ML20153G416

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Forwards Revs J & M to TS Section 3.6 & 5.0,converting to Improved Tech Specs (Its),Originally Submitted on 961213. Revs Constitute Final Closeout for ITS Sections.Final Response to Rai,Encl
ML20153G416
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 09/25/1998
From: Tulon T
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20153G421 List:
References
NUDOCS 9809300069
Download: ML20153G416 (55)
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Text

Commonwealth filimn Company tiraldwood Generating Station p Route *l, llox 81 ilracesille. IL NH07/Xil9 Tel H l 5-iSH-2801 September 25,1998 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington D. C. 20555 - 0001

Subject:

Revision J and Revision M to the Improved Technical Specifications (ITS)

Submittal - ITS Se: tion 3.6 (Rev. J) Closecut and ITS Section 5.0 (Rev. M) Closcout Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Numbers: 50-454 and 50-4.55 Braidwood Nuclear Power Ntation, Units 1 and 2 Facility Operming Licenses NPF-72 and NPF-77 NRC Docket Numbers: 50-456 and 50-457

Reference:

G. Stanley and K. Graesser (Commonwealth Edison) letter to NRC Document Control Desk, " Conversion to the Improved Standard Technical SpeciGeations," dated December 13,1996 The purpose of this letter is to provide Revision J and Revision M to the referenced ITS submittal. ITS Revision J contains Commonwealth Edison's (Comed's) final Package Closeout for ITS Section 3.6. ITS Revision M contains Commonwealth Edison's '

(Comed's) final Package Closeout for ITS Section 5.0 I o

Enclosure 1 contains ITS Revision J. Attachment I contains Comed's final RAI

[ Responses to Section 3.6. Any revised response is noted along with the original response. Attachment 2 contains an affected page list summarizing ITS pages that have Og changed in Revision J. Attachment 3 is a list of Byron and Braidwood CTS pages that have been amended since Dc: ember 13,1996, the original Revision A submittal date.

Attachment 4 contains the SER Tables for ITS Section 3.6.

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m Document Control Desk U September 25,1998 Page 2 Enclosure 2 contains ITS Revision M. Attachment I contains Comed's final RAI Responses to Section 5.0. Any revised response is noted along with the original response. Attachment 2 contains an affected page list summarizing ITS pages that have changed in Revision M. Attachment 3 is a list of Byron and Braidwood CTS pages that have been amended since Decemoer 13,1996, the original Revision A submittal date.

Attachment 4 contains the SER Tables for ITS Section 5.0.

These Revisions are being provided in the sanw ten-section format as the initial ITS submittal:

1. Byron ITS
2. Braidwood (Brwd)ITS
3. Byron CTS Markups
4. Brwd CTS Markups
5. CTS Discussion of Changes (DOCS)
6. LCO Markups p 7. LCO Justification for Differences (JFDs)

(,) 8. Bases Markups

9. Bases JFDs
10. No Significant Hazards Consideration (NSHC)

Please address any comments or questions regarding this matter to our Nuclear Licensing Department.

Sincerely, T' , i y J./Tulon r

Vice President i raidwood Nuclear Generating Station Enclosure 1: ITS Revision J Attachments: Attachment 1 - ITS Section 3.6 RAI Revised Responses Attachment 2 - ITS Section 3.6 ITS Affected Page List Attachment 3 -ITS Section 3.6 CTS Amended Page List Attachment 4 -ITS Section 3.6 SER Tables v

Enclosure 2: ITS E,e 'sion M 2

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'vI September 25,1998 Page 3

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Attachments: ' Attachment 1 - ITS Section 5.0 RAI Revised Responses

' Attachment 2 - ITS Section 5.0 II Affected Page List Attachment 3 -ITS Section 5.0 Ci , Amended Page List

- Attachment 4 -ITS Section 5.0 SER Tables l

cc: NRC Regional Administrator - Region 111 Senior Resident Inspector - Braidwood 2 Senior Resident Inspector - Byron Office of Nuclear Facility Safety -IDNS nrc/98060tjt. doc i

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ATTACHMENT 1 l O. l ITS SECTION 3.6 RAI REVISED RESPONSES l

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BRAIDWOOD/ BYRON IMPROVED TECH SPEC

SUMMARY

DISPOSITION MATRIX CURRENT TECmtCAL SPEClflCAf!ON IMPR0vt0 T5 STAS 0ARD T5 mjREG-1431. Rty. I NRC BYRON /8RAIDWOG) NOTES Pist175 RESULYS - CRITERIA  ?

35 E*ERGtKV CORE CG1 LING SYSTEMS 35I ArClMil AftRS 351 351 3$l RE IA14 0 R[fAi4 0 - 3 357 (005 51E567[M5 TAVG e 3Wi 3S? 357 35? Rf YAIW D Rf TAIED - 3 353 ICCS StR575ftwi IAVG ( 3so f 353 353 353 Rf TAiW D RE TA14 0 3 354I (f(5 5tE57511M5 TAVG s ?00'f tPip if vfl ) st) 34I? N'A 34I? Rf TAIM D RITAIWD 2 3%42 f ff$ SURS6fiM5 IArG s 700 f IPIR If vil s %t) 4<A NtA NA N/A RfLOCATED w)1f 19 ,

355 Rf f tillT. WAff R STfFA2 TAR 354 355 354 Rf 1AlW D Rf1 AIM D - 3 36 CONTAIWENT SYSitwS 36II Om1 AIM NT INif GilIT 361 3611 36.1 RI IA!4 D R[ TAIM D 3 3612 OMTAIM NTIfABXE 361 36I? 36t Rf f A1410 Rf lAlW D 3 mitt 17 3613 OmtAIM NT AIR taKS 362 3613 367 Rf ! AIM D RI1 AIM D 3 3614 IMTIPvt PR155tRF 364 36I5 364 Rt1AlW D Rf TAIW D 7 36I5 AIR If 4 tRA10PT 365 3616 365 Pf TAlWD Rf ! A!M D 7 3616 CratAIMNT vf WL STRtiri1R4 INff f7]IT 361 36iF 361 Rf fA14 D Pf FATED - 3 Flff 13 O 36iT (T]NTAIMN1 PNRfl vt4Til Alif t 5f511M 363 36I9 363 RE TA140 Rt!Alwp 3 I 367I OmfAIMNT SPRAT 56 TIM 366 367.1 366 RilAlW D Rf l AlW D 3 Y 3622 SPRAY ADDillyf Sv5 TIM 367 36?? 36i Rf l AlW D REIAi40 3 0)' 3673 C0h1 AIM MI OH IT $v51(M 366 36?3 366 RE TAlW D RE IA{W D 3 363 CONT AIM N1 150t Afirm vat VES 363 364 363 Rt1AINLD Rf lA14 D 3 364i HvinGN ultrRS 333 3651 336 Rt TAlw D Rf IAt w D 3 ,

,A l 3642 f t f CTRIC HVfWYif u Rf 0PF14 P5 369 365? 368 Rf TAlwp pf 1Aiw p 3 ig 4-6 9/15/98 Povnim 1

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Response to NRC RAI For ITS Section 3.6 16-sep.98 I NRC RAI Number NRC issued Date RAI Status G 3.6-01 11/5/97 Closed-NRC Description ofissue DOC Al CTS 3/4.6.4.1, Hydrogen Monitors ITS 3.3.3 I

- ITS 3.3.6 l 1

The CTS markup'for CTS 3/4.6.4.1, Hydrogen Monitors, shows that this specification is retained as part ofITS 3.3.3; however, the CTS S?tit Report states this specification is retained as part ofITS 3.3.6 Radiation Monitoring. Comment:

Correct this discrepancy.

Comed Response to issue )

The Split Report was revised to state that the Hydrogen Monitors are being retained as part ofITS LCO 3.3.3.

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Response to NRC RAI For ITS Section 3.6 i 6-Sep-98 NRC RAI Number NRC issued Date RAI Status

^ 3.6-02 11/5/97 Closed NRC Description of issue DOC L9, JFD P.6 Bases 3D B2 (Bases for ITS 3.6.8)

Bases JFD P6 STS 3.6.9, Hydrogen Mixing System l

l DOC L9, JFD P.6, Bases JFD B2 (Bases for ITS 3.6.8), and Bases JFD P6 imply or state that the reactor containment fan

! coolers provide an alternate hydrogen control function similar to or the same as the STS hydrogen mixing system. ITS 3.6.6 4 l

and associated Bases do not contain any information or discussions about the hydrogen mixing / hydrogen control function of i the reactor containment fan coolers. In addition, JFD B6 and Bases JFD P.6 do not discuss how the containment cooling i

system SRs and Actions are more conservative than the Actions and SRs associated with STS 3.6.9. Comment: Adopt STS l 3.6.9 or a plant-spe inc equivalent in the ITS with appropriate discussions and justifications or provide additional discussion and justification fo. , adopting STS 3.6.9. See Comment 3.6.8-02.

Comed Response to issue The fact that the Containment Spray System and the Reactor Containment Fan Coolers (RCFCs) provide an alternate .

I hydrogen control function is discussed in the Byron /Braidwood UFSAR Section 6.2.5.2.3," Hydrogen Mixing System )

I Design," and states, "The function of the mixing subsystem is to ensure that local concentrations with greater than 4% '

hydrogen cannot occur within the primary containment following a LOCA. The mixing is achieved by natural convection 1 processes, containment fan cooler operation, and the containment spray system. Natural convection occurs as a result of the )

l temperature difference between the bulk gas space in the vessel and the containment wall. The natural convection action is '

enhanced by the momentum of steam emitted from the point of the break. The operation of the containment spray system following the accident will result in the creation of an extremely turbulent atmosphere within the containment. as f demonnrated in the Zion Station full-flow containment spray system test. The containment spray system is discussed in f Subsection 6.5.2. Mixing of the containment atmosphere to assure that there will be no " pocketing" oflarge hydrogen k concentrations will be accomplished by the reactor containment fan coolers (RCFC), an engineered safety feature described

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in Subsection 6.2.2. The operation of the recombiner system is not dependent on the operation of any engineered safety features other than the reactor containment fan coolers. Four coolers (two required for both normal and postaccident conditions) each supplying 94,000 cfm (normal operation) or 59,000 cfm (postaccident operation) are provided for each  ;

containment. The RCFC fans discharge this air through concrete ducts to the lower elevation." For completeness, the l Background Section of the Bases for ITS LCO 3.6.6. Containment Spray and Cooling Systems," was revised to add the sentence,"In addition, the Containment Spray System and Containment Cooling System provide an alternate hydrogen i control function to the hydrogen recombiners during post-LOCA conditions." The fact that the Post-LOCA Purge System I provides an alternate hydrogen control function is discussed in the Byron /Braidwood UFSAR Section 9.4.9.3.1.a.1, " Post- l LOCA Purge System Safety Design Bases " and states "The post-LOCA purge system is a non-safety-related system (per l Branch Technical Position CSB 6-2) which is provided as a backup to the hydrogen recombiners to purge the containment of  ;

hydrogen to maintain the hydrogen concentration below 4% by volume." Comed continues to pursue this change. (See RAI 3.6.8-02.)

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l Response to NRC RAI For ITS Section 3.6 16-Sep-98 NRC RAI Number NRC Issued Dats RAI Status O 3.6.1-01 11/5/97 Closed NRC Description of issue DOC Al CTS 3/4.6.1 CTS 3/4.6.1, the existing specification for primary containment, is the basis for ITS 3.61, Containment. In the upper right hand corner of the CTS markup, DOC Al shows CTS 3/4.6.1 also has requirements wHch apply to ITSs 3.7.3 and 5.5.16-l however, the CTS markup does not identify any specific requirements related to these specifications. DOC A l does not provide sufficient technicaljustification to explain this reference to ITSs 3.7.3 and 5.5.16. Comment: Revise the CTS markup to delete these ITS references or explain why they are appropriate.

Comed Response to issue l The CTS Markup pages were revised to delete the reference to ITS LCO 3.7.3. CTS DOC AS, as annotated c, the CTS Markup, references Specification 5.5.16.

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NRC RAI Number NRC issued Date RAI Status 3.6.1-02 11/5/97 Closed NRC Description of issue DOC Al CTS 3.6.1.6 Actions ITS 3.6.1 Action A CTS 3/4.6.1.6 ACTION a allows 15 days to restore containment integrity for structural degradation and ACTION b allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore containment integrity for an inoperable tendon group. Corresponding ITS 3.6.1 ACTION A allows one j^ hour to restore the containment Operable status. ITS 3.6.1 now includes all Operability requirements and remedial actions

\. for containment. Thur CTS 3.6.1.6 ACTIONS a and b are replaced with ITS 3.6.1 Action A. Since Action A is More Restrictive than the action requirements it replaces, this change is more restrictive, not administrative. Comment: Revise the submittal to show that CTS 3.6.l.6 Actions a and b are replaced by Action A ofITS 3.6.1, and provide justification for this more restrictive change. See Comment 3.6.1-03.

