change " operate" to " operates" -
typographical error.
- 18. Pages 3/4 8-14, 3/4 8-16 Delete references to Buses 131Z, 132Z, 231Z, and 232Z - site specific.
- 19. Pages 3/4 8-42, 3/4 8-43 Delete valves OSX157A & B, OSX158A & B.
Table 3.8-2a 0SX162A & B, OSX163A, B. E & F - site specific.
- ~
Add valves OSX147, OSX165A & B - site l
specific.
.! 1; Change nomenclature on OSX146 - site specific.
i
- 20. Pages 3/4 8-46, 3/4 8-47 Delete valves OSX162C & D, DSX163C, D.
Table 3.8-26 G. & H, DSX175A & B, OSX158A & B - site specific.
Add valves 0SX146, OSX165A & B - site specifk.
Change nomenclature on DSX147 - site l
specific.
- 21. Page 3/4 g-8 Change "until October 31, 1965" to
" prior to storage of irradiated fuel"
- site specific; October 31, 1985 holds no significance for Braidwood.
- 22. Page 3/4 11-8 Add coma after " gases" - typographical error.
- 23. Pages 3/4 12-3 through 3/4 12-6 Changes are requested to ensure Table 3.12-1 uniformity with the Commonwealth Edison Offsite Dose Calculation Manual, included as Attachment 2.
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- 24. Page B 3/4 3-4 Change "two" to "one", "six" to "five",
delete reference to River Screen House, change free field sensor coordinates -
site specific.
- 25. Page B 3/4 4-11 Replace with Insert C - site specific Unit I vessel data.
- 26. Page B 3/4 4-12 Replace with insert D - site specific Unit 2 vessel data.
- 27. Pages B 3/4 7-3 B 3/4 7-4 Replace basis for Ultimate Heat Sink with Insert E - site specific, g
Braidwood utilizes a cooling lake in lieu of towers.
- 28. Page B 3/4 9-1 Change " Byron" to "Braidwood" - site
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specific.
- 29. Page 5-1 Change " Byron" to "Braidwood" - site specific.
- 30. Page 5-2 Replace with Insert F - site specific.
- 31. Page 5-3 Replace with Insert 6 - site specific.
. @ 32. Page 5-5 Change "423 feet 2 inches" to "423 feet 0 inches" - site specific.
- 33. Page 6-2 Change " Byron" to "Braidwood" - site specific.
Change "shall submit" to " submittal
- 34. Page 6-13 of" - typographical error.
- 35. Page 6-24 Add "For emergency situations,... dose rate specification" to ensure consistency with Byron Technical Specifications; Byron submittal included as Attachment 3.
_______________,___i______._...._._.. _ _ _ _. _.. _ _
RESOLUTION / CHANGE (NUMBERS ARE C0'SISTENT WITH PROPOSED CHANGES) 1.
Proposed change considered site specific and was incorporated.,
2.
Proposed change considered site specific and was incorporated.
3.
Braidwood FSAR, Table 7.3-1, item 1.d validated the proposed change.
Change considered an editorial error generic to both Byron and Braidwood Technical Specifications. Additional comments are addressed in.
4.
Proposed change was not incorporated. Footnote on page 3/4 3-41 was considered Byron site specific and therefore deleted from Braidwood's Technical Specification.
5.
Proposed change to delete references to Byron River Screen house is site specific and was incorporated. Braidwood FSAR Section 3.7.4.2.2, validates the proposed triaxial acceleration sensor location change in the free field at site coordinates 39+00E, 41+005, and was incorporated.
Proposed change in measurement range is not site specific and was not incorporated. Additional comments are addressed in Enclosure 3.
6.
Braidwood SER, Section 2.3.3, validates the proposed changes in meteorological instrumentation elevations to be site specific. Changes were incorporated.
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4 7.
Proposed change to delete the total number of fire detection instruments was considered not to be site specific and therefore not incorporated.
Proposed change to delete zones 52 which is at the Byron River Screen house, and zone 26 which is at the Byron Essential Cooling Tower Electrical Substation, was considered site specific and incorporated.
, Additional connents are addressed in Enclosure 3.
