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Forwards Rev L to Conversion to Improved Sts,Dtd 961213.Rev L Contains Util Final Package Closeout for Improved STS, Section 3.8.Affected Page List,Ser Tables & List of Byron & Braidwood CTS Pages That Have Been Amended,Encl
	ML20154A865
Person / Time
Site:	Byron, Braidwood
Issue date:	10/02/1998
From:	Tulon T; COMMONWEALTH EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
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ML20154A871	List: ML20154A865; ML20154A888;
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	NUDOCS 9810050028
	Download: ML20154A865 (49)
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Commonweahh 1:dimn Osmpany

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Braidwood Generating Station

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United States Nuclear Regtdatory Commission Attn: Document Control Desk Washington D. C. 20555 - 0001 1

Subject:

Revision L to the Improved Technical Speci6 cations (ITS) Submittal -

ITS Section 3.8 Closecut Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Numbers: 50-454 and 50-455 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 d,m NRC Docket Numberr: 50-456 and 50-457 1

Reference:

G. Stanley and K. Graesser (Commonwealth Edison) letter to NRC Document Control Desk, " Conversion to the Improved Standard Technical Speci6 cations," dated December 13, 996 The pu pose of this letter is to provide Revision L to the referenced ITS submittal. ITS Revision L contains Commonwealth Edison's (Comed's) Snal Package Closeout for ITS Section 3.8.

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Enclosure I contains ITS Revision L. Attachment I contains Comed's Gnal RAI Responses to Section 3.8. Any revised response is noted along with the original

,j response. Attachment 2 contains an ITS Affected Page List summarizing ITS pages that have changed in Revision L. Attachment 3 is a list of Byron and Braidwood CTS pages 7);[

that have been amended since December 13,1996, the original Revision A submittal date. contains the SER Tables for ITS Section 3.8.

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These Revisions are being provided in the same ten-section fennat as the initial ITS submittal:

.l. Byron ITS 2; Braidwood(Brwd)ITS

3. Byron CTS Markups

4. Brwd CTS Markups

5. CTS Discussion of Changes (DOCS)

6. LCO Markups

7. LCO Justification for Differences (JFDs)

8. Bases Markups

9. Bases JFDs

10. No Significant Hazards Consideration (NSilC)

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

.g Department.'

- (f Sincerely,

$ :s T' iothy J. Tulon

, ite Vice President Braidwood Nuclear Generating Station

? : ITS Revision L Attachments: Attachment 1 -ITS Section 3.8 RAI Revised Responses - ITS Section 3.8 ITS Affected Page List -ITS Section 3.8 CTS Amended Page List -ITS Section 3.8 SER Tables cc:

NRC Regional Administrator - Region Ill Senior Resident inspector - Braidwood l

Senior Resident Inspector-Byron f-q Ollice of Nuclear Facility Safety - IDNS

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ATTACHMENT 1 ITS SECTION 3.8 RAI REVISED RESPONSES l

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Responsa to NRC RAI Fcr ITS Section 3.8 17 Sep.98 NRC RAI Number NRC issued Date RAI Status l,q 3.8.1-01 4/29/98 Closed NRC Description ofIssue 3.8.1-1 DOC A2 The discussion in DOC A2 is not consistent with Insert 3.8-2D or with ITS 3.8.1 Condition G. Is the DOC or the LCO an the Insert correct?

l Comed Response to issue ITS 3.8.1 Condition G will be revised, consistent with the clean copy and LCO markup, to state, "Two DGs inoperable, and one or more buses with one or more required qualified circuits inoperable OR One DG inoperable. one bus with two required qualified circuits inoperable, and the second bus with one or more required qualified circuits inoperable." This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.

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NRC RAI Number NRC Issued Date RAI Status 3.8.1-07 4/29/98 Closed NRC Description of issue 3.8.1-2 JFD BP45 Insert B 3.8-15A is consistent with the ITS Bases discussion for ITS 3.8.1 Condition G. However, the inclusion of the two l(Q DG inoperable example is not helpful in explaining the condition because that example does not explain the level of j

equipment operability at which the Condition must be entered.