Comed Response to Issue 9/17/98 Revised Response: Comed is resubmitting the CTS Markup pages with CTS License Amendment #90 for Braidwood and #102 for Byron incorporated. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: No change. CTS 3.6.1.6 Actions a and b provide actions to restore the tendon (s) or the containment vessel to the required level ofintegrity within 15 days and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, respectively, and perform an engineering evaluation of the containment within 30 days and 15 days, respectively. The purpose of the evaluation is to demonstrate compliance with CTS 3.6.1.1 for primary containment integrity. Only after the engineering evaluation is performed and it is determined that primary containment integrity is lost, is the I hour action of CTS 3.6.1.1 applicable. Further, as addressed in Section 5.0 DOC A38 and LA14, the requirements for the Containment Vessel Structural Integrity Specification (CTS LCO 3.6.1.6) are placed in a program in the Administrative Controls Chapter (ITS Specification 5.5.6, " Pre-Stressed Concrete Containment Tendon Surveillance Program"). Section 5.0 provides the markups and justifications for CTS LCO 3.6.1.6. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change. (See RAls 3.6.1-03 and 3.6.1 -05.)

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RcSponi,e to NRC RAI For ITS Section 3.6 16-sep-98 I l

NRC RAI Number NRC lssued Date RAI Status

/~ 3.6.1-03 11/5/97 Closed

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NRC Description of issue DOC Al CTS 3.6.1.6 Actions ITSs 5.5.6 and 5.6.8 CTS 3.6.1.6 Actions require submitting Special Reports to the Commission in accordance with CTS 6.9.2. Since these CTS Actions are replaced by ITS 3.6.1 ACTION A, which does not requhe Special Reports, the CTS markup should indicate the disposition of the requirement for Special Reports - whether moved to another specificatiou or deleted. DOC A l indicates generally that portions of CTS 3.6.1.6 are moved to ITS 5.5.6 and 5.6.S: however, the CTS q'arkup does not indicate which of these details are moved to these specifications. Comment: Revise the CTS markup to show which items remain in ITS 3.6.1 and which are moved to ITS 5.5.6 and 5.6.8. Provide additioaal discussions andjustifications for these changes. See Comments 3.6.1-02 and 3.6.1-05.

Comed Response to issue 9/17/98 Revised Response: Comed is resubmitting the CTS Markup pages with CTS License Amendment #90 for Braidwood and #102 for Byron incorporated. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: No change. As addressed in Section 5.0 DOC LA14, the reporting requirements of the containment structure are contained in ITS Specification 5.6.8," Tendon Surveillance Report," which was adopted verbatim. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change. (See RAls 3.6.1-02 and 3.6.1 -05.)

NRC RAI Nmaber NRC lssued Date RAI Status 3.6.1-04 11/5/97 Closed NRC Description ofIssue DOC AS CTS 4.6.1.1.c CTS 4.6.1.2.a, b, c, d, and g CTS 4.6.1.3.a b, and d ITS SR 3.6.1.1-ITS SR 3.6.2.1 The above referenced CTS requirements are being changed to reflect the 10 CFR 50 Appendix J, Option B requirements as modified by TSTF 52. DOC A5 states this change applies only to CTS 4.6.1.1.c and 4.6.1.3; whereas, this change actually applies to all of the CTS requirements referenced. DOC A5 needs to be indicated on the CTS markup for every me to which it applies and should be revised to reference all afTected CTS requirements. Comment: Revise the CTS m Kap and DOC A5 to address andjustify all the administrative changes relative to adopting Option B.

Comed Response to Issue l 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer. In addition, DOC 3.6-A5 has been revised to include reference to CTS SR 4.6.l.2.h. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

1 Original Response: No change. As addressed in Section 5.0 DOC LA24, CTS 4.6.1.2.a. b, c, d, and g and CTS 4.6.1.3.a. b.

and d are placed in a program in the Administrative Controls Chapter (ITS Specification 5.5.16, " Containment Leakage Rate Testing Program"). Section 5.0 provides the markups andjustifications for these surveillances. This presentation conforms l to the standard for ITS submittals. Comed continues to pursue this change. (See RAls 1.0-07,3.6.1-09,3.6.2-01,3.6.2-08.

and 3.0-11.)

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Response to NRC RAI For ITS Scction 3.6 16-Sep-98 NRC RAI Number NRC Issued Date RAI Status 3.6.1-05 1I/5/97 Closed NRC Description of Issue DOC A12 CTS 3.6.1.1 CTS 4.6.1.6.1 ITS SR 3.6.1.2 CTS 4.6.1.6.1 states " Containment vessel tendons' structural integrity shall be demonstrated.. " Corresponding ITS SR 3.6.1.2 states " Verify containment structural integrity in accordance with the Containment Tendon Surveillance Program."

DOC A12 states the CTS requirement is technically equivalent to the ITS requirement; however, in the CTS markup, DOC.

A12 is associated with CTS 3.6.1.1 when it should be placed with CTS 4.6.1.6.1, where the CTS requirement originates.

Comment: Revise the submittal to address the administrative changes to CTS 4.6.1.6.1. See Comment 3.6.1-03.

Comed Response to issue 9/17/98 Revised Response: Comed is resubmi.ang the CTS Markup pages with CTS License Amendment #90 for Braidwood and #102 for Byron incorporated. As a result of the Amendments, DOC 3.6-A12 is no longer valid and is therefore deleted. This change is provided in our comprehensive ITS Section 3.6, closeout submittal Revision J.

Original Response: DOC A12 designator was added to the top of the page for CTS LCO 3.6.1.6. (See RAls 3.6.1-02 and 3.6.1-03.)

NRC RAI Number NRC issued Date RAI Status 3.6.1 06 11/5/97 Closed NRC Description of Issue p DOC A36 for ITS Section 5.0 CTS 1.7.d ITS SR 3.6.1.1 CTS 1.7.d (Containment Leakage Rates) is not accounted for in the CTS markup for ITS 3.6.1. DOC A36 for ITS Section 5.0 stat:s that this is a cross reference to another CTS and therefore can be deleted, as an administrative change. Since the CTS referenced is CTS 3.6.1.2 which is addressed in the CTS markup ofITS SR 3.6.1.1, CTS 1.7.d is not deleted but retained as ITS SR 3.6.1.2. The change should not be addressed under ITS Section 5.0, but under ITS 3.6.1. Comment:

Revise the submittal to include a justification and discussion of this administrative change with the DOCS associated with ITS 3.6.1.

Comed Response to Issue 9/17/98 Revised Response: Based on discussions with the ITS Section 3.6 NRC Reviewer, DOC 3.6-A32 was created to reiterate DOC 5.0-A36 in ITS Section 3.6. This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J.

Or:ginal Response: No change. CTS Specification 1.7.d states, " Containment integrity shall exist when the containment leakage rates are within the limits of Specification 3.6.1.2." In Section 3.6, the CTS markup for Specification 1.7.d illustrates that 1.7.d is addressed in Section 5.0. Similarly. CTS LCO 3.6.1.2 and CTS 4.6.1.1.c are both addressed in Section 5.0 for Specification 5.5.16, " Containment Leakage Rate Testing Program," as illustrated in the CTS Markups for Section 3.6. Section 5.0 DOC A36 deletes CTS Specification 1.7.d because it simply provided a reference to another technical specification. The Frequency for ITS SR 3.6.1.1 states,"In accordance with the Containment Leakage Rate Testing Program." This change is appropriately contained in Section 3.6 DOC A5 for the CTS markup of CTS 4.6.1.1.c.

which references the Containment Leakage Rate Testing Program. Section 3.6 DOC A12 addresses ITS SR 3.6.1.2. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change. (See RAls 3.6.1-08 (l.7.e),3.6.2-06 (l.7.c), and 3.6.3-06 (l.7.a).)

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s Response to NRC RAI For ITS Section 3.6 16-sep-98 NRC RAI Number NRC Issued Date RAI Status

/ 3.6.1-07 11/5/97 Closed NRC Description of Issue DOC MI CTS 3.6.l.1 Actions CTS 3.6.1.2 Actions ITS 3.6.1 Actions CTS 3.6.1.2 Actions restrict reactor coolar. heatup beyond 200 F if the containment leakage rates are outside established limits. However, no Actions are provided in CTS 3.6.1.2 if the reactor coolant temperature is >200 F (Mode 4) and the containment leakage rates are outside established limits. In this case, CTS 3.0.3 or CTS 3.6.1.1 Actions are to be entered since they are equivalent. Because ITS 3.6.1 Actions are the same as both CTS 3.6.1.1 Actions and CTS 3.0.3. :he replacement of these CTS Action requirements by the Actions ofITS 3.6.1 is actually an administrative change rather than a more restrictive change. Comment: Revise the submittal to address this change in presentation of CTS action requirements l

as an administrative change. .

i Comed Response to issue 9/l7/98 Revised Response: Section 3.6 DOC M1 was deleted and DOC A31was added per Original Response. This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J.

Original Response: Section 3.6 DOC M I was deleted and an administrative ('A') DOC was added which states, " CTS 3.6.1.2 Actions restrict reactor coolant heatup beyond 200 'F if the containment leakage rates are outside established limits.

If the reactor coolant temperature were > 200 'F (Mode 4) with the containment leakage rates outside established limits, the actions of CTS LCO 3.0.3 would apply. With ITS SR 3.6.1.1 not met for containment leakage rate testing. the Required l Actions ofITS LCO 3.6.1 would apply. Since these actions are comparable to CTS LCO 3.0.3, this change is considered l administrative in nature. This change is consistent with NUREG 1431."

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Response to NRC RAI For ITS Section 3.6 16-sen-98 NRC RAI Number NRC issued Date RAI Status 3.6. l-08 l1/5/97 Closed NRC Description of Issue DOC LA18 l DOC LA19 for ITS Section 5.0 Bases JFD B5 CTS 1.7.e Bases Background discussion for ITS 3.6.1 As part of the definition of Containment Integrity (or what is required for an Operable containment) CTS 1.7.e requires Operable penetration sealing mechanismt This requirement is not accounted for in the CTS markup for ITS 3.6.1 Bases; rather it is addressed by DOC LA19 for ITS Section 5.0 as being moved outside the ITS to the Containment Leakage Rate Testing Program (ITS 5.5.16). In addition, this condition for an Operable containment, which is contained in the Bases Background discussion for STS 3.6.1, is not adopted in the Bases for ITS 3.6.1. Bases JFD B5 justifies this omission by l stating this condition is not applicable to the plant design. However, DOC LA19 for ITS Section 5.0 states that CTS 1.7.e is a detail with respect to containment Operability that has to been moved outside the ITS to the Containment Leakage Rate

! Testing Program. Because this detail is a condition fc.r containment Operability, it should be stated in the Bases Background discussion for ITS 3.6.1, as was done with the balance of CTS 1,7, consistent with the STS. Comment: Revise the submittal for ITS Section 3.6.1 with an LA-type justification for moving the containment operability condition of CTS 1.7.e to the Bases for ITS 3.6.1 consistent with the STS. Make appropriate changes to the CTS and STS markups and DOC LA19 for ITS Section 5.0. See Comment 3.6.1-06.

Comed Response to issue 9/17/98 Revised Response: Same as Original Response, except that the Background Section of the Bases for ITS LCO 3.6.1 was revised to read, "The sealing mechanism assaciated with each penetration (e.g., welds, bellows, or O rings) is OPERABLE, except as provided in LCO 3.6.3." This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J.

Original Response: Section 3.6 DOC LAIS has been revised a read," CTS Definition 1.7 includes details with respect to Containment Integrity. Consistent with NUREG-1431, Definition 1.7 items a, b, c, and e are relocated to the Background section ofITS LCO 3.6.1 Bases. Item d is discussed in ITS Section 5.0. These details (CTS Definition 1.7 items a, b, c. and e) are attributes of containment Operability. ITS LCO 3.6.1 requires containment to be OPERABLE. ITS 3.6.1 and the definition of Operability suffice. As such, these relocated details are not required to be included in the TS to provide adequate protection of the public health and safety. Any change to the details relocated to the Bases will be made in accordance with the Bases Control Program described in ITS Section 5.5." Section 5.0 DOC LA 19 was deleted. The Background Section of the Bases for ITS LCO 3.6.1 was revised to include item d and reads. "The pressurized sealing mechanism associated with a penetration is OPERABLE." (See RAls 3.6.1-06 (1.7.d),3.6.2-06 (1.7.c), and 3.6.3-06 (1.7.a).) .