8; Braidwood FSAR, Figure 9.4-10 validates the nomenclature A, B, C, & D --
Reactor Containment Fan Coolers. The proposed change is considered a typographical error generic to both Byron and Braidwood Technical Specifications.
9.
Proposed change to delete surveillance requirement 4.7.4.c concerning the Byron cooling towers was considered site specific and incorporated.
- 10. Proposed change to add an ultimate heat sink specification for Braidwood which utilizes an Essential Service Cooling Pond (ESCP) and delete Byron's specification was considered site specific. However, the utilities proposal was found to be unacceptable and was replaced by the Westinghouse PWR-STS, LCO 3.7.5, modified to incorporate the Braidwood SER Section 2.5.5.4.3, additional suryet.l. lance' requirements." Additional c,omments are addressed in Enclosure 3.
4
- 11. The site specific requirement for automatic isolation of the control room HVAC on high chlorine detection was validated by Braidwood's SER, Section 2.2.1.
The proposed change did not ensure that two trains of chlorine detection were available, therefore, the Westinghouse PWR-STS LCO 3.3.3.7, " Chlorine Detection Systems," was incorporated into Braidwood's draft Technical Specifications. Additional connents are addressed in Enclosure 3.
- 12. The footnote on page 3/4 7-19 was considered site specific to Byron and therefore, deleted from Braidwood's draft Technical Specification.
- 13. The proposed change was considered site specific, however, " flume" was changed to " pond" to reflect the Braidwood SER terminology. Surveillance 4.7.10.1.1.a was validated site specific and deleted since Braidwood's motor and diesel driven fire pumps take suction from the ESCP (via the pond screen house forebay) whose level is verified by surveillance 4.7.5.1.
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- 14. The proposed change was incorporated since 4.7.10.1.1.a was deleted.
4
- 15. Braidwood's Fire Protection Report validated the proposed changes to be site specific. Changeswereincorporated.
- 16. Proposed directional changes for fire hose stations were considered site specific and incorporated. Proposed changes from fire hose station "K-14" i
to "X-17" could not be validated by the Braidwood Fire Protection Report and was not incorporated. Proposed change from fire hose station "M-11" to "N-11" was validated by the Braidwood Fire Protection Report, Diagram M-52, Sheet 11, to be a typographical error generic to both Byron and Braidwood. Enclosure 3 contains additional connents.
- 17. Proposed change was vaiidated by the Westinghouse PWR-STS to be a typographical error generic to both Byron and Braidwood.
l
- switchgear for each unit versus four at Byron. The proposed change was~
considered site specific and incorporated.
19./ Braidwood FSAR, Figure 9.2-2, Sheets 5 and 10, validated the proposed
- 20. changes to the list of motor-operated valve thermal overload protective devices. These are considered to be site specific and were incorporated.
- 21. Footnote on page 3/4 9-8 was site specific to Byron and therefore' deleted on Braidwood's draft Technical Specification.
- 22. Proposed addition of a comma was incorporated and considered.a typographical error generic to both Byron and Braidwood.
- 23. Proposed change was not considered as site specific and therefore not incorporated. The ODCM, which is site specific, should be developed from the generically approved radiological environmental monitoring program. The program should not be changed to agree with the ODCM.
e.
- 24. Proposed change was previously validated in 5 above to 'e site specific b
and was incorporated.
25./ The proposed tables were considered site specific and incorporated.
The licensee's proposal was modified to reflect the format of Braidwood FSAR, 26.
Table 5.3-4 In the licensee's proposal for Unit 1, the bottom head ring heatnumber(490248-1-1), deviated from the Table 5.3-4 number (49D148-1-1). Table 5.3-4 numbers were assumed to be correct and incorporated.
27./28./29./30./31./32./and 33.
The proposed changes were considered site specific and incorporated.
- 34. The proposed change was validated by the W-STS to be a typographical error generic to both Byron and Braidwood.
- 35. The proposed change was not site specific and not incorporated.
S4 O
O,
T ATTACHMENT B Apparent Technical Specification Deficiencies and Proposed Resolutions.
J
APPARENT DEFICIENCIES IDENTIFIED DURING REVIEW 0F BRAIDWOOD'S DRAFT TECHNICAL SPECIFICATION A.