Comed Response to Issue No change required per discussions with ITS Section 3.8 Reviewer (Jim Luchman) during May 7,1998 meeting with Comed and NRC.

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Response to NRC RAI For ITS S:ction 3h 17-sep-98 NRC RAI Number NRC Issu ed Date RAI Status A

3.8.1-03 4uv/98 Closed NRC Description of Issue 3.8.13 DOC LA4 i

The DOC states "This change is required to properly reflect the manufacturer's current recommendation. " and "the manufacturer is inditTerent to the benefits of this type of start" What is the documented basis for these statements?

Comed Response to Issue As specified in ITS SR 3.8.1.2 Note 3, "A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR." The statements in question from DOC 3.8-LA4 were meant to address this type ofidle start. The manufacturer acknowledges the advantages of prelubed/ prewarmed starts, but is indifferent to the advantages of reduced speed (idle) starts, it is their contention that reduced fuel starts have the greatest value and reduced speed starts have minimal positive impact. To better clarify this, a portion of DOC 3.8-LA4 will be revised to state, ". It should be noted that the phrase " recommended by the manufacturer" has been deleted from the CTS footnote. This change is required to properly reflect the manufacturer's current recommendation for Cooper-Bessemer diesel generators, No specific recommendation has been provided concerning modified reduced speed starts. This change in the footnote is considered to be an editorial correction to properly characterize the basis far the modified starts.." This change will be provided in our comprehensive ITS Section 3.8 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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NRC RAI Number NRC Issued Date RAI Status 3.8.1-04 4/29/98 Closed j

NRC Description ofIssue O'

3.8.1-4 DOC L8 The discussion states ". and eliminating an upper voltage criteria. " What voltage criteria are eliminated?

Comed Response to issue CTS SR 4.8.1.1.2.f.2) requires the DG to reject the equivalent ofits single largest post-accident load with acceptance criteria of 4160 V plus or minus 420 V (3740 V - 4580 V) " transient" generator voltage. ITS SR 3.8.1.9 requires that, following load rejection, the " steady state" voltage be maintained 3950 V - 4580 V, but does not impose a transient voltage limit.

Therefore, the transient voltage criteria were climinated. For clarity, the last sentence in DOC 3.8-L8 will be revised to state, "Therefore, meeting the frequency acceptance criteiia and eliminating the transient voltage criteria continues to provide adequate testing of the DG response." This chang;e will be provided in our comprehensive ITS Section 3.8 closeout submittal revision upon NRC's ccncurrence with the Comed Responses to the ITS Section 3.8 RAI.

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R:spo:'se to NRC RAI For ITS S:ctisti

.8 175p-98 NRC RAI Number NRCIssued Date RAI Status

'.A 3.8.1-05 4/2')/98 Closed NRC Description ofIssue 3.8.1-5 DOC M11 The CTS markup (CTS 4.8.1.1.2.f.2 ) of the voltage values (-420, +210) results in values that are inconsistent with those in ITS 3.8.1.9.

Comed Response to Issue The Byron CTS markup for CTS SR 4.8.1.1.2.f.2 will be revised from -420/+210 to +420/-210. This change will be provided in our comprehensive ITS Section 3.8 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.

l NRC RAI Number NRC Issued Date RAI Status 2.8.1-06 4,29/98 Closed NRC Description ofIssue 3.8.1-6 Bases JFD P36 i

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The JFD does not appear to be applicable in the markup of the second paragraph of STS Bases page B 3.8-9.