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Response to NRC RAI For ITS Section 3.6 16-sen-98 l l NRC RAI Number NRC Issued Date RAI Status 3.6.1-09 11/5/97 Closed NRC Description of issue Bases JFD Cl CTS 4.6.1.1.c l CTS 4.6.1.2 STS SR 3.6.1.1 ITS SR 3.6.1.1 and associated Bases discussion CTS 4.6.1.1.c and 4.6.1.2 require leak rate testing in accordance with R.G.1.163 and 10 CFR 50 Appendix J. Option B.

STS SR 3.6.1.1 requires the visual examination and leakage rate testing be performed in accordance with 10 CFR 50 Appendix J as modified by approved exemptions. ITS SR 3.6.1.1 modifies STS SR 3.6.1.1 to conforms to CTS 4.6.1.1.c and 4.6.1.2, as modified in the CTS markup. The STS is based on Appendix J Option A while the CTS and ITS are based on App ~idix J, Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr.  !

Christopher 1. Grimes to Mr. David J. Modeen, NEl, dated 11/2/95, and TSTF 52. While the ITS SR 3.6.1.1 differences from STS SR 3.6.I,1 are in conformance with the letter or TSTF 52 as modified by staff comments, the change to the ITS Bases are not in conformance. Comment: Comed should revise the submittal, to conform to the i 1/2/95 letter and to the  ;

updated TSTF 52 once the Owners Groups provides revision. Otherwise, additionaljustification is required for the deviations.

Comed Response to issue 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC ,

Reviewer. This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J. j Original Response: Comed has conformed to TSTF 52, Revision 0, which was drafted based on the i1/2/95 letter. Prior to l issuance of the ITS SER, Comed will evaluate any NRC/ industry approved revisions to TSTF-52, and will incorporate 1 applicable changes into the ITS submittal as appropriate. (See RAls 1.0-07,3.6.1-04,3.6.2-08, and 3.0-11.)

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Response to NRC RAI For ITS Section 3.6 16-sep.98 NRC RAI Number NRC Issued Date RAI Status 3.6.1 10 11/5/97 Closed NRC Description of Issue Bases JFD Pl Bases for STS SR 3.6.1,1 Bases for ITS SR 3.6.1.1 The Bases for STS SR 3.6.l.1 states the following: " Failure to meet air lock [and purge valve with resilient seal] leakage l

limits...causes that to exceed limits." The Bases for ITS SR 3.6.1.1 adopts different wording at the end of this sentence and reads as follows: "...causes the limits to be exceeded." Bases JFD Pi bases this difference from the STS as a general

( reformatting / editorial rewording for plant specific nomenclature. However, this change is not for clarity or for plant specific

[ nomenclature, but would be considered a generic editorial change to the STS. Comment: Revise the submittal to conform to l

the STS wording.

Comed Response to Issue 9/17/98 Revised Response: The ITS submittal has been revised to conform to the STS wording. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: No change. The Surveillance Requirements Section of the Bases for ITS LCO 3.6.1 states," Failure to meet air lock and purge valve leakage limits specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes [TH AT to exceed limits)." Comed believes that the use of the word "that" is not clear. Therefore, the sentence has been modified to read

" Failure to meet air lock and purge valve leakage limits specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless heir contribution to overall Type A, B, and C leakage causes

[the limits to be exceeded]." As Bases JFD P1 states, certain wording preferences were adopted in order to enhance the understanding by plant operators and other users. Comed continues to pursue this change.

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Response to NRC RAI For ITS Section 3.6 i6-Sep-98 NRC RAI Number NRC issued Date RAI Status r~% 3.6.1-11 11/5/97 Closed NRC Description of Issue DOC /JFD - None CTS 4.6.1.2.e CTS 4.6.1.2.f ITS SR 3.6.2.1 ITS SR 3.6.3.6 and SR 3.6.3.7 CTS 3/4.6.1.2 has not been retained as a separate LCO in the ITS. CTS 4.6.1.2.e states " Air locks shall be tested and demonstrated OPERABLE". This requirement is now ITS SR 3.6.2.1. CTS 4.6.2.1.f states that " Purge supply and exhaust isolation valves...shall be tested and demonstrated OPERABLE.. " per CTS requirements which are now ITS 3.6.3.6 and SR 3.6.3.7. Therefore, these CTS requirements are not relocated to ITS 5.5.16 as is shown on the CTS markup. Comment:

Revise the submittal to show the CTS 4.6.1.2.e and 4.6.2.1.f are relocated to ITS 3.6.2 and 3.6.3 respectively and revise the CTS markups for ITS 3.6.2 and 3.6.3 respectively to include these marked up paF 3. See item Numbers 3.6.2-4 and 3.6.3-;.

Comed Response to issue 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: No change. CTS 4.6.1.2.e states. " Air locks shall be tested and demonstrated OPERABLE by the requirements of Specification 4.6.1.3. CTS 4.6.1.3.a. b, and d delineate how the air lock shall be demonstrated i

OPERABLE. The details of what ccnstitutes OPERABILITY are addressed in Specification 5.5.16 as the CTS markup  ;

illustrates. Likewise, CTS 4.6.1.2.f(not 4.6.2.1.f) states, " Purge supply and exhaust isolati on valves with resilient material seals shall be tested and demonstrated OPERABLE by the requirements of Specification 4.6.1.7.3 or 4.o.l.7.4." CTS 4.6.1.7.3 and CTS 4.6.1.7.4 delineate details of OPERABILITY. These details are relocated to the TRM as specified in i LCO JFD LA16. Therefore, the CTS Markups for CTS 4.6.1.3 (ITS SR 3.6.2.1). CTS 4.6.1.7.3 (ITS SR 3.6.3.7). and CTS 4.6.1.7.4 (ITS SR 3.6.3.6) are appropriate and correct. This presentation conforms to the standard for ITS submittals.

O% Comed continues to pursue this change.

1 NRC RAI Number NRC lssued Date RAI Status l 3.6.2-01 11/5/97 Closed NRC Description ofIssue DOC AS CTS 4.6.1.3.a, b. and d ITS SR 3.6.2.1 Comment: See Comment 3.6.l-04 i l

Comed Response to issue 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Ori Final Response: ho change. Comed continues to pursue this change. See Comed Response to RAI 3.6.1-04.

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i R:sponse to NRC RAI For ITS S:ction 3.6 16-Sep-98 NRC RAI Number NRC lssued Date RAI Status j I

/~T J 3.6.2-02 11/5/97 Closed NRC Description of Issue DOC A6 JFD P5 STS 3.6.2 Actions Note 3 )

ITS 3.6.2 Actions Note 3 i l

STS 3.6.2 Actions Note 3 states: " Enter applicable Conditions and Required Actions of LCO 3.6.1," Containment" when air lock leakage results in exceeding the overall containment leakage rate." ITS 3.6.2 ACTIONS Note 3 changes the word "when" to "if'. JFD PS bases this difference on achieving consistency with changes made to other sections. This justification is inadequate and the staff considers this change to be a generic change to the STS. Comment: Revise the Note to adopt the STS wording.. )

Comed Response to issue The Note was revised to adopt the STS wording. (See RAls 3.4.14-02,3.7.7-04,3.7.8-06, and 3.8.1-22.)

NRC RAI Number NRC Issued Date RAI Status 3.6.2-03 11/5/97 Closed i NRC Description of Issue

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DOC All DOC L7 CTS 3.6.1.3 Action a.1 CTS 3.6.1.3 Action b ITS 3.6.2 Required Actions A.1 and C.2 -

O h CTS 3.6.1.3. Actions a.1 and b require an air lock door to be maintained closed; with the time requirement in which to complete the action to be " maintain closed" is up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.6.2 Required Actions A.I and C.2 state that the air lock door is to be verified closed within a one hour. The change to CTS 3.6.1.3 ACTION a.1 is justified as L.7, Action b is justified as A.ll. Thejustification provided with A.11 is "Not used." Also, these are more restrictive CTS changes (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to I hour), not administrative (A.11) and less restrictive (L.7). Comment: Revise the submittal and provide additional discussion and justification for this more restrictive change.

Comed Response to Issue 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer. Specifically, DOCS 3.6-L7 and 3.6-All were changed to DOC 3.6-M2. This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J.

Original Response: Section 3.6 DOC A11 for CTS 3.6.1.3 Action b has been changed to DOC L7, consistent with CTS Action a.l. Comed maintains that this change is "less restrictive" in that the action to " maintain at least the OPERABLE /one air lock door closed" can be interpreted to mean "immediately" take action, whereas in ITS 3.6.2 Required Action A.I and C.2, this requirement is changed to " verify" and a I hour time period is specified.

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l R:sponse to NRC RAI For ITS Section 3.6 16-Sep-98 NRC RAI Number NRC lssued Date RAI Status O

a 3.6.2-04 11/5/97 Closed

'.- NRC Description of Issue DOC Mi l ITS 3.6.2 Actions Note 3 i CTS 3.6.1.2 Actions ITS 3.6 2 Actions CTS 4.6.1.2.e ITS SR 3.6.2.1 Because CTS 4.6.1.2.e corresponds to ITS SR 3.6.2.1 (See Comment 3.6.1-11), CTS 3.6.1.2 Actions also apply to ITS

3.6.2. Comment

Revise the CTS markup for ITS 3.6.2 to include CTS 3.6.1.2 Actions. See Comments 3.6.1-7 and 3.6.l.

I1.

Comed Response to Issue 9/17/98 Revised Response: Based on discussions with the ITS Section 3.6 NRC Reviewer, the CTS Markup page for 3.6.1.2 was revised to reflect ITS LCO 3.6.2 Note 3 and DOC 3.6-A6 was created to document this change. This change is i provided in our comprehensive ITS Section 3.6 closeout submittal Revision J. I Original Response: No change. CTS 4.6.1.2.e states. " Air locks shall be tested and demonstrated OPERABLE by the requirements of Specification 4.6.1.3." CTS 4.6.1.3 (not CTS 3.6.1.2) stmes. "Each containment air lock shall be demonstrated OPERABLE ." CTS 4.6.1.3 corresponds to ITS SR 3.6.2.1 as illustrated in the CTS markup. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change.

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Response to NRC RAI For ITS S:ction 3.6 16-sen-98 NRC RAI Number NRC issued Date RAI Status 3.6.2-05 11/5/97 Closed ,

NRC Description of issue DOC LA2 DOC L1 DOC L2 CTS 3.6.1.3.a ITS 3.6.2 Actions Note 1 ITS 3.6.2 Action A Note 2 ITS 3.6.2 Action B Note 2 CTS 3.6.1.3.a states that the containment airlock doors are to be closed except when the air lock is being used for normal transit entry and exit, during which at least one door must remain closed. This information according to DOC LA2 is relocated to the Bases. This is not entirely correct. The information with regards to using the air lock doors for normal entry and exit appears to be retained, with clarifications, in ITS 3.6.2 Actions Note 2, ITS 3.6.2 Action A Note 2 and ITS 3.6.2 Action B Note 2. Thus it should be considered as an extension of this requirement to the CTS 3.6.1.3 Actions. Comment:

Revise CTS 3.6.1.3.a to reflect this Administrative change. Provide additional discussion and justification for this change.

Comed Response to issue 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC J Reviewer. Specifically, DOCS 3.6-L1 and 3.6-L3 were changed to DOC 3.6 A6, and DOC 3.6-L2 was changed to DOC 3.6-M3.This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J. 1 1

Original Response: No change. There is a distinct difference between OPERABILITY requirements and Required Actions, including Notes in Required Actions. The statement in CTS 3.6.1.3.a which states, "Each containment air lock shall be OPERABLE with both doors closed except when the air lock is being used for normal transit entry and exits through the containment, then at least one air lock door shall be closed," describes what constitutes containment air lock g

OPERABILITY. As addressed in Section 3.6 DOC LA2, these details are being relocated to the Surveillance Requirements

( Section of the Bases for ITS LCO 3.6.2. Since Surveillance Requirements (SRs) are the mechanisnis by which OPERABILITY, and therefore compliance with a specification, is demonstrated, this change is appropriate. Correlating this information with Actions would be inappropriate since Actions are only entered when an LCO/SR is not met. Comed continues ta pursue this change.

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Resp::nse to NRC RAI For ITS Section 3.6 16-sep-98 NRC RAI Number NRC issued Date RAI Status O 3.6.2-06 1I/5/97 Closed U NRC Description of Issue DOC LA18 CTS 1.7.c ITS SR 3.6.2.1 ITS SR 3.6.2.2 CTS 1.7.c has been relocated to ITS B3.6.1 Bases-BACKGROUND perjustification LA.lS. While it is acceptable to relocate CTS 1.7 to the Bases, CTS 1.7.c also refers to the requirements of CTS 3.6.1.3 which would translate to ITS SRs 3.6.2.1 and 3.6.2.2. Thus the markup of CTS 1.7 should also be included in the CTS markup for ITS 3.6.2. Comment: i Provide the appropriate markup of CTS 1.7 in the ITS 3.6.2 CTS markup. Provide additional discussion and justification for I this administrative change.