Proposed typographical error [i.e., change " Pressurizer Pressure-Low (Above P-7)" to " Pressurizer Pressure-Low (Above P-11)"] validation review based on Braidwood's FSAR Section 7.3, " Engineered Safety Features Actuation System," with the assumption that the reactor trip system logic drawings (Figure 7.2-1) were accurate.
Coments 1.
FSAR Table 7.3-1, item 1.c, referenced a note "*" concerning a permissible bypass on low-low T that appeared to be inappropriate. Figure 7.2-1, sheet 5 of 17 and smit 10 of 17, confim that the low steamline pressure safety injection is not dependent on the low low T pemissive P-12. P-12 appeared to be a pemissive for the steam dump IUves to control cooldown. Figure 7.2-1, sheet 7 of 17, confims that low steamline pressure safety injection is dependent on loop isolation and the P-11 pemissive.
2.
FSAR, Table 7.3-1, it'em 1.d. validates the licensee's request to make the above Technical Specification change. Figure 7.2-1, sheet 6 of 17, validates enabling of pressurizer pressure low safety injection when y4 greater than P-11.
3.
FSAR Table 7.3-2, item 2.a. appeared to be in error by not referencing the P-11 permissive. Figure 7.2-1, sheet 8 of 17, confims that steamline isolation on low steamline pressure is activated at greater than P-11.
4.
FSAR Table 7.3-2, item 2.c. does not indicate a P-11 pemissive.
Figure 7.2-1, sheet 7 of 17 and sheet 8 of 17, confim.that high steam pressure rate steamline isolation is automatically blocked above P-11.
Working copies of the referenced tables / figures are attached. Also the following recomendations are provided:
e Recomendations 3
1.
Tables 3.3-3 and 3.3-4 of the Byron Technical Specification should be revised to clarify when the trip is functional. This would minimize confusion with the existing permissible bypass note "f" in the i
" Applicable Mode" column (e.g., state " Active above P-11" instead of "Above P-11").
2.
FSAR, Table 7.3-1 note "**" would be less confusing to the plant operators if worded differer.tly [e.g., " Operating Bypass" permissive j
when pressurizer pressure is less than 2000 psig (via P-11)].
3.
FSAR, Table 7.3-1, item 1.c. note "*" should be the same as the proposed note "**" above.
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4.
FSAR, Table 7.3-1, existing note "*" should be deleted.
5.
FSAR, Table 7.3-2, item 2.a. should reference the Table 7.3-1, note "**"
indicating that it is required to be active when > P-11 and cart be bypassed when4P-11, 6.
FSAR, Table 7.3-2, item 2.c. should note that it is only active when less than P-11 and automatically blocked when greater than P-11.
I B.
Proposed change to Technical Specification Table 3.3-2, " Seismic Monitoring Instrumentation," validation.
Coments 1.
Byron /Braidwood FSAR Section 3.7.4.2.2, does not validate the triaxial acceleration sensor " Auxiliary Building /18N-426'" listed in the Braidwood l
draft Technical Specification.
Braidwood FSAR a'nd draft Technical Specification do not agree with RG 1.12 2.
which requires a triaxial response-spectrum recorder at the foundation of an independent seismic Category I structure where the response spectrum is
~
different from that of the reactor containment structure (e.g., the pond screen house for Braidwood).
Recomendation 1.
Bymn/Braidwood FSAR should be revised to agree with Technical Specifications.
'2.
Braidwood's draft T2chnical Specification should reflect the RG 1.12 requirements.
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C.
Proposed site specific changes to fire detection instruments Technical Specification. Tables 3.3-11a and 11b validation.
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4 i
D.
Proposed change in ultimate heat sink validation.
Comments 1.
Braidwood FSAR, Section 2.4.11.6, page 2.4-17 Amendment 43, concludes a 1.5 ft. ESCP level loss in a 30 day period due to evaporation and seepage, whereas, FSAR, Section 2.6.6.6.3, page 2.5-110, Amendment 18, concludes a 2.5 ft. loss.
2.
Braidwood SER, Section 2.5.5.4.3, page 2-49, addresses RG 1.127 surveillance requirements to ensure the ESCP slopes are maintained.
and were not submitted with the proposed LCO.