Comed Response to Issue The Actions Section of the Bases for ITS LCO 3.8.1 will be revised to state, " Discovering one required DG inoperable s

comcident with one or more inoperable required redundant feature (s) results in starting the Completion Time for the Required Action. Four hours from..."

v in addition, Bases JFD 3.8-P36 will be revised to include the following discussion, "The Actions Section of the Bases for I

ITS LCO 3.8.1 was revised to be consistent with ITS LCO 3.8.1 Required Action B.2 and current plant design. Plant specific design consists of two AF pumps. 'A' train AF inclades a motor drivea AF pump that relies on the 'A' DG for emergency power. 'B' train AF includes a stand-alone diesel-driven AF pump that does not depend on the 'B' DG. In the l

event the 'A' DG were to be declared inoperable, not only would the redundant feature (s) associated with the OPERABLE l

DG (i.e., the 'B' DG) be required to be evaluated for OPERABILITY, but so would the independent 'B' AF pump. Further, in the event the 'A' DG and the 'B' AF pump were to be declared inoperable, both AF pumps would be declared inoperable, and the appropriate Conditions ofITS LCO 3.7.5 would be entered."

This change will be provided in our comprehensive ITS Section 3.8 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.

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Response to NRC RAI Fcr ITS Secti:n 3,8 17-Sep-98 NRC RAI Number NRC Issued Date RAI Status A

3.8.1-07 4/29/98 Closed f

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NRC Description of Issue 3.8.1-7 Bases JFD B1 and insert B 3.8-27A (Bases JFD P21)

The markup of the STS Bases for SR 3.8.1.3 eliminates the discussion of power factors (STS B 3.8-13) and substitutes a discussion of DG operation from 0 to 1000 kVars. Use of Bases JFD B1 is not appropriate and if Bases JFD B3 was intended, ajustification of the 0 to 1000 kVars range should be provided as it does not appear in the CTS. Likewise, while Bases JFD P21 makes the case for discontinuing testing at rated power factor, it fails to provide any technical basis for the guidance provided in Insert B 3.8-27A.

Comed Response to issue Bases JFD 3.8-B1 will be revised to Bases JFD 3.8-B3 for the Bases Markup for SR 3.8.1.3. In addition, a Bases 'P' JFD will be added for this change and will state, "As stated in the STS Bases for SR 3.8.1.3, there are no power factor requirements established by the SR. The substitution of operation between 0 and 1000 kVars in place of the power factor references is a plant specific limitation. This limitation ensures that in the event of a full load reject during testing, the

. sulting voltage transient will not exceed the vendor recommended maximum value of 5000 V. While operating outside the stated kVar band, a full load reject may result in a voltage transient that exceeds 5000 V." For this reason Bases JFD 3.8-P21 (ITS SR 3.8.1.14) states that testing at rated power factor has been determined to be unjustified, potentially destructive testing due to exceeding the vendor recommendation for maximum generator voltage.

In addition, the following will be added to Bases JFD 3.8-P21, "The guidance from insert B 3.8-27A ensures that the DG is 1

tested at its rated power factor for a brief time to verify the generator, regulator, and exciter can achieve their design ratings.

During testing, the DG is increased to rated power factor for a short period while at full load and then returned to <1000 kVars. This testing ensures the full functionality of the generator and voltage regulator / exciter and yet serves to minimize i

exposure to the risks associated with a full load reject at rated power factor."

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i These changes will be provided in our comprehensive ITS Section 3.8 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl. (See RAl 3.8.1-23.)

l NRC RAI Number NRC lssued Date RAI Status 3.8.1-08 4'29/98 Closed j

NRC Description of Issue 3.8.1-8 ITS 3.8.1 Changing of"offsite" circuit to " qualified" circuit appears to be a problem without the carryos er of the CTS qualification of "Each units System Auxiliary Transformer bank energized from an independent transmission circt it." The ITS LCO Bases state that a qualified circuit is as defined in the FSAR yet, the discussion then goes on to state in tabular form what the two qualified circuits are. The problem with that discussion is that there is no assurance of the SATs being energized from independent transmission circuits. In fact, the ITS 3.8.1 Bases Background states, in part ".. switchyard are maintained in accordance with the UFSAR and are not (emphasis added) governed by the requirements of Technical Specifications." Both the words of the STS and those of the CTS assure that independence will be maintained while the ITS does not. (Note:

Qualified circuit has also been substituted into other places in the ITS).