Comed Response to issue 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

1 Original Response: No change. CTS Specification 1.7.c references CTS LCO 3.6.1.3, which by definition includes Surveillance Requirements. The CTS markup for 4.6.1.3 appropriately addresses ITS SR 3.6.2.1 as designated by Section 3.6 DOC A5 and DOC A6. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change. (See RAls 3.6.1-06 (1.7.d),3.6.1-08 (1.7.e), and 3.6.3-06 (1.7.a).)

NRC RAI Number NRC issued Date RAI Status 3.6.2-07 11/5/97 Closed NRC Description of Issue s DOC L2 CTS 3/4.6.1.3 Actions ITS 3.6.2 Action A Note 2 Based on the discussion in Comenent 3.6.2-5, the addition of a 7-day limit for entry and exit with one or more air locks having one air lock door inoperable could be considered as a more restrictive change, since the CTS would allow an l indefinite period of time. Comment: Provide additional discussion and justification for this more restrictive change. See '

Item Number 3.6.2-5.

Comed Response to issue 9/l7/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer (see Revised Response to RAI 3.6.2-05). This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J.

Original Response: No change. Per CTS 3.6.1.3 Action a. with one air lock door inoperable, the operable air lock door must be maintained closed. As addressed in Section 3.6 DOCS L1, L2, and L7, CTS 3.6.1.3 actions do not contain provisions for opening a door that is required to be closed to comply with the required actions. Comed continues to pursue this change.

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Respens2 to NRC RAI For ITS Section 3.6 16-sep.98 NRC RAI Number NRC Issued Date RAI Status 3.6.2-08 1I/5/97 Closed V' NRC Description of issue JFD-Bases C.1 CTS 4.6.1.2.e CTS 4.6.1.3.a CTS 4.6.1.3.b CTS 4.6.1.3.d ITS SR 3.6.2.1 and associated Bases Comment: See Comment 3.6.1-09.

Comed Response to Issue 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer (see RAI 3.6.1-09). This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J. j l

Original Response: Comed has conformed to TSTF-52, Revision 0, which was drafted based on the 1 I/2/95 letter. Prior to issuance of the ITS SER, Comed will evaluate any NRC/ industry approved revisions to TSTF-52, and will incorporate applicable changes into the ITS submittal as appropriate. (See RAls 1.0-07,3.6.1-04,3.6.1-09, and 3.0-11.)

NRC RAI Number NRC issued Date - RAI Status 3.6.2-09 11/5/97 Closed l NRC Description of Issue Bases JFD C2 l STS SR 3.6.2.2 and associated Bases l

/*

ITS SR 3.6.2.2 and associated Bases l

'k STS SR 3.6.2.2 requires verifying caly one door in the air lock will open at a time at six month intervals. The interval is modified in ITS SR 3.6.2.2 from 6 months to 24 months. This modification is in accordance with TSTF-17; however, the Bases changes are not in accordance with TSTF-17. Comment: Revise the ITS Bases to be in accordance with TSTF 17 or justify the deviations.

l Comed Response to issue I Insert B 3.6-27C in the Surveillance Requirements Section of the Bases for ITS LCO 3.6.2 has been modified to conform to

! TSTF-17, Revision 1, and reads, ". . used for entry and exit (procedures require strict adherence to single door opening), this

! test is only required to be performed every 24 months. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPER ABILITY if the Surveillance were performed with the reactor at power. The 24 month Frequency for the interlock is justified based on generic operating experience." Additionally, Bases JFD C2 was revised to read, "This change is consistent with NUREG-1431, as modified by TSTF-17, Revision 1."

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Response to NRC RAI For ITS S:ction 3.6 16-sep-98 NRC RAI Number NRC lssued Date RAI Status O 3.6.2 10 11/5/97 Closed NRC Description of issue JFD Pl5 Bases discussion ofITS 3.6.2 Required Actions A.1, A.2 and A.3, B.l. B.2.

and B.3, and C.1, C.2 and C.3 The listed Bases discussions differ from the STS to clarify the actions to be taken for two inoperable air lock doors in the same air lock. The stafThas reviewed the changes and finds that it reiterates information already included in the Bases and other sections of the ITS. In addition, the staff considers this change to be generic. This is not a justifiable plant specinc or editorial difference from the STS. Comment: Revise the ITS Bases to delete the proposed clarification.

Comed Response to Issue The Bases for ITS LCO 3.6.2 have been revised to withdraw the change associated with Bases JFD P15.

NRC RAI Number NRC lssued Date RAI Status l 3.6.3-01 11/5/97 Closed NRC Description of issue DOC A17 CTS 3.6.3 DOC LAl )

CTS 3.6.3 Table 3.6-11 JFD B6 ITS LCO 3.6.3 Note ,

JFD C3 I O/

STS LC0 3.6.3 Bases JFD C3 Bases discussion of LCO for ITS 3.6.3 Bases JFD PS ITS LCO 3.6.3 contains a note not contained in CTS 3.6.3 or STS LCO 3.6.3. This note exempts the feedwater isolation valves (FWlVs), the FWlV bypass valves, the feedwater preheater bypass valves and the feedwater tempering valves from this specification. The justifications (DOC A3, JFD B6, and Bases JFD PS) state that the containment isolation function for these valves is covered by ITS LCO 3 7.3 and JFD C3 and Bases JFD C3 state that this difference change is in accordance with TSTF-44 Rev.l. The stafThas rejected TSTF 44 Rev. O and TSTF 44 Rev. I has not been submitted to the staff for review. The staff considers this change to be a generic change that is beyond the scope of review for this conversion.

Comments: Delete this generic change.

Comed Response to issue TSTF-44 has been withdrawn from the ITS submittal. Comed is deleting LCO 3.7.3, "FW lsolation Valves," from the ITS submittal and retaining the requirements for feedwater valves in ITS LCO 3.6.3, " Containment Isolation Valves," consistent with Byron /Braidwood Current Licensing Basis. i j

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ROSponse to NRC RAI For ITS S:ction 3.6 16-Sep-98 NRC RAI Number NRC Issued Date RAI Status

[]

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3.6.3-02 1I/5/97 Closed

NRC Description of issue DOC A18 ITS SR 3.6.3.3 DOC L1!

ITS SR 3.6.3.4 l CTS 4.6.1.1.a l ITS SR 3.6.3.8 i CTS 4.6.3.2 l CTS 4.6.1.1.a, CTS 4.6.3.2, and various other ITS 3.6.3 SRs, state the requirements te verify that valves are demonstrated l Operable. The CTS requirements have been revised to only require these surveillances for valves that are not locked. sealed. l or otherwise secured in position. This change reduces the number of valves subjected to these surveillance requirements. In some cases this change is designated Administrative (DOC AIS) and in others less restrictive (DOC L11). The staff considers this change Less Restrictive in every case because this exempts previously tested valves from the surveillance.

Comment: Revise the submittal to treat all instances of this change as less restrictive and add additionaljustification and i discussion as appropriate.

Comed Response to issue CTS SR 4.6.2.1.c.I, SR 4.6.2.2.c and SR 4.6.3.2 have been revised to add the phrase, "that is not locked, sealed, or  !

otherwise secured in position." The CTS markups for these SRs have been revised to designate them as 'less restrictive'.

Therefore, all'A18' designators have been replaced by 'L1 l' designators, and Section 3.6 DOC A 18 was deleted. Section 3.6 DOC L1 I was revised to state, " CTS SR 4.6.l.l.a, SR 4.6.2.1.c.1), SR 4.6.2.2.c and SR 4.6.3.2 require periodic verification that the valves are in their correct position. ITS requires the same verification, but excludes valves that are locked. sealed. or otherwise secured in their correct position. This allows these valves, which are secured in their required position under g administrative controls, to be exempted from the surveillance. These valves are secured in their accident position and are not

( ) required to actuate to perform their safety function. Proper positioning of valves is administratively controlled by the Out of

'd Service Program in conjunction with the Locked Equipment and Caution Card Program. These programs ensure valves are maintained in their proper position by requiring independent verification of safety-related or other important equipment.

documentation of the position oflocked equipment in a surveillance program, and periodic reviews of equipment normally required to be locked. Exempting these valves that are secured in their required position is perceived as the intent of the CTS wording, and therefore, the addition of the phrase more accurately reflects this intent." (See RAls 3.6.6-01, and 3.6.7-01.)

NRC RAI Number NRC issued Date RAI Status

! 3.6.3-03 1I/5/97 Closed NRC Description of Issue DOC A29

.iFD P5 CTS 3.6.3 Actions STS 3.6.3 Actions Notes and associated Bases ITS 3.6.3 Actions Notes and associated Bases.

Comment: See Comment 3.6.2-02 Comed Response to issue The Note was revised to adopt the STS wording.

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Response to NRC RAI For ITS S:ction 3.6 i6-Sep-98 NRC RAI Number NRC lssued Date RAI Status O 3.6.3-04 11/5/97 Closed NRC Description ofissue DOC M1 ITS 3.6.3 Actions Note 4 CTS 3.6.1.2 Actions ITS SR 3.6.3.7 CTS 4.6.1.2.f ITS SR 3.6.3.8 ITS 3.6.3 Actions Because CTS 4.6.1.2.f applies to ITS SR 3.6.3.7 and SR 3.6.3.8 (See Comment 3.6.1-11). CTS 3.6.1.2 Actions also apply to ITS 3.6.3. See Comment 3.6.1-7. Comments: Revise the CTS markup for ITS 3.6.3 to include CTS 3.6.1.2 Actions. See Comment 3.6.17 and 3.6.1-11.

l Comed Response to issue j 9/17/98 Revised Response: The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: No change. Comed continues to pursue this change. (See Comed Response to RAI 3.6.1-11.)

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Response to NRC RAI For ITS Section 3.6 16-sen-98 I NRC RAI Number NRC lssued Date RAI Status 3.6.3-05 11/5/97 Closed NRC Description of issue DOC LA4 l

CTS 4.6.1.7.1 Bases JFD P7 1

STS SR 3.6.3.1 and associated Bases '

CTS 3.6.1.7.a ITS SR 3.1.3.1 and associated Bases I

CTS 3.6.1.7 and CTS 4.6.1.7.1 are speci6c in how the 48 inch purge vahes are to be assured of not inadvertently opening:

each purge valve is required to have the power removed. STS/ITS SR 3.6.3.1 requires that these valves be sealed closed.

The Bases for STE SR 3.6.3.1 states that a purge valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve  !

operator. The Bases for ITS SR 3.6.3.1 deletes the phrase " removing the air supply to the valve operator" and replaces it l with " installing a mechanical block." Bases JFD P7 justifies this change on plant specific design, analysis, and terminology details. Since the CTS only talks about power removal, not installation of mechanical block, thisjustification is insufficient.

Finally, thejustifications given by DOC LA4 and Bases JFD P7 do not specify whether the staff has approved using l mechanical blocks as an alternative to power removal. Comment: Delete the ITS Bases change and conform to the CTS or i STS, or provide additional discussion and justification to show that using mechanical blocks has been approved by the staff.

Comed Response to issue No change. The option ofinstalling a mechanical block as a means of removing motive power to the valve operator of a containment purge valve that is sealed closed is discussed in the Byron /Braidwood UFSAR Section 6.2.4," Containment isolation System," and states, "The normal containment purge valves are locked closed by the administrative procedure of j g interrupting power to the valve at the circuit breaker (i.e., the circuit breaker is racked out) and tagging the breaker "out of '

t V; service"(OOS). Inadvertent operation of the purge valves requires violation of procedures prohibiting both the operation of tagged-out equipment and the containment purge system. Tagging out at the breaker is considered equivalent to a l mechanical lock because in both instances positive action is used to prevent the valve from receiving power and an administrative procedure is required to return the breaker to service. At Braidwood, valves VQ001 A/B and VQ002A/B may have exterior mechanical stops mounted to the valve. These valve stops may be used as an additional method oflocking the valves closed." In addition, the Bases for CTS Specification 3/4.6.1,7 states, "To provide assurance that the 48-inch containment valves ca' mot be inadvertently opened, the valves are sealed closed in accordance with Standard Review Plan 6.2.4 which includes mechanical devices to seal or lock the valve closed, or prevents power from being supplied to C e valve operator." This page of the Bases is an original page of CTS approved by the Staff when issuing the Byron and h aidwood operating licenses. Comed continues to pursue this change. l l

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Rtsponse to NRC RAI For ITS Section 3.6 16-Sep-98 NRC RAI Number NRC issued Date RAI Status

[\ 3.6.3-06 11/5'97 Closed

- NRC Description of issue DOC LAl8 ITS SR 3.6.3.1 CTS 1.7.a ITS SR 3.6.3.2 CTS 3.6.1.1.a

- ITS SR 3.6.3.3

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CTS 3.6.1.7 ITS SR 3.6.3.4 CTS 4.6. l .7.1 CTS 4.6.1.7.2 CTS 1.7.a has been moved to Bases Background discussion ofITS 3.6.1 according to DOC LA18. While it is acceptable to relocate CTS 1.7 to the Bases, CTS 1.7.a also refers to the requirements of CTS 34.1.1.a, CTS 3.6.1.7, CTS 4.6. l.7.1 and CTS 4.6.1.7.2 which translates to ITS SR 3.6.3.1, SR 3.6.3.2, SR 3.6.3.3, and SR 3.6.3.4. Thus the markup of CTS 1.7 should also be included in the CTS markup ofITS 3.6.3. Comment: Provide the appropriate markup of CTS 1.7 in the ITS 3.6.3 CTS markup. Provide additional discussion andjustification for this administrative change.