3.
RG 1.127 is referenced on p. 2-49 of the Braidwood SER but not in Appendix B. " Bibliography."
Recommendations 1.
The Braidwood FSAR should be revised to ensure agreement.
2.
The requirement to conform to RG 1.127 inservice inspection requirements was incorporated into the first draft of Braidwood's Technical Specification.
3.
The Braidwood SER, Appendix B, should be revised..
a E. _' Proposed addition of a surveillance requirement to the control room j
HVAC LC0 validation.
Coment
~
f 1.
The proposed requirement that at least once per 18 months verify thtt on a high chlorine air intake test signal, the system automatically switches into a recirculation mode of control room ventilation with flow through the recirculation charcoal absorber, is below the minimum requirements accepted by the staff for chlorine detection reliability.
j 2.
'The licensee's sumnary of proposed changes referenced FSAR, Section 7.3.11.9. This is actually Section 7.3.1.1.9.
Recommendation The W-STS LC0 3.3.3.7 requirements for chlorine detection systems'were incorporated in the Braidwood first draft Technical Specification.
4 F.
Proposed Fire hose station location change validation.
Comments 1.
Fire hose station directional changes could not be validated from a documentation review.
2.
Changing K-14 to K-17 could not be validated by the Braidwood Fire Protection Report, diagram M-52, Sheet 11, which gave the proper designator as K-14.
Recommendation The above changes should be validated by the NRC fire protection ~ technical reviewer's site visit.
G.
Additional deficiencies noted during this review.
Comments 1.
Braidwood draft Technical Specification index did not list LCO 3.8.1.3 on p. 3/4 8-9a.
2.
Draft Technical Specification index has Basis 3/4.7.9 on page B 3/4 7-6 g.
instead of B 3/4 7-7.
( C'}
x; 3.
Draft Technical Specification index has Basis 3/4.7.11 on page B 3/4 7-7 instead of 7-8.
4.
Draft Technical Specification index did not list Table 6.2-la.
Recommendation
- 1.. Comments 1 and 4 above were considered editorial errors without
- technical substance. Byron Technical Specification should be revised.-
2.
Comments 2 and 3 above were considered typographical errors. Byron Technical Specification should be revised.
O ATTACHMENT C SER peview Comments and Proposed Resolutions.
l Braidwood Safety Evaluation Report (SER) Review Comments ;
and Proposed Resolutions s
CODNENT 1.
Section 2.4.3.5 - This section of the Braidwood SER states that the portion of the Braidwood essential service cooling pond (ESCP) that is constructed to el 602.5 ft. MSL serves a safety function and should be included in the inspection program described in RG 1.127.
2.
Section 2.5.4.8 - This section of the Braidwood SER states that the staff requires monitoring of the pond screen house for settlement to be part of I
the inservice inspection (ISI) program.
Resolution As indice,ted in our memorandum dated August 23, 1985,...'gilio to Youngblood,
, identified that Braidwood SER, Section 2.5.5.4.3 addressed T..G.1.127 surveillance requirements, to ensure the ESCP slopes are main-tained, which were not submitted with the proposed LCO. This requiremen'.,
was subsequently incorporated in the first draft of Braidwood's Technical i
i Specification (TI).
O Subsequent discussion, with theStructural'and Beotechnical Engineering Branch (SGEB), concluded that based on their safety significance, maintenance of the ESCP slopes and dike, and monitoring for pond screen house settlement-should all be incorporated into the TS surveillance requirement addressing i
JG 1.122 requirements. Therefore, we propose that: (1) The second draft of Braidwood's TS will reflect this position, and (2) the Braidwood SER * -
should be supplemented to also reflect this position.
l Comment l
3.
Section 10.4.4 - This section of the Byron /Braidwood SER stated that the staff would condition the license to require that the ISI prugram include the requirement that the turbine bypass valves be stroked at least once a quarter.
However, this is not reflected in Byron':. TS or Braidwood's l
first draft.
t Resolution Discussions with the Power System Branch (PSB) technical reviewer, indicated that this SER license condition requirement had been deleted based on,a j
previous applicant commitment to perform this inspection.