Comed Response to issue The second sentence in Insert B 3.8-1 A will be revised to state, "From the switchyard, two electrically and physically separated lines (i.e., independent transmission circuits) provide AC power through their associated System Auxiliary

,lp Transformer. " This change will be provided in our comprehensive ITS Section 3.8 closecut submittal revision upon I

NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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Response to NRC RAI For ITS Srction 3.8 17-Sep 98 NRC R AI Number NRC issued Date RAI Status 3.8.1-09 4/29/98 Closed NRC Description ofissue l

3.8.1-9 DOC L2 The DOC states "This backup source of power is r ot credited in any des:gn basis event and is not needed to preclude any new or different accident.". That statement does not adequately explain why, if that is the case, the requirment still ended up in the CTS. Was it included for any extended action time or other consideration elsewhere in the CTS?

Comed Response to Issue The requirement to have the opposite unit's diesel g;enerator capable of crosstie is a design strength that was recognized in the Auxiliary Feedwater Reliability Analysis that was performed during the initial licensing of Byrre and Braidwood. This provides a unit's motor driven AF pump with the cipability of being powered from any of two nite power sources or the division-specific diesel generator of either unit. 'Ihis crosstie ability provides the circuit path to align the second required offsite power source to the ESF busses. As stated, this ability is not credited in the Chapter 15 analyses because manual actions are required to complete the crosstic. (See ital 3.8.1-14.)

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R spons3 to NRC RAI For ITS S:ction 3.8 17-Sep-98 NRC RAI Number NRC Issued Date RAI Status 3.8.1-10 4/29/98 Closed j

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rv NRC Description of Issue 3.8.1 10 DCC L3 This DOC explains the two relaxations but provides no basis for why either is acceptable.

Comed Response to Issue 9/17/98 Revised Response: DOC 3.8-L3 has been revised to state, "With one PG inoperable, CTS LCO 3.8.1.1, Action c, requires all features that depend on the Operable DG to be Operable. If this requirement can not be met, the CTS Action requires a shutdown be commenced within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.1 Required Action B.2 provides two relaxations:

1. Rather than a plant shutdown requirement, the ITS requires that the feature (s) supported by the inoperable DG be declared inoperable ifits redundant counterpart is inoperable. This provides for actions appropriate to the actual inoperabilities, which may avoid an immediate shutdown and the risks associated with a plant shutdown. For example, if the "B" DG is inoperable in conjunction with the "A" hydrogen recombiner, CTS Actions would require a shutdown to commence within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , while ITS would allow entering Actions for both hydrogen recombiners inoperable, tnereby providing for the complete 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the DG to Operable status. Not requiring a unit shutdown is acceptable since Required Action D.2 is intended to address the loss of safety function in the event of a loss of offsite power. These features are designed with redundant safety related trains. Redundant required feature failures consist ofinoperable features associated with a train, redundant to the train that has an inoperable DG. In this condition, the remaining OPERABLE DG is adequate to supply electrical power to the onsite Class ED Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function may not have been lost.

2. ITS allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (versus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) to commence the specified action. This extension provides additional time to restore I'h b

either the inoperable DG or the inoperable feature, and is considered a reasonable time to effect repairs prior to requiring a forced shutdown of the unit. This extension is acceptable since it takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes inte account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during the period." This change is provided in our comprehensive ITS Section 3.8 closeout submittal Revisic n L.

Original Response: DOC 3.8-L3 will be revised to state, "With one DG inoperable, CTS LCO 3.8.1.1, Action c, requires all features that depend on the Operable DG to be Operable. If this requirement can not be met, the CTS Action requires a shutdown be commenced within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.1 Required Action B.2 provides two relaxations:

1. Rather than a plant shutdown requirement, the ITS requires that the feature (s) supported by the inoperable DG be declared inoperable ifits rcJandant counterpart is inoperable. This provides for actions appropriat ' the actual inoperabilities, which may cvoid an immediate shutdown. For example, if the "B" DG is inoperab e. monjunction with the "A" h,Jrogen recombiner, CTS Actions would require a shutdown to commence within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , while ITS would allow l

entering Actions for both hydrogen recombiners inoperable thereby providing for the complete 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the DG to Operable status. Not requirin; a unit shutdown is acceptable since Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of I

critical systems. The,e features are desi ned with redundant safety related trains. Redundant required feature failures g

consist ofinoperable ft atmes associat'.d with a train, redundant to the train that has an inoperable DG. In this condition, the l

remaining OPER A BLE DG is adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a l

component basis, single failure protection for the required feature's function may have been lost, however, function may not have been lost.