Comed Response to Issue 9/17/98 Revised Response. The CTS Markup pages have been revised based on discussions with the ITS Section 3.6 NRC Reviewer. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: No change. This presentation conforms to the standard for ITS submittals. See Comed Response to RAls 3.6.1-06 and 3.6.2-06. (See RAls 3.6.1-06 (1,7.d),3.6.1-08 (1.7.e), and 3.6.2-06 (1.7.c).)

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R sponse to NRC RAI For ITS Section 3.6 is-sep 98 NRC RAI Number NRC issued Date RAI Status

(] 3.6.3-07 11/5'97 Closed NRC Description of Issue DOC L12 STS SR 3.6.3.5 and associated Bases JFD C6 ITS SR 3.6.3.5 and associated Bases Bases JFD C6 Bases discussion of LCO for ITS 3.6.3 CTS 4.6.3.3 CTS 4.6.3.3 requires the isolation time of each power operated or automatic containment isolation valve be determined to be within limits. STS SR 3.6.3.5 states basically the same thing but the "or" i.; changed to "and" STS SR 3.6.3.5 has been modified by TSTF 46 Rev. I which clarifies that the SR only applies to automatic power operated valves. ITS SR 3.6.3.5 and the Bases discussions of LCO for ITS 3.6.3 and ITS SR 3.6.3.5 have been modified to reflect TSTF 46 Rev. O, as justified by DOC L12. Since TSTF 46 Rev. 0 was modified by the staff and resubmitted and approved as TSTF 46 Rev.1, the changes proposed in the ITS differ from the STS, as revised. Comment: Change the CTS markup, ITS SR markup and ITS Bases markup to conform to the approved TSTF 46 Rev.1 or provide additional discussion and justification for the deviations.

Comed Response to issue 9/17/98 Revised Response: Bases INSERTS 3.6-34 A/35B/36A have been revised to include the sentences, " Automatic valves refer to those valves that require a motive force to actuate, such as air or electric, and receive an automatic actuation signal. Power operated valves require a motive force to actuate, such as air or electric, but do not receive an automatic actuation signal." This change is provided in our comprehensive ITS Section 3.6 closeout submittal Revision J.

Original Response: TSTF-46, Revision 0, has been withdrawn from the ITS submittal. Comed, however, continues to (n) pursue this change on a plant specific basis for the following reesons. The references to " manual," " remote-manual,"

" power-operated," " check," and " automatic" is not consistent within the STS. Byron /Braidwood plant specific terminology l distinguishes between the classification of valves designated as " power operated" and " automatic " Automatic valves refer to those valves that require a motive force to actuate, such as air or electric, and receive an automatic actuation signal. I Automatic air operated valves and automatic electric operated valves fall into this category. Power operated valves, on the I other hand, require a motive force to actuate, such as air or electric, but do not receive an automatic actuation signal. Air l power operated valves and electric power operated valves fall into this category. Adopting the change to SR 3.6.3.5 in  ;

TSTF-46, Revision 1, which states, " Verify the isolation time of each automatic power operated containment isolation valve j is within limits" would inappropriately include power operated containment isolation valves (i.e., valves that do not receive a I containment isolation signal), which is not the intent. Therefore, deleting reference to power operated isolation valve time l testing reduces the potential for misinterpreting the requirements of this SR while maintaining the assumptions of the I accident analysis, and is consistent with plant specific terminology. (See RAI 3.4.14-04.)

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i 1

1 Response to NRC RAI For ITS Section 3.6 16-sep-98 NRC RAI Number NRC lssued Date RAI Status

[] 3.6.3-08 11/5/97 Closed l NRC Description ofIssue JFD B3 Bues JFD B3 i Bases JFD Pl3 l STS 3.6.3 Action E l STS SR 3.6.3.1 and associated Bases discussions ITS 3.6.3 Action D ITS SR 3.6..' I and associated Bases discussions STS 3.6.3 RA E.1, E.2 and E.3 have been revised in ITS 3.6.3 ACTION D to delete the option ofisolating a penetration flow l path with a purge valve not within the leakage limits and associated ras. The only option is the current licensing basis of l restoring the valve to OPERABLE status in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or begin an orderly plant shutdown. Also, the STS SR 3.6.3.1 exception for opening one purge valves while in Condition E is deleted. Justification B.3 Bases B.3 and Bases P.13 state this exception is already accommodated in Condition A Required Actions. This is not understood because if a purge valve is

, leaking, then Condition A cannot be entered. Thejustification must be further explained. Comment: Provide additional l l discussion and justification for this CTS change.

Comed Response to issue l " Condition A" has been changed to " Condition D" in Section 3.6 LCO JFD B3 and Bases JFD B3. The JFDs have been l revised to state,"This exception is adequately addressed by Condition D Required Actions, without the necessity for the

!= complexity introduced by this exception." The exception in SR 3.6.3.1 is unnecessary since SRs do not have to be 1 perfnrmed on inoperable equipment or components, i.e., when Condition D is entered.

NRC RAI Number ' NRC issued Date RAI Status 3.6.3-09 11/5/97 Closed NRC Description of Issue JFD-Pl i Bases JFD P20 Bases P22 Bases P24 STS 3.6.3 Required Action A.2 Completion Time

! STS SR 3.6.3.4 and associated Bases ITS 3.6.3 Required Action A.2 Completion Time l 1

ITS SR 3.6.3.4 and associated Bases STS 3.6.3 Required Action A.2 Completion Time and STS SR 3.6.3.4 Frequency state the following: " Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days.. " ITS 3.6.3 Required Action A.2 Completion Time and ITS SR 3.6.3.4 Frequency, add the word "once" to the Completion Time and Frequency to change the STS wording to:

" Prior to entering MODE 4 from MODE 5 if not performed once within the previous 92 days.. " The staff considers this to be a generic change which is beyond the scope of review for this conversion. Comment: Revise the submittal to adopt the STS wording.

Comed Response to issue 1 I

9/17/98 Revised Response: The ITS submittal has been revised to conform to the STS wording. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: Per Comed response to RAI 3.1-01, Comed submitted a traveler at the November 1997 Westinghouse Owner's Group (WOG) ITS meeting. The Staffs comment in RAI 3.1-01 for SR 3.1.6.1 was that this change was e i l

legitimate use of the word "once" in an SR Frequency. A final disposition of the traveler is to be determined at the February 1998 WOG ITS meeting. (See RAls 3.1-01,3.1.6-04,3.4.14-09,3.4.16-05, and 3.4.18-03.) j O

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l Response to NRC RAI For ITS Sedion 3.6 16-sen-98 NRC RAI Number NRC lssued Date RAI Status 3.63-10 11/5/97 Closed NRC Description of issue Bases JFD C4 Bases for STS 3.63 Bases for ITS 3.6.3 STS 3.6.3 Required Action C.1 Completion Time has been modified by TSTF-30 Rev. 2. While ITS 3.6.3 Required Action C,1 Completion Time incorporates TSTF-30 Rev. 2 changes, the Bases for ITS 3.6.3 does not fully incorporate all of the STS Bases changes associated with TSTF-30 Rev. 2. Comment: Revise the Bases for ITS 3.6.3 to incorporate the Bases ,

changes associated with TSTF-30 Rev. 2 or provide additional discussion and justification for the deviations. '

, Comed Response to issue 9/17/98 Revised Response: Same as Original Response, except that Ref. 5 was changed to Ref. 4. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

1 Original Response: Bases JFD C4 designator was added to ITS SR 3.6.3.6 for "(Ref. 5)" in the Surveillance Requirements l Section of the Bases for ITS LCO 3.63. In addition, Bases JFD C4 was revised to read,

_ ._ 1_ _

NRC RAI Number NRC Issued Date RAI Status 3.6.3 11 11/5/97 Closed NRC Description of Issue Bases JFD C5 Bases for STS SR 3.6.3.3 and SR 3.6.3.4 f' Bases for ITS SR 3.633 and SR 3.6.3.4 N.

STS SR 3.6.3.3 and SR 3.6.3.4 have been modified by TSTF 45 Rev.1. While ITS SR 3.6.3.3 and SR 3.6.3.4 have incorporated the changes associated with TSTF 45 Rev.1, the Bases for STS SR 3.633 and SR 3.63.4 do not fully incorporate all of the Bases changes associated with TSTF 45 Rev.1. Comment: Revise the Bases for STS SR 3.633 and SR 3.63.4 to incorporate the Bases changes associated with TSTF 45 Rev. I or provide additional discussion and justification for the deviations.

Comed Response to issue TSTF-45, Revision 1, added an Insert in the Surveillance Requirements Section of the Bases for ITS LCO 3.63 stating, "This SR does not apply to valves that are locked, scaled, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, sealing, or securing." TSTF-45. Revision I, was incorporated by adding the Insert to the Bases for SR 3.6.33 and SR 3.63.4.

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e Response to NRC RAI For ITS Section 3.6 16-sen-98 NRC RAI Number NRC Issued Date RAI Status 3.6.3-12 11/5/97 Closed b ) NRC Description of issue Bases JFD P8 Bases discussion of LCO for STS 3.6.3 Bases discussion of LCO for ITS 3.6.3 s The third paragraph of the Bases discussion of LCO for STS 3.6.3 states "The normally closed isolation valves... are those listed m Reference 1." This paragraph deals with those containment isolation vahes that are required to be closed during an accident and are in the closed position during normal operation. This paragraph is omitted from the Bases discussion of LCO for ITS 3.6.3 and the STS Bases markup indicates this omission isjustined by Bases JFD P8 which does not address this subject. Bases JFD P8 also states there is no requirement for an isolation valve's Operability to be tied to the integrity of a closed system. This is incorrect.10 CFR 50 Appendix A GDC 55 through 57, and the definition of Containment Integrity (CTS 1.7.a) tie the Operability ofisolation valves to the integrity of a closed system. Therefore, the STS wording is correct and should be retained. In addition, the staff 6nds this change to be generic and beyond the scope of review for this conversion. Comment: Delete this generic change.

Comed Response to Issue 9/17/98 Elevised Res,nonse: The STS paragraph in the LCO Section of the Bases fsr ITS LCO 3.6.3 has been retained. This change is provided in aur comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: No change. The LCO Section of the Bases for STS LCO 3.6.3 states, "The normally closed isolation valves are considered OPERABLE when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind flanges are in place, and closed systems are in act. These pessive isolation valves / devices are those listed in Reference 1." This paragraph was deleted by Bases JFD P8 since there is no requirement in ITS for a normally closed automatic valve to be de-activated and secured in its closed position. Implementing this requirement. would in fact, render the Emergency Core Cooling System inoperable. Additionally,10 CFR 50 Appendix A GDC 55-57 require that each b line that . . shall be provided with containment isolation valve (s) . , The converse is not true - There is no requirement tying U an isolation valve's operability to the integrity of a closed sy stem. Furthermore, CTS Dennition 1.7.a specines operability requirements for containment INTEGRITY, not containment isolation valves (CIVs). ITS LCO 3.6.3 which addresses tFe operability of CIVs does not specify any requirements for the integrity of closed systems. Comed continues to pursue this change.