The feviewer could not remember what was previously acer 'ed or where the appitcant's commitment was documented. We propose that supplements to the Byron and Braidwood SERs be developed to reflect how this open issue was subsequently resolved.
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1 Coment 4.
Braidwood SER, Page 16-1, refers to ground water elevation in Section 2.4.6 as being a TS issue.
This could not be validated by reference to the Braidwood SER, Section 2.4.6.
However, Byron's SER, Section 2.4.6', does require the applicant to submit a draft TS and bases thereof for the ground water elevation for which NRC will be notified.
i 5.
Section 16 refers to safety-related water supply in Section 2.4.8 as being a TS issue.
This could not be validated by the Braidwood SER, Section 2.4.8.
However, Byron's SER, Section 2.4.8, established TS conditions for the safety-related water supply.
1 Resolution Our review indicates that the above issues were site specific to Byron and were not incorporated in the draft Braidwood TS.
We propose that the Braidwood -
SER Section 16, be supplemented to delete Byron site specific ground water
. 4levation and Byron safety-related water supply concerns from the Braidwood SER.
Coment 6.
Section 16 refers to seismic instrumentation as a TS issue and refers to
~
Byron's SER, Section 3.7.4.
Memorandum of August 23, 1985, M. J. Virgilio
- h to B. J. Youngblood, which forwarded the first draft, questioned whether or not the applicant complied with R.G.1.12 by not having seismic instru-mentation in a Category I structure not attached to containment.
Resolution f
It appears, from discussion with the SGEB technical reviewer, that his review of 2
Byron's'SER.Section 3.7.4. " Seismic Instrumentation." was based on the generic plant design and was not a Braidwood site specific review. SGEB was unaware that Braidwood would not be requiring seismic instrumentation in a Category I structure not attached to containment as required by SRP, Section 3.7.4.
We propose to incorporate this requirement to seismically monitor the Braidwood pond screen house into LC0 3.3.3.3. Table 3.3-7, of Braidwood's second draft TS.
Comment 7.
Section 16 refers to ventilation system flowrates in Section 6.5.1 as a TS issue.
SER, Section 6.5.1.2, requires the ESF atmospheric cleanup system (i.e. control room HVAC, non-accessible area exhaust filter plenum in auxiliary building, and fuel-handling building exhaust system) drop to be verified during plant operation on a routine basis, pressurehowever, such a requirement does not appear in Byron's TS or Braidwood's ifraft TS (e.g. LC0 SR 4.7.6. 4.7.7, and 4.9.12 do not require routine checking of systemAP).
Byron SER, Supplement 5 subsequently stated that Amendment 42 to Byron's FSAR indicated only AP across the HEPA filters, upstream of the charcoal
absorbers, would be recorded.
S,.upplement' 5 also discusses AP alarms on the non-accessible area exhaust filters and the control room emergency make-up air filters.
However, Supplement 5, is not clear as to whether or 'not the initial SER TS requirement is still in affect, and does not identify whether or not a AP alarm exists on the fuel-handling but.1 ding exhaust system.
Resolution Section 7.3.1.1.9.2.3.2 of the B/B-FSAR validates indication of AP across the control room emergency supply air filters that annunciate on the main control board.
Section 9.4.5.1.2.h.5 of the B/B-FSAR validates indication of AP across the upstream HEPA filters in the nonaccessible area exhaust plenum and the fuel-handling building exhaust plenums that annunciate on the main control panel.
From our FSAR review and discussions with the METB technical reviewer, Supplement 5 to the Byron SER appears to be deficient by not completely
,, addressing the original SER TS issue. We, therefore, propose the following:
(1) supplement the Byron SER to indicate that AP across the HEPA filters for all ESF atmospheric cleanup systems is continuously monitored and alarmed in the control room; (2) supplement the Braidwood SER to also indicate this position; and (3) close the initial SER TS issue by stating in the SER supplements that the AP alarm satisfies the intent of the SRP, Section 6.5.1 requirement to record system flow rate.
Comment 8.
Section 16 refers to testing of slave relays with proving lamps for ESF Systems as a TS issue. Byron SER, Supplement 3 Section 7.3.2.12, implies
.that untjl an acceptable circuit. modification is installed, TS will include inonthly tests (instead of quarterly) of any slave relay that has a proving.
