ML20141F304

Suppl to 970524 Application for Amends to Licenses NPF-66 & NPF-77,revising TS 4.5.2.b Re Venting of ECCS Pump Casings & Discharge Piping High Points Outside of Containment.Proposed Changes to Bases Revised to Delete Ref to Pressure

ML20141F304
Person / Time
Site:	Byron, Braidwood
Issue date:	06/24/1997
From:	Graesser K COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20141F306	List: ML20141F304 ML20141F308
References
BYRON-97-0152, BYRON-97-152, NUDOCS 9707020229
Download: ML20141F304 (3)

Text

.,. - . ~ , - . - - . . . - . . - - . . . - . . .

-' Commonwealth Edien Company i lhrun Generating Station 4150 North German Church Road liyron. IL 61014979 i "l;ct HI42R5 Hi June 24,1997 U. S. Nuclear Regulatory Commission 4 Attention: Document Control Desk Washington D.C. 20555-0001 l Lir BYRON 97-0152

{ File: 1.10.0101

Subject:

Supplement to the Application for Exigent Amendment Request for Appendix A, i Technical Specifications, to Facility Operating Licenses:

Byron Nuclear Power Station, Unit 2 Facility Operating License NPF-66 NRC Docket No. 50-455 Braidwood Nuclear Power Station, Unit 2 Facility Operating License NPF-77 NRC Docket No. 50-457

" Emergency Core Cooling System Venting" 1

References:

1. T.J. Tulon (Comed) letter to the United States Nuclear Regulatory Commission (NRC) Document Control Desk, " Application for Exigent  !

Amendment to Appendix A, Technical Specifications, for Facility Operating Ucense NPF-37, NPF-66, and NPF-72, dated May 24,1997.

2. K. L. Graesser (Comed) letter to the NRC Document Control Desk,

" Supplement to Application for Exigent Amendment to Facility Operating License NPF-37, dated May 31,1997.

3. George F. Dick, Jr. (NRC) letter to I.M. Johnson (Comed), " Request for additional information Regarding Emergency Core Cooling System Venting - Braidwood Station, Unit 2 and Byron Station, Unit 2 (TAC Nos.

M98780 and M98782)", dated June 6,1997.

4. John Hosmer (Comed) letter to NRC Document Control Desk, " Request for Addi:ionallnformation Response for Emergency Core Cooling System Venting Surveillance," dated June 20,1997.

In Reference 1, Commonwealth Edison (Comed) requested an exigent amendment for Byron Units 1 and 2 and Braidwood Unit 2. The proposed change affects Technical Specification 4.5.2.b with respect to venting of Emergency Core Cooling System (ECCS) pump casings and discharge piping high points outside of containment. In Reference 2, Comed requested that the exigent amendment request in Reference 1 be approved as an emergency change for Byron Unit 1 because an emergency situation arose that would have prevented startup of Unit 1. In Reference 3, the NRC transmitted a request for additional information (RAI) concerning the exigent request for Byron Unit 2 and Braidwood Unit 2. Comed responded to the Reference 3 g 9707020229 970624

^ " '

E'E

~

h@l f E" llllOllllOllllljWlllJlllylillll A Unicom Company

d Byron 97-0152  !

June 24,1997 4 Page 2 '

i i

questions in Reference 4. Comed is revising the exigent Technical Specification submittal for i Byron Unit 2 and Braidwood Unit 2 based on discussions with the NRC staff and Comed's RAI  :

i response (Reference 4).

i

The changes to the original submittal are described in detail in Attachment A. The revised i Technical Specification changes are provided in Attachments B1 and B2 for Byron and l Braidwood, respectively. The proposed changes in this document are to supersede the

)

l corresponding pages in the original request (Reference 1). There is one change to the original I Attachment C, " Evaluation of Significant Hazards Consideration." Question 2 included a

statement that said " flows and/or pressures prevalent in these systems are sufficient to provide ,

' confidence that water hammer which could occur from voiding would not result in unacceptable dynamic loads." Based on a response to the RAI (Reference 4) the proposed changes to the l Bases in Reference 1 were revised to delete the reference to pressure. Subsequently, the j words "and/or pressures" are deleted from the Evaluation of Significant Hazards Consideration.

Please direct any questions to Marcia Lesniak, Nuclear Licensing Administrator, at (630) 663-6484.

Sincerely, K. L Graesser Site Vice President Byron Nuclear Power Station KLG/ML/rp Attachments l cc: A.B. Beach, Regional Administrator- Rlll S.D. Burgess, Senior Resident Inspector - Byron C.F. Phillips, Senior Resident inspector - Braidwood G.F. Dick, Jr., Project Manager- NRR Office of Nuclear Safety -IDNS

,,=:: :. . ::::::: ::_. :: . . . .__ .

Signed ppfore me this Mk day,

OFFICIAL SEAL ,

of NAuf , 1997, ll JACQUELINE T EVANS  !

by (/OA m L ll h % 0 f=$c^$' h*N#$f',LR*

...:: ::: m w ,

fotarf PubIic . ..

(p:\97byltrs\970152. doc)

l ATTACHMENT A DISCUSSION OF ADDITIONAL PROPOSED CHANGES FOR EMERGENCY CORE COOLING SYSTEM VENTING Commonwealth Edison (Comed) proposes to make four changes to the proposed Byron Unit 2 and Braidwood Unit 2 Technical Specifications (TS) for Emergency Core Cooling System (ECCS) Venting. The changes apply to the request transmitted on May 24,1997. These changes are based on informal discussions with the NRC and on Comed's response to the NRC's June 6,1997 request for additional information (RAI).

1. The original proposed TS Surveillance Requirement 4.5.2.b.1 limited the duration of the Technical Specification surveillance through the completion of Cycle 7 for Byron Unit 2 and through the completion of Cycle 6 for Braidwood Unit 2. The proposed revision removes the  !

cycle-based restriction on the applicability of the TS surveillance. Based on communication with the NRC Staff, it has been determined that there is no time dependency that requires a cycle restriction. Additionally, the Improved Technical Specifications (ITS) are scheduled to be implemented by July 1998 at both Byron and Braidwood. The surveillance requirement will simply require verification that the piping is full of water, without specifically requiring ver> ting to be performed.

2. The original proposed TS Bases includes the same cycle-based restriction as noted above.

The proposed revision removes this cycle-based restriction in the Bases for consistency with the surveillance.

3. The original proposed TS 4.5.2.b.3 verifies portions of the Chemical and Volume Control (CV) system is full of water by ultrasonically examining (UT) the discharge portion of the idle l CV pump up to the check valves (discharge and miniflow) and the stagnant portion of the ,

piping upstream of the Sl8801 A and B valves at the S1045 valve. Comed reviewed the CV l system piping as required by the RAI and discussed the results with the NRC Staff. An ,

intermediate high point location with vent valve CV206 is located in a section of the CV l

discharge piping which, dependent upon system operation, could be stagnant. This occurs I when the B train of the CV system is idle. As a result, the proposed revision wili add UT l inspection requirements at the CV206 valve if that train (the B train CV pump) is not operating. Adding a requirement to UT the piping at this location when the B CV pump is idle will provide additional confidence that the CV discharge piping is full of water.

4. The original proposed TS Bases include a discussion that the flows and/or pressures in the CV system provide confidence that water hammer would not result in unacceptable dynamic loads. The proposed revision will eliminate the reference to pressure. This change is made in accordance to Comed's response to the RAl.

(p:\97byltrs\970152. doc)