4 24

Resp:nse to NRC RAI For ITS Section 3.6 16-Sep 98 NRC RAI Number NRC lssued Date RAI Status 3.6.3 13 11/5/97 Closed NRC Description of Issue Bases JFD P12 Bases discussion of Applicable Safety Analyses for STS 3.6.3 Bases discussion of Applicable Safety Analyses for ITS 3.6.3 The Bases for ITS 3.6.3 does not adopt the last sentence of the first paragraph of the Bases discussion of Applicable Safety Analyses for STS 3.6.3. This sentence states "Therefore, the safety analyses of any event requiring isolation of containment is applicable to this LCO." Bases JFD P12 bases this omission on :he the fact that ITS 3.6.3 Applicability is limited to Modes 1,2,3, and 4, and that ITS 3.9.4 addresses containment isolation requirements outside these modes. (Note. this is clearly stated in the Bases discussion of Applicability.) The omitted sentence appears to assume that the analyses referenced are only applicable during Modes 1,2,3, or 4 in the ITS which may not be true. The staff considers this omission to be a generic difference from the STS and outside the scope of an ITS conversion. Comment: Revise the submittal to adopt the omitted sentence.

Comed Response to issue 9/17/98 Revised Response: Same as Original Response, except that the omitted sentence was adopted in the Applicable Safety Analyses Section of the Bases for ITS LCO 3.6.3, not the Background Section. This change is provided in our comprehensive ITS Section 3.6 closcout submittal Revision J.

Original Response: The omitted sentence was adopted in the Background Section of the Bases for ITS LCO 3.6.3, and Bases JFD P12 was deleted.

NRC RAI Number NRC Issued Date RAI Status 3.6.3-14 11/5/97 Closed NRC Description of Issue Bases JFD P20 Bases JFD P24 Bases for STS 3.6.3 Required Action B.1 Bases for ITS 3.6.3 Required Action B.1 The Bases for ITS 3.6.3 Required Action B.1 differs from the STS as discussed in Bases JFDs P20 and P24. These modifications incorporate portions of TSTF 145, as well as other changes. The staff has accepted TSTF-145 Rev. I as modified by staff comments. Comment: Revise the Bases to adopt STS Bases changes of TSTF-145 Rev. I as supplemented by staff comments or provide additional discussion and justification for deviations.

Comed Response to issue Subsequent to the NRC Staff approving TSTF-145, Revision I, the industry withdrew the traveler at the 10/l/97 NRC/TSTF meeting. NUREG LCO 3.6.3 Condition A, for one containment isolation valve inoperable, requires verification that the affected penetration flow path is isolated once per 31 days for isolation devices outside containment and prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment. The traveler proposed adding this requirement to Condition B for two containment isolation valves inoperable. This is an inappropriate charge since whenever Condition B is entered for two valves inoperable, Condition A will always be entered for one valve inoperable. Duplicating requirements in Conditions is not consistent with NUREG philosophy. Comed did not adopt TSTF-145, Revision 1, and continues to pursue the Bases changes plant specifically.

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Response to NRC RAI For ITS Section 3.6 16-sep-98 l NRC RAI Number NRC Issued Date RAI Status

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3.6.6-01 11/5/97 Closed D' NRC Description of issue DOC AIS j DOC LIi 1 CTS 4.6.2.1.c.)  ;

ITS SR 3.6.6.5 l l

Comment: See Comment 3.6.3-02 l

Comed Response to issue CTS SR 4.6.2.1.c.1, SR 4.6.2.2.c, and SR 4.6.3.2 have been revised to add the phrase, "that is not locked, sealed. or otherwise secured in position." The CTS markups for these SRs have been revised to designate them as 'less restrictive'. ,

Therefoge, all'A18' designators have been replaced by 'Li l' designators, and Section 3.6 DOC AI8 was deleted. (See RAls 3.6.3-02 and 3.6.7-01.)

)

I NRC RAI Number NRC Issued Date RAI Status j 3.6.6-02 1I/5/97 Closed NRC Description of Issue DOC LA7 CTS 4.6.2.1.b Bases for ITS SR 3.6.6.4 The markup of CTS 4.6.2.1.b shows that the system alignment ("that on recirculation flow") for the containment spray pump test has been removed from CTS. DOC LA7 states that this system alignment detail is relocated to the TRM. However, the A Bases for ITS SR 3.6.6.4 describes the system alignment as "They [ pumps) are tested en recirculation flow." Comment:

Revise DOC LA7 to show that the test flow path has also been relocated to the Bases for ITS SR 3.6.6.4.

Comed Response to issue )

Section 3.6 DOC LA7 has been revised to read, " CTS SR 4.6.2.1.b details the required developed head for the containment l spray pump and test flow path during performance of the Surveillance. Thesc ietails are to b relocated to the Bases. These details are not necessary to ensure the Operability of the containment spray pumps. The requirements ofITS LCO 3.6.6. i

" Containment Spray and Cooling Systems," and associated SRs are adequate to ensure the containment spray pumps are  !

Operable. As such, these details are not required to be in the TS to provide adequate protection of the public health and safety. Relocating these details to the Bases maintains the consistency with NUREG 1431. Any change to these details will be made in accordance with the Bases Control Program described in ITS Section 5.5."

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1 Response to NRC RAI For ITS Stetion 3.6 issep.98 NRC RAI Number NRC issued Date RAI Status

( 3.6.6-03 11/5/97 Closed 1

\ l

% NRC Description of issue '

DOC L8 CTS 3.6.2.3 Actions

)

JFD P3 STS 3.6.6 Actions A and C and associated Bases Bases JFD P3 l ITS 3.6.6 Actions A and C and associated Bases CTS 3.6.2.1 Action Consistent with CTS, ITS 3.6.6 Regt.. red Actions A.] and C.1 specify a 7-day Completion Time, instead of the 72-hour Completion Time of the STS, in the event of one inoperable containment spray train or one or more inoperable containment  ;

cooling trains, respectively. The ITS also specifies a 14-day Completion Time measured from discovery of failure to meet 1 the LCO, instead of the 14-day Completion Time of the STS. While the Completion Time change from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days is )

acceptable based on current licensing basis, the change from 10 to 14 days is unacceptable. The justi6 cations provided (L.8. I P.3 and Bases P 3) are inadequate, and are not based on current licensing basis. Thus, the staff considers the change to be a generic change that is beyond the scope of review for this conversion. Comment: Delete this generic change.

Comed Response to issue No change. ITS LCO 3.6.6 requires that with one containment spray (CS) train inoperable or with one or more containment cooling trains inoperable, restore CS train to operable status in 7 days AND 14 days from discovery of failure to meet the LCO. ITS LCO 3.8.1 requires that with one or more buses with one required quali0ed circuit inoperable, restore required qualified circuit (s) to operable status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AND 6 days from discovery of failure to meet the LCO. The purpos.: of the second Completion Time (i.e., . days from discovery ...) is to prevent altemating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. In the case of CS and Containment Cooling, Comed has conformed to the NUREG philosophy of allowing alternating only once between a CS train fn' inoperability (7 day Required Action) and one or more Containment Cooling train inoperabilities (7 day Required Action).

This results in a 14 day Completion Time, rather than the STS 10 day Completion Time. Comed believes that this change is justi6able based on NUREG philosophy and continues to pursue this change.

NRC RAI Number NRC Issued Date RAI Status 3.6.7-01 11/5/97 Closed l

NRC Description of Issue DOC A18 l DOC Lil CTS 4.6.2.2.c ITS SR 3.6.7.4 Comment: See Comment 3.6.3-02 Comed Response to issue CTS SR 4.6.2.1.c.l. SR 4.6.2.2.c, and SR 4.6.3.2 have been revised to add the phrase, "that is not locked, sealed, or otherwise secured in position." The CTS markups for these SRs have been revised to designate them as 'less restrictive'.

Therefore, all'A18' designators have been replaced by 'L1l' designators, and Section 3.6 DOC A18 was deleted. (See RAls 3.6.3-02 and 3.6.6-01.) (Correction Note: This RAI was labeled 3.7.7-01 instead of 3.6.7-01.)

O 27

Response to NRC RAI For ITS Section 3.6 16-sep-98 l

NRC RAI Number NRC issued Date RAI Status I 3.6.7-02 11/5/97 Closed NRC Descriphon of Issue )

Bases JFD P7 i i

Bases Background discussion for STS 3.6.7 Bases Background discussion for ITS 3.6.7 Bases for ITS SR 3.6.7.5 The last sentence of the third paragraph in the Bases Background discussion for STS 3.6.7 states "The eductors are designed to ensure that the ph of the spray mixture is between 8.5 and 11.0." The Bases Background discussion for ITS 3.6.7 omits this sentence. Bases JFD P7 provides no technical basis for this change. Note that the Bases for ITS SR 3.6.7.5 basically makes the same statement, but without the limits. The omitted Background statement is necessary to describe the design characteristics of the spray additive system and thus is required. Comment: Revise the submittal to adopt the STS wording with the STS pH limits of 8.5 and 11.0 or specify the plant specine limits. Provide additional discussion andjusti6 cation as necessary.

Comed Response to issue The omitted sentence in the Background Section of the Bases for ITS LCO 3.6.7 was adopted with plant specific pH values and reads, "The eductors are designed to ensure that the pH of the spray mixture is between 8.5 and 12.8." (Correction Note: This RAI was labeled 3.7.7-02 instead of 3.6.7-02.)

NRC RAI Number NRC issued Date RAI Status 3.6.8-01 11/5/97 Closed ,

I NRC Description of issue .

DOC LA14

' f ITS SR 3.6.8.1 and associated Bases CTS 4.6.4.2.a ITS SR 3.6.8.2 and associated Bases l CTS 4.6.4.2.b l ITS SR 3.6.8.3 and associated Bases CTS 4.6.4.2.a and b speciGes surveillance requirements for hydrogen recombiner testing pertaining to (1) rate of heater l

sheath temperature increase and power consumption; (2) channel calibration of instrumentation and controls; (3) attributes of l a visual examination; and (4) required heater phase resistance. Accord;ng to DOC LAl4, details of these four surveillance requirements have been moved to either the Bases or the TRM. Items 1,3, and 4 have been relocated to the Bases. In addition, procedural details for determining power consumption (item 1) are moved to the TRM. DOC LA14 does not justify placing this requirement in the TRM, as opposed to the Bases. In addition, the channel calibration requirement, item 2, cannot be found in the Bases for ITS 3.6.8, as specified in DOC LAli. Comment: Revise the Bases for ITS 3.6.8 to include the channel calibration details as speciSed in the CTS 4.6.4.2.b.1 and DOC LA14. Provide additional discussion and justification for moving the channel calibration power consumption procedural details.

Comed Response to issue Section 3.6 DOC LA14 was revised to read. " CTS SR 4.6.4.2 details specinc acceptance criteria for hydrogen recombiner testing: 1) rate of heater sheath temperature increase and power consumption; 2) channel calibration ofinstrumentation and controls; 3) attributes of a visual examination; and 4) required heater phase resistance. Tne rate of heater sheath temperature increase and power consumption, the attributes of the visual inspection, and the required heater phase resistance details are relocated to the ITS Bases. The channel calibration ofinstrumentation and controls is relocated to the TRM. These details

{ are not necessary to ensure the Operability of the Hydrogen Recombiner Systems. The requirements ofITS LCO 3.6.8, Hydrogen Recombiners," and associated SRs are adequate to ensure the Hydrogen Recombiner Systems are Operable. As

{ such, these details are not required to.be in the TS to provide adequate protection of the public health and safety. The relocation of these details maintains the consistency with NUREG-1431. Any change to these details in the Bases will be A made in accordance with the Bases Control Program described in ITS Section 5.5. Any change to these details in the TRM ,

i 1- will be made in accordance with 10 CFR 50.59."

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o r Response to NRC RAI For ITS Section 3.6 16-sen-98  !

NRC RAI Number NRC issued Date R M Status  ;

3.6.8-02 11/5/97 Clos 1 ,

NRC Description of issue DOC L9  !

JFD Bl  !

Bases JFD B1 Bases JFD B2 Bases JFD P7 CTS 3.6.4.2 Action l ITS 3.6.8 Action B Bases for ITS 3.6.8 Required Actions B.1, B.2, and C.]

CTS 3.6.4.2 Actions do not address the condition in which both hydrogen recombiners are inoperable. Thus, CTS would require a plant shutdown in accordance with CTS 3.0.3. ITS 3.6.8 Action B allows 7 days of operation in this condition, i

provided the hydrogen control function is maintained. Thejustification given in DOC L9 for this relaxetion is unacceptable because there is no evidence that the four alternate hydrogen control functions, listed in the proposed Bases for ITS 3.6.8 Actions, have been previously accepted by the staff. In addition, how does one perform a surveillance on natural convection to verify that it is Operable as an alternate hydrogen control function. Also, containment spray does not reduce or facilitate hydrogen gas concentration. If Comed cannot reference documentation showing that the NRC staff accepted these alternate i hydrogen control functions, then ITS 3.6.8 Action B cannot be used. Therefore, the CTS requirement for an LCO 3.0.3 shutdown should be retained. Comment: Provide additional discussion and justiGcation for this less restrictive change. See Comment 3.6-02.