. lamp. This apparently was not incorporated into Byron's TS or Braidwood's
, draft TS.
Resolution NRC Inspection Report 50-456/85-014 validated the completion of the required circuit modification for Unit 1 on February 9,1984, and for Unit 2 on August 9, 1984. We propose that a supalement to the Braidwood SER be issued to reflect installation of the acceptable circuit modification.
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CP ATTf.CHMENT D Proposed Revision to Chlorine Detection Technical Specification.
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INSTRUMENTATION CHLORINE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION Ins}rumdalb Mads 3.3.3.7 Two independent Chlorine Detection-Sy;te ^, with their Alarm / Trip set-points adjusted to actuate at a chlorine concentration of less than or equal to.
5 ppm, shall be OPERABLE.
APPLICABILITY:
All MODES.
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ACTION:
With one Chlorine Detection +/:te9 inoperable, restore the inoperable a.
system to OPEPABLE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the Control Room Emergency Ventila-tion System in the recirculation mode of operation.
insbw4.Jnx cLaeh b.
With both Chlorine Detection Syrte D inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initi-ate and maintain operation of the Control Room Emergency Ventilation System in the recirculation mode of operation.
c.
The provisions of Specification 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS
,n MM '- c h ad 4.3 3.7 Each Chlorine Detection SystD shall be demonstrated OPERABLE by pee --
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BRAIDWOOD - UNITS 1 & 2 3/4 3-56 Sp y e gg
s CHLORINE DETECTION Braidwood utilizes eight Wallace & Tiernan Series 50-150 chlorine detectors to provide detection capabilities in the control room HVAC system.
They are arranged such that there are two detectors in each outside air intake duct, and two in each turbine building air intake.
The available indication consists of a power light and an alarm light on each detector, and all detectors supply a common annunciator window.
The W-STS for chlorine detection identifies a Chlorine Detection System.
Braidwood's chlorine detection equipment is more appropriately identified as instrumentation channels.
The W-STS surveillance requirement call for a channel check every twelve Fours.
This is defined as a qualitative assessment of channel operability.
The design and installation of the chlorine detection instrumentation at Braidwood does not provide a means for performing a meaningful channel check.
It is therefore requested that this requirement be deleted.
The W-STS further calls for an analog channel operational test, including setpoint verification, every 31 days.
The only method known to the station to verify setpoint is to perform a $
portion of the calibration procedure.
Further, to verify the actual setpoint this procedure would have to be continuously repeated in order to, establish the minimum concentration of chlorine required to l
1 alarm the detectors.
A review of the vendor manual reveals that a decrease in chlorine concentration would only result in an increase in response time.
Thus, a setpoint verification would also necessitate der:.ning an acceptable response time.
This would appear to be a somewha. burdensome requirement given the level or protection incorporated in Braidwood's design.
Inquiries made at several other nuclear plants and utilities having chlorine detection requirements have revealed that the manufacturer's recommendations have been followed to periodically verify operability.
Braidwood has proposed a monthly surveillance with wording that would allow the manufacturer's recommendation to be followed.
In the case of Braidwood's detectors, the manufacturer recommends that operability be demonstrated by wetting a cotton swab with chlorine bleach and touching it to the electrode.
The proposed surveillance further provides for checking one detector per duct per month.
As there are redundant detectors in each duct, the only effect checking all detectors each month would have would be to cycle the control room dampers in each train an additional four times per month.
This excessive exercising of these dampers would be in addition to the normal surveillances performed on the Control Room HVAC system to fulfill the requirements of Specification 3/4.7.6.
The proposed wording allows a surveillance l
that is adequate to demonstrate chlorine detection capability in all intake ducts on a monthly basis, ano would therefore demonstrate that the LCO has not been violated.
9 It should be noted that the typical sensitivity of Braidwood's detectors is 5 ppm chlorine (by volume) in air, and that the typical response time of the detector is 5 seconds, exclusive of transport time.
s ATTACHMENT E Proposed Revision to Ultimate Hest Sink Technical Specification.
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PLANT SYSTEMS 3/4.7.5 ULTIMATE HEAT SINK (Essential Service Cooling Pond)
LIMITING CONDITION FOR OPERATION 3.7.5 The essential service cooling pond (ESCP) shall be OPERABLE with:
a.