2. ITS allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (versus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) to commence the specified action. This extension provides additional time to restore either the inoperable CC or the inoperable feature, and is considered a reasonable time to effect repairs prior to requiring a forced shutdown of the unit. This extension is accepuble since it takes into account tha OPERABILITY of the redundant l [d counterpart to the inoperable equired feature. Additionally, the 4 hou; Completion Time takes into account the capacity ar.d

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capability of the remain!ng AC sources, a reasonable time for repairs, and the low probability of a DBA occurang during this period."

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m Respons to NRC RAI Fcr ITS Sectinn 3.8 28-Sep-98

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NRC RAI Number NRC lssued Date RAI Status 3.8.1 11 4/29/98 Closed NRC Description ofIssue 3.8.1-11

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ITS SR 3.8.1.3 Note 1 In the ITS, the use of the manufacturers recommendations is permissive. However, in CTS 4.8.1.1.2.a.5 the test must be done in accordance with the manufacturers recommendations. There is no discussion supporting this less restrictive change.

Comed Response to Issue 9/17/98 Revised Response: DOC 3.8-L31 has been revised to state, " CTS SR 4.8.1.1.2.a.5) requires " verifying the generator is synchronized, loaded to greater than or equal to 5500 kW in accordance with the manufacturer's recommendations.

ITS 3.8.1.3 Note I states, "DG loadings may include gradual loading as recommended by the manufacturer." There may be occasions where the manufacturers recomrnendations may not be strictly complied with, but the DG is still verified operable. Prudent operations may necessitate an engineering evaluation of the data to ensure the slight alteration is acceptable and the manufacturer may be contacted for confirmation. The purpose of gradual loading is to increase engine reliability by eliminating the degradation caused by " fast loading" which does not allow the engine to gradually come to thermal equilibrium. Increased engine reliability ultimately results in increased plant safety. This testing philosophy is consistent with NUREG-1431 and was specified in GL 93-05 (Line item Tech Spec Improvements). Enclosure 1 of GL 93-05 included a line item which allowed the elimination of 60 second " fast loading" and incorporation ofloading "in acccordance with the manufacturers recommendations" This line item tech spec change was adopted as part of CTS Amendment 71 for Braidwood and Amendment 79 for Byron. For the reason's stated above, it is the licensee's intent to (m) perform DG surveillances in accordance with the manufacturers recommendations. This type of operation directly increases engine reliability and therefore indirectly increases plant safety. This philosophy is reflected in current operating procedures. The current ITS verbage does not change this philosophy, but gives the station the flexibility to deviate from the manufacturers loading schedule if required (ie. tornado /T-storm wamings, emerging plant conditions, etc.) without invalidating the SR. GL 93-05 stated that, "while the majority of the testing at power is important, safety can be improved, equipment degradation decreased, and an unnecessary burden on personnel resources eliminated by reducing the amount of testing that the TS require during power operation." This is considered to be a less restrictive change since literal compliance with the CTS would require that the DG loading for this SR only be done as recommended by the manufacturer.

This change is consistent with NUREG-1431." This change is provided in our comprehensive ITS Section 3.8 closcout submittal Revision L.