Comed Response to issue The fact that the Containment Spray System and the Reactor Containment Fan Coolers (RCFCs) provide an alternate hydrogen control function is discussed in the Byron /Braidwood UFSAR Section 6.2.5.2.3, " Hydrogen Mixing System l Design," and states, "The function of the mixing subsystem is to ensure that local concentrations with greater than 4%

hydrogen cannot occur within the primary containment following a LOCA. The mixing is achieved by natural convection processes, containment fan cooler operation, and the containment spray system. Natural convection occurs as a result of the temperature difference between the bulk gas space in the vessel and the containment wall. The natural convection action is enhanced by the momentum of steam emitted from the point of the break. The operation of the containment spray system following the accident will result in the creation of an extremely turbulent atmosphere w 6 thin the containment as demonstrated in the Zion Station full-flow containment spray system test. The conwnment spray system is discussed in Subsection 6.5.2. Mixing of the containment atmosphere to assure that there will be no " pocketing" oflarge hydrogen concentrations will be accomplished by the reactor containment fan coolers (RCFC). Ato engineered safety feature described in Subsection 6.2.2. The operation of the recombiner system is not dependent on the operation of any engineered safety features other than the reactor containment fan coolers. Four coolers (two required for both normal and postaccident conditions) each supplying 94,000 cfm (normal operation) or 59,000 cfm (postaccident operation) are provided for each containment. The RCFC fans discharge this air through concrete ducts to the lower elevation." For completeness, the Background Section of the Bases for ITS LCO 3.6.6, Containment Spray and Cooling Systems," was revised to add the  !

sentence, "In addition, the Containment Spray System and Containment Cooling System provide an altemate hydrogen )

control function to the hydrogen recombiners during post-LOCA conditions." The fact that the Post-LOCA Purge System )

provides an alternate hydrogen control function is discussed in the Byron /Braidwood UFSAR Section 9.4.9.3.1.a.1, " Post- )

LOCA Purge System Safety Design Bases," and states "The post-LOCA purge system is a non-safety-related system (per Branch Technical Position CSB 6-2) which is provided as a backup to the hydrogen recombiners to purge the containment of hydrogen to maintain the hydrogen concentration below 4% by volume." Comed continues to pursue this change. (See RAI )

3.6-02.)

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Response to NRC RAI For ITS Section 3.6 16-sen-98 NRC RAI Number NRC issued Date RAI Status O

Q 3.6.8-03 11/5/97 Closed NRC Description of issue Bases JFD P7 Bases Backgound discussion ofITS 3.6.8 in the Bases Background discussion ofITS 3.6.8, the third paragraph states that two 100% capacity independent hydrogen recombiners are shared between the units; however, Bases JFD P7 does not explain how ITS LCO 3.6.8 affects each unit's operation, if these hydrogen recombiners are in use for one Unit or inoperable, what is the operational status of the second Unit? Is it shutdown? The ITS APPLICABILITY, ACTIONS and/or Bases should explain this restriction. If not, an explanation of how ITS 3.6.8 OPERABILITY requirements for the unaffected Unit are met when the recombiners are dedicated to the afTected unit or are inoperable. Comment: Revise the submittal and provide the additional discussion.and justification for this plant specific design.

Comed Response to issue 9/17/98 Revised Response: ITS LCO 3.0.8 and ITS SR 3.0.5 were added to the submittal consistent with CTS LCO 3.0.5 and CTS SR 4.0.6 for the application of the single set of Technical Specifications to dual units (see Revised Response for RAI 3.0-01). This 0 nge was provided in our comprehensive ITS Section 3.0 closcout submittal Revision F.

Original Response: For Byron and Braidwood, the design basis does not postulate accidents on both units concurrently, but rather an accident on one unit and safe shutdown of the other unit. Therefore, the need for the hydrogen recombiners on the non-accident unit is not postulated in the design basis. However, if a recombiner were in use on one unit, it would still be  !

capable of being manually realigned to the other unit. The Bases for the Byron and Braidwood Current Technical Specifications (CTS) 3/4.6.4, " Combustible Gas Control " states, "The OPERABILITY of the equipment and systems required for the detection and control of hydrogen gas ensures that this equipment will be available to maintain the hydrogen concentration within containment below its flammable limit during post-LOCA conditions. EITHER RECOMBINER UNIT n (or the Purge System) is capable of controlling the expected hydrogen generation associated with: (1) zirconium-water

! i reactions, (2) radiolytic decomposition of water, and (3) corrosion of metals within containment. These Hydrogen Control V Systems are consistent with the recommendations of Regulatory Guide 1,7, " Control of Combustible Gas Concentrations in Containment Following a LOCA," March 1971. The Hydrogen Mixing Systems are provided to ensure adequate mixing of the containment atmosphere following a LOCA. This mixing action will prevent localized accumulations of hydrogen from exceeding the flammable limit." Comed belicus that this change is justifiable and continues to pursue this change.

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ATTACHMENT 2 ITS SECTION 3.6  ;

ITS AFFECTED PAGE LIST l I

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ATTACHMENT 2 ITS SECTION 3.6 ITS AFFECTED PAGE LIST SECTION/ TAB ITS AFFECTED PAGE RAI i 3.6 BYRON ITS 3.6.2-1 3.6.2-02 l 3.6 BRWD ITS 3.6.3-1 3.6.3-01, 3.6.3-03 3.6.3-2 3.6.3-09 3.6.3-4 -

3.6.3-5 -

3.6.3-6 3.6.3-09 B 3.6.1-2 3.6.1-08 l B 3.6.1-3 3.6.1-09 l B 3.6.1-5 3.6.1-09, 3.6.1-10 i B 3.6.1-6 -

B 3.6.2-2 3.6.1-09 B 3.6.2-5 3.6.2-10 B 3.6.2-7 3.6.2-10 B 3.6.2-8 3.6.2-10

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B 3.6.3-3 3.6.3-13 l B 3.6.3-4 -

B 3.6.3-5 3.6.3-01. 3.6.3-12 B 3.6.3-7 3.6.3-07 .

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B 3.6.3-10 3.6.3-07 B c.6.3-11 3.6.3-07 B 3.6.3-12 -

B 3.6.3-15 3.6.3-11 B 3.6.3-16 3.6.3-09. 3.6.3-11 B 3.6.3-17 -

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.O, ITS SECTION 3.6 ITS AFFECTED PAGE LIST SECTION/ TAB ITS AFFECTED PAGE RAI 3.6 ".nRON ITS B 3.6.6-1 3.6-02. 3.6.8-02

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ITS SECTION 3.6 CTS AMENDED PAGE LIST O

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ITS SECTION 3.6 ,

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3.6 BYRON CTS 3/4 6-1 #102 3/4 6-2 #102 3/4 6-3 #102 3/4 6-5 #97 l

3/4 6-8 #99 3/4 6-9 #99 3/4 6-10 #99 i

3/4 6-12 #97 3/4 6-21 #91 & #90 3/4 6-22 #91 & #90 I 3/4 6-23 #91 & #90 3/4 6-24 #91 & #90 3.6 BRWD CTS 3/4 6-3 #90 3/4 6-5 #88 3/4 6-8 #90 3/4 6-9 #90 3/4 6-10 #90 3/4 6-12 #88 l 3/4 6-21 #84 & #83 l 3/4 6-22 #84 & #83 .

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ITS SECTION 3.6 ,

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Table A - Administrative Changes to CTS Discussion Description ITS CTS of Change of Change Requiremmt Requirement ITS Section 3.6, Containment Systems 3.6 A1 Editorial rewording, reformatting, and renumbering changes were made to conform with 3.6 3/4.6,1.7 conventions used in Westinghouse Standard Technical Specifications NUREG-1431(STS).

3.6 A2 Containment Integrity war c.mved as a defined term and is now referred to as containment 3.6.1 3/4.6.1.1 Operability.

3.6 A3 The Spray Additive System does not contain any power operated valves and, therefore, SR 3.6.7.1 4.6.2.2.a reference to this type of valve was deleted.

3.6 A4 Explicit requirement to comply with another Specification was deleted in conformance with STS N/A 4 6.1.1.b I

format.

3.6 A5 The requirement to perform containment leakage rate testing in accordance with Regulatory SR 3.6.1.1, 4.6.1.1 c, Guide 1 163 September 1995 was changed to reference the Containment Leakage Rate Testing SR 3 6.2.1, 4.6.1.2, Program which contains the same requirement. 5.5.16 4 6.1.3 3.6 A6 Actions notes, an action, and surveillance notes were added consistent with STS to clarify CTS 3.6.2 Actions, 3.6.1.3 Actions, intent regarding containment air lock Operability requirements and containment entry and exit SR 3.6.2.1 4.6.1.3 controls.

(By)- Byron speofk:

(Bw)- Braidwood specific Byron and Braidwood A_TBL3 6 i

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0 D (v v (V Table A - Administrative Changes to CTS Discussion Description ITS CTS of Change of Change Requirement Requirement 3.6 A7 Explicit allowances were included for separate condition entry for each inoperable air lock and 3.6.2 Actions N/A containment isolation valve. Note 2, 3.6.3 Actions Note 2 3.6 A8 Clarification was provided for proper application of actions if both doors in an air lock are 3.6.2 Action N/A inoperable. Note 1 3.6 A9 Action to restore an inoperable air lock to Operable status was deleted since the option to LCO 3.0.2 3.6.1.3 restore inoperable components currently exists and does not need to be expl;citly stated. Action a 1 3.6 A10 The explicit requirement that an inoperable air lock door be repaired prior to the next overall air N/A 3 6.1.3  :

lock leakage test was deleted since the test cannot be successfully performed with an inoperable Action a.2 ,

door.

l 3.6 A11 Not used.

t 3.6 A12 Not used. ,

An exception for the 48 inch purge valves was included in the allowaace that containment 3.6.3 Actions 3/4.6 1.7 3.6 A13 isolation valves may be opened under administrative controls to clarify an inconsistency in CTS. Note 1 4.6.1.1.a (By) - Byron specific (Bw)- Braidwood specific Byron and Brardwood A_TBL3.6 2

_ _ . . . . _ _ . _ _ . _ _ . _ . _ _ . . . _ . _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ______________________I

(3 r~N O b, /"~}!

\,s Table A - Administrative Changes to CTS Discussion Description ITS CTS of Change of Change Requirement Requirement 3.6 A14 The explicit allowsnce that the provisions of Specification 3.0.4 are not applicable was deleted LCO 3.0.4 3.6.1.3 since STS Specification LCO 3 0.4 allows entry into the Modes of applicability when the actions Action a 4 allow continued operation for an unlimited period of time.

3.6 A15 The terms " purging" and " venting" are no longer used as defined terms in accordance with STS. SR 3.6.3.2 LCO 3 6.1.7.b.

1.24,1.40 3.6 A16 A list of specific methods for isolating a penetration was added pertaining to all penetration flow 3.6.3 Action A 3 6.1.7 paths with two containment isoiation valves. Actions a and b 3.6 A17 Not used.

3.6 A18 Not used.

3.6 A19 Requirements for containment cooling fans and the Containment Spray System were combined 3 6.6 Action C 3.6.3.2 and reformatted such that explicit verification of containment spray Operability is unnecessary. Actions a and b 3.6 A20 The action to maintain at least one isolation valve Operable in each affected penetration that is 3.6.3 Action A 3.6.3 Action a ,

open is addressed in STS format by separate actions for penetrations designed with one and two isolation valves.

(By) - Byron specific '

(Bw)- Braidwood specific Byron and Braidwood A_TBL3 6 3

O O O Table A - Administrative Changes to CTS Discussion Description ITS . CTS of Change of Change Requirement Requirement 3.6 A21 Action to restore inoperable containment isolation valve (s) to Operable status was deleted since LCO 3.0.2 3.6 3 Action a.1 the option to restore inoperable components currently exists and does not need to be explicitly stated.

3.6 A22 Not used.

3.6 A23 Reference to Specification 4.0.5 for performing surveillances on pumps and valves was changed SR 3.6.6.4, 4.6.2.1.b.

to reference the equivalent inservice Testing Program. SR 3.6.3.5 4.6.3.3 3.6 A24 The explicit allowance that the provisions of Specification 3.0.4 are not applicable povided the LCO 3.0.4 3 6.3 Action b affected penetration is isolated was deleted as redundant to the provisions of STS Specification LCO 3.0.4.

3.6 A25 Explicit allowance ves included to use remote manual valves to isolate a penetration. 3.6.3 Action A 3 6.3 Action a 2 3.6 A26 Requirement to enter LCO 3.0.3 was explicitly included for certain conditions of containment 3.6.6 Action E Specification spray and/or containment cooling inoperability. 3.0.3 3.6 A27 Frequency for demonstrating each Hydrogen Recombiner System Operable was changed from SR 3.6.8.1 4 6.4.2.a "each refueling outage" to the equivalent "18 months."