A minimum water level at or above elevation 590 ft. Mean Sea Level, USGS datum, and b.
An essential service water pump discharge water temperature of less than or equal to 98'F.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTION:
With the requirements of the above specification not satisfied, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
4 SURVEILLANCE REQUIREMENTS 4.7.5.1.
The ESCP shall be determined OPERABLE at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the average water temperature and water level to be within their limits.
4.7.5.2 Ir additfer te the requir r:nts of Spect'icatier *.0.5, th: ESCP :h:11 be 4 :pected per the rec:rt:nd:tfen: ef o:gul:tery P :iti:n C cf ":gulat:ry
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BRAIDWOOD - UNITS 1 & 2 3/4 7-13 SEP 16 G85
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ATTACHMENT F Additional Site Specify Information and Technical Specification Changes 1.
Fig.~3.4-2a U1 RCS Heat Up Curve 2.
Fig. 3.4-2b U2 RCS Heat Up Curve 3.
Fig. 3.4-3a U1 RCS Cool Down Curve 4.
Fig. 3.4-3b U2 RCS Cool Down Curve 5.
Sec. 3/4.7.4 Essential Service Water System Tech Specs which is site specific 6.
Table 4.4-5 Reactor Vessel Material Surveillance i
Program-Withdrawal Schedule i
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PLANT SYSTEMS MInns 3 3/4.7.4 ESSENTIAL SERVICE WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.4 At least two independent Essential Service Water Systems shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTION:
a.
With only one Essential Service Water System OPERABLE, restore at least two Essential Service Water Systems to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANOBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REQUIREMENTS 4.7.4 At least two Essential Service Water Systems shall be demonstrated OPERABLE:
a.
At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position.
c.g At least once per 18 months during shutdown, by verifying that:
1)
Each automatic valve servicing safety-related equipment or isolating the non-nuclear safety-related portion of the system actuates to its correct position on a Safety Injection test signal, and 2)
Each Essential Service Water System pump starts automatically on a Safety Injection test signal.
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TABLE 4.4-5 1
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CAPSULE VESSEL LEA 0
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NUMBER LOCATION FACTOR WITHDRAWAL TIME (EFPY)*
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A 06-3. 4 1st Refueling e.
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most closely approaching the withdrawal schedule.
O ATTACHMENT G Radiological Environmental Monitoring Program 0920K I
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s TA8LE 3.12-1 (Continued) 5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Q
NUMBER OF o
REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AND/0R SAMPLE SAMPLE LOCATIONSgg)
COLLECTION FREQUENCY OF ANALYSIS e
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- 2. Airborne Radiolodine and Samples from five locations:
Continuous sampler Radiolodine Cannister:
Particulates operation with sample I-131 analysis weekly.
Three samples from close to collection weekly, or the three SITE BOUNDARY loca-more frequently if tions, in different sectors, required by dust Particulate Sampler:
of the highest calculated loading.
Gross beta radioactivity annual average ground level D/Q; analysisfollogg filter change; and One sample from the vicinity of gamma isotopic analysis (4) a community having the highest of composite (by location) w>
calculated annual average ground-quarterly.
level D/Q; and, Q
m One sample from a control M
location, as for example 10 to b
30 km distant and in the least T
prevalent wind direction.
q 3.' Waterborne I4)
- a. Surface (5)
One sample opstream.
Composite sample over Gamma isotopic analysis i
One sample downstream.
1-month period by monthly.
Composite for weekly grab samples.
tritium analysis quarterly.
- b. Ground Samples from one or two sourc Quarterly.
Gamma isotopicI4) and tritium only if Ilkely to be affected analysis quarterly.
- c. Drinking One sample of each community Composite sample I-131 analysis on each drinking water supply over 2-week period (6) composite when the dose downstream of the plant when I-131 analysis calculated for the consump-within-10
- Hemeters, is performed, monthly tion of the water is greater AMS composite otherwise.
than 1 ares per year.(8) Com-S One sample from a control positeforgrossbetaag
- location, gamma isotopic analyses monthly.
Composite for g
tritium analysis quarterly.
_