3.6 A28 Leakage rate acceptance criteria were removed to the Containment Leakage Rate Testing 5.5.16 3.61.2 Actions Program.

(By) - Byron specific (Bw)- Braidwood specific Byron and Braidwood A_TBL3 6 4

- - - _ - _ _ - _ _ - _ _ _ _ _ _ _ - _ - _ _ _ . _ _ _ _ _ - . - - - - _ _ _ - _ _ _ _ _ - - - - _ - - _ _ = _ _ _ - - . _ _ _ _ - - _ _ - _ _ _ - - _ _ _ _ _ -

O O O Table A - Administrative Changes to CTS s

Discussion Description ITS CTS of Change of Change Requirement Requirement 3.6 A29 The requirement to enter another LCO when isolation valve leakage results exceed overall 3.6.3 Actions N/A containment leakage rate acceptance criteria to prevent misapplication of LCO 3.0.6. Note 4 3.6 A30 Notes were included to clarify which actions apply to inoperable containment isolation valves 3.6.3 Actions N/A depending on the number of valves in the penetration. A, B, and C 3.6 A31 With containment leakage rates not within limits, the explicit action to restrict Reactor Coolant 1 E. I Action B, 3.6.1.2 Actions, I System heatup to below 200*F was deleted since default actions are comparable. SR 3.0.1 3.0.3 3.6 A32 Cross reference to a Specification limiting containment leakage rates was deleted. N/A 1.7.d l

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Table R - Relocated CTS Discussion Relocated Description of New Control of Change CTS Relocated CTS Location Process CTS Section 3!4.6, Containment Systems .

I None  !

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Byron and Braidwood 1 R_TBL3.6  ;

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Table M - More Restrictive Changes to CTS Discussion Description ITS CTS of Change of Change Requirement Requirement ITS Section 3.6, Containment Systems 3.6 M1 Not used.

3.6 M2 The action to maintain at least one containment air lock door c'osed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was restricted 3.6.2 Actions 3.6.1.3 Actions to require the door be verified closed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. A 1 and C.2 a.1 and b 3.6 M3 Containment entry and exit when both air locks have an inoperable door was restricted from an 3.6.2 Action A N/A indefinite period to 7 days under administrative controls. , Note 2 (By) - Byron specific (Bw) - Braidwood specific Byron and Braidwood 1 M_TBL3 6

v bp. d(.

Table LA - Details Relocated from CTS Discussion CTS Description of New Control of Change Reference Relocated Details Location Process Type ITS Section 3.6, Containment Systems 3.6 LA1 4.6.1.1.a 3/4.6.3 Design information, such as penetration number, valve number, function, and Bases ITS 5.5.14 1 isolation time, for containment isolation valves.

3.6 LA2 LCO 3.6.1.6 a Operability requirement for air lock doors to De closed except for containment Bases ITS 5.5.14 2 entry and exit.

3.6 LA3 4.6.1.5 Details for determining containment average air temperature. Bases ITS 5.5.14 3 3.6 LA4 LCO 3.6.1.7.a. Details for complying with the requirement that the 48-inch purge valves cannot be Bases ITS 5.5.14 3 4.6.1.7.1 inadvertently opened.

3.6 LA5 Not used. t 3.6 LA6 LCO 3.6.2.1 Design information related to Containment Spray Systems Operability. Bases ITS 5.5.14 1 Discharge head and flow path for testing the containment spray pumps. Bases ITS 5.5.14 3 3.6 LA7 4.6.2.1.b 3.6 LAB 4.6.2.1.d Details of how to perform verification of unobstructed containment spray nozzles. Bases ITS 5.5.14 3 3.6 LA9 LCO 3.6.2.2.b Design information related to Spray Additive System Operability. Bases ITS 5.514 1 Details of how to perform verification of flow rate from spray additive tank. TRM 50.59 3 3.6 LA10 4.6.2.2.d 3.6 LA11 LCO 3.6.2.3 Design information related to containment cooling fans. Bases ITS 5.5.14 1 4 i

Relocated Detat! Types 1 Details of System Design 3 Procedural Details for Meeting TS Requirements 2 Desenption of System Operation (By) - Byron specific (Bw)- Braidwood specific ,

Byron and Braidwood 1 LA_TBL3 6

'N 0 0 0 Table LA - Details Relocated from CTS -

Discussion CTS Description of New Control of Change Reference Relocated Details Location Process Type 3.6 LA12 4.6.2.3.a.1 Details of how to perform verification that each containment fan system operates Bases ITS 5.5.14 3 in slow speed.

Details of how to perform verification that each containment fan system starts from TRM 550.59 3 the control room.

3.6 LA13 LCO 3.6.4.2 Design details related to Hydrogen Recombiner Systems Operability. Bases ITS 5.5.14 1 3.6 LA14 4.6.4.2.a. Details of how to demonstrate each Hydrogen Recombiner System is Operable, Bases ITS 5.514 3 4.6.4.2.b.2, specifically the rate of heater sheath temperature increase and power 4.6.4.2.b.3 consumption, the attributes of the visual inspection, and the required heater phase resistance.

4.6.4.2.b.1 Details of how to demonstrate each Hydrogen Recombiner System is Operable. TRM 50.59 3 specifically the channel calibration of instrumentation and controls.

3.6 LA15 4.6.3.1 Details of how to perform post maintenance testing of containment isolation TRM 550.59 3 valves.

3.6 LA16 4.6.1.7.3, Acceptance criteria for leakage rate testing of containment purge valves. TRM $50.59 3 4.6.1.7.4 3.6 LA17 3.6.1.7 Action a Details of how to isolate penetrations. Bases ITS 5.5.14 3 3.6 LA18 1.7 Details of containment penetration design which constitute Operability attributes. Bases ITS 5.5.14 1 Relocated Detail Types 1 Details of System Design 3 Procedural Details for Meeting TS Requirements 2 Desenption of System Operation (By)- Byron specific (Bw) - Braidwood specific .

Byron and Braidwood 2 LA_TBL3 6

- . _ _ _ - _ _ _ . _ _ .____--.______..__.-_______.m____________.___-_m_-____-..__._..-__-__-.- __ m____ _ . _ _ _ _ . . . _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _ - . .

m NJ Table L - Less Restrictive Changes to CTS Descussion Description ITS CTS Change of Change of Change Requirement Requirement Category ITS Section 3.6, Containment Systefr:s 3.6 L1 Not used.

3.6 L2 Not used.

3.6 13 Actions have been added to allow continued operation for the condition of an inoperable 3.6.2 Action B N/A 111 air lock door interlock mechanism. Actions parallel those for an inoperable air lock door except that containment entry and exit is controlled by a dedicated individual.

3.6 L4 The frequency for testing the air lock interlock was relaxed from at least once per 6 SR 3.6.2.2 4.6.1.3.c VI +

months to at least once per 24 months so that the interlock can be tested in a Mode when '

it is not required.

3.6 L5 The requirement to stagger the scheduling of purge valve leakage tests for the 48-inch SR 3.6.3.7 4.6.1.7.3 VI supply and exhaust penetrations was deleted consistent with STS.

3.6 L6 Surveillances to verify that each automatic valve actuates to its correct position and that SR 3.6.6.5, 4.6.2.1.c, V rach pump starts on a test signal was changed to allow actual as well as simulated SR 3.6.6.6, 4.6.2.2.c, i signals for actuation during operation as well as during shutdown. This allows credit for SR 3.6.7.4, 4 6.2.3 b.  !

the surveillance if a valid actuation occurs during operation or through post-maintenance SR 3.6.6.7, 4.6.3.2 testing that satisfies the surveillance. SR 3.6.3.8 3.6 L7 Not used.

l t

less Restrictive Change Categones I Relaxation of LCO requirements V Relaxation of SR acceptance enteria 11 Relaxat on of Applicability VI Relaxation of Surveillance Frequency 111 Relaxation of Action requirements Vil Deletion of requirements redt.ndant to regulation IV Relaxation of completon time Vill Deleton of Surveillance requirements (By) - Byron specific (Bw)- Braidwood specific Byron and Braidwood 1 L_TBL3 6

b b b V Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS Change of Change of Change Requirement Requirement . Category 3.6 L8 The containment spray and containment cooling fans Specifications have been combined 3.6.6 Actions 3.6.2.1 Actions, IV with separate restoration actions for each system to be completed within 7 days. To A and C 3.6.2.3 Actions prevent continued operation without meeting the LCO by alternating between the two actions, separate 14 day completion times measured from entry into the LCO were included to restore all inoperable trains. This change could result in as much as 7 additional days to complete all restoration activities.

36 L9 Action requirements were relaxed to a!!ow entry into the applicable Modes with one 3.6.8 Actions N/A til hydrogen recombiner inoperable. Also, to prevent unnecessary unit shutdowns, actions A ar.d B were included to address both hydrogen recombiners inoperable. The actions are to periodically verify that hydogen control is otherwise maintained and that one hydrogen recombiner is restored within 7 days.

3.6 L10 The list of acceptable isolation devices which may be used to isolate a penetration with an 3.6.3 Action A 3.6.3 Action a.3 111 inoperable isolation valve was revised to include check valves with flow through the valve secured to accommodate those penetrations designed with check valves for isolation.

The CTS exception that valves and blind flanges inside containment which are locked. SR 3.6.3.3, 4.6.1.1.a. V 3.6 L11 sealed, or othermse secured in their correct position to isolate a penetration need not be SR 3.6.3.4, 4.6.2.1.c.1, verified closed was similarly applied to isolation devices outside contairiment since SR 3.6.6.5. 4 6.2.2.c.

administrative coritrols provide a positive means of controlling their correct positions. SR 3.6.7.4, 4.6.3.2 SR 3.6.3.8 Less Restrictive Change Categones i Relaxation of LCO requirements V Relaxation of SR acceptance enteria 11 Relaxatton of Apphcabihty VI Relaxaton of Surveillance Frequency ill Relaxation of Action requirements VII Deletiori of requirements redundant to regulaten IV Relaxation of completion time Vlt1 Deletion of Surveillance requirements (By) - Byron specific (Bw) - Braidwood specific Byron and Braidwood 2 L_TBL3 6

( ,- ,,

k.) 'Y b Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS Change of Change of Change Requirement Requirement Category 3.6 L12 Power operated valves were removed as a type of valve for which isolation times must be SR 3.6.3.5 4.6.3.3 V verified. Isolation time implies receipt of an automatic isolation signr.: where power operated valves are remote manually operated.

3.6 L13 CTS implicitly requires immediate unit shutdown when both valves in a penetration are 3.6.3 Action B N/A IV inoperable. The completion time for isolating the affected penetration was relaxed to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by adding an action which addresses this condition, consistent with the time allowed for an inoperable containment.

3.6 L14 Actions were included to address penetrations which are designed with only one 3.6.3 Action C N/A IV containment isolation valve. The completion time for restoring /isolatM the affected penetration was relaxed from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> considering the der jn provisions associated with these closed systems.

3.6 L15 Notes were added to actions and surveillances requiring verification of containment 3.6.3 Actions 4.6.1.1.a 111. V isolation devices to allow the verification by use of administrative means when the devices A and C Note, are located in high radiation areas. This change reduces personnel exposure to radiation 3.6.2 Action A in areas with limited access. Note.

SR 3.6 3.3 Note SR 3.6.3 4 Note Less Restnctive Change Categones 1 Relaxation of LCO requirements V Relaxation of SR acceptance criteria Il Relaxation of Applicabihty Vi Relaxation of Surveillance Frequency til Relaxation of Action requirements Vil Deletion of requirements redundant to regulation IV Retaxation of completion tme Vill Deleuan of Surveiltance requirements (By) - Byron specific (Bw)- Braxfwood speofic Byron and Braidwood 3 L_TBL3 6

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Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS: Change of Change of Change Requirement Requirement Category 3.6 Li6 Notes were added to allow use of adrninistrative means to verify the affected penetration 3.6.3 Action 3.6.3 Ill flow path is isolated in high radiation areas and for isolation devices that are locked, C.2 Notes ,.

sealed, or otherwise secured.

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Less Restrictive Change Categories i Retaxation of LCO requirements V Relaxation of SR acceptance enteria li Relaxation of Applicability VI Relaxation of Surveillance Frequency til Retaxation of Action requirements Vil - Deletion of requirements redundant to regulation IV Relaxaton of completion'tane Vill Deletion of Surveillance requirements [

(By)- Byron speofic j (Bw)- Braidwood specific  !

Byron and Braidwood 4 L_TBL3 6 ,

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