Original Response: Comed will revise the CTS markup to include a less restrictive 'L' DOC which will state, " CTS SR 4.8.1.1.2.a.5) requires " verifying the generator is synchronized, loaded to greater than or equal to 5500 kW IN ACCORDANCE WITH THE MANUFACTURER'S RECOMMENDATIONS. " ITS 3.8.1.3 Note I states,"DG loadings MAY INCLUDE GRADUAL LOADING AS RECOMMENDED BY THE MANUFACTURER." There may be occasions where the manufacturers recommendations may not be strictly complied with, but the DG is still verified operable. Prudent operations may necessitate an engineering evaluation of the data to ensure the slight alteration is acceptable and the manufacturer may be contacted for confirmation. This is considered to be a less restrictive change since literal compliance with the CTS would require that the DG loading for this SR only be done as recommended by the manufacturer. This change is consistent with NUREG-1431." This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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R:sponse to NRC RAI For ITS Section 3.8 17-Sep-98

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NRC RAI Number NRC issued Date RAI Status A

3.8.1-12 4/29/98 Closad b

NRC Description ofIssue 3.8.1-12 DOC LA6 The acceptable load range values (greater than or equal to 4950 KW and less than or equal to 6050 KW) are not consistent with the CTS footnote 6050 (+0, 150) or the values in ITS SR 3 8.1.14. The ITS SR values are consistent with the ITS SR Bases which in turn make the Bases inconsistent with LA6. What are the correct numbers?

Comed Response to Issue The second sentence in DOC 3.8-LA6 will be revised to state, "ITS simply states an acceptable load range (i.e., greater than or equal to 5775 kW and less than or equal to 6050 kW); relocating the remaining discussion to the ITS Bases." This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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NRC RAI Number NRC Issued Date RAI Status 3.8.1-13 4/29/98 Closed NRC Description ofIssue 3.8.1-13 DOC L10 The DOC states "No analyzed event credits the use of the cross connect for DG operation. " That does not explain why it l

still ended up in the CTS.

I Comed Response to Issue No change. CTS 4.8.1.1.2.f.ll) requires verification that the fuel transfer pump transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines. The cross-connection capability only provides altemate means of ensuring that diesel fuel oil from the storage tank can be supplied to each day tank. The only function the CTS SR provides is a verification that the cross-connection and associated transfer pump can transfer fuel oil to the day tanks.

Comed does not take any credit for the use of the cross-connection capability. This SR was in the original Westinghouse STS, NUREG-0452, and therefore incorporated into the original CTS. Comed does not take credit for the cross-connection in any safety analysis or accident mitigation factors. Since this SR does not meet the NRC Criteria 10 CFR 50.36(c)(2)(ii), it was not incorporated into ITS. Comed continues to pursue this change.

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Respons: to NRC RAI F r ITS Secii5n~N 17-sep.98 NRC RAI Number.-

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3.8.1-14 4/29/98 Closed NRC Description ofIssue 3.8.1 14 DOC LA10 The DOC states "This capability is not a credited function for any assumed design basis event.." Again this does not explain why it still ended up in the CTS Comed Response to issue 9/17/98 Revised Response: DOC 3.8-LA10 has been revised to include the statement, "In addition, these CTS SRs do not represent real life conditions. In the event of a loss of offsite power (LOOP) on Unit 2, crossticing Unit I 'A' DG to bus 241 (Unit 2) would not be performed via synchronizing the I A DG to bus 241. In the event of a LOOP on Unit 2, both Unit 2 ESF buses would be de-energized, and therefore the crosstie woulJ be to a dead Unit 2 bus." This change it provided in our comprehensive ITS Section 3.8 closeout submittal Revision L.

Original Response: The surveillances m question provide a verification of the ability to crosstie the unit's ESF buses. This pathway is the one relied upon to provide the unit with its backup ofTsite power source. Because the CTS LCO requires the i

ability to power an ESF bus from two offsite sources, the surveillance in question was required to demonstrate this ability.

-.. _As stated, the Chapter 15 analyses do not assume this ability. (See RAI 3.8.1-09.)

NRC RAI Number NRC Issued Date RAI Status 3.8.1-15 4/29/98 Closed NRC Description ofIssue I

3.8.1-15 DOC LIS is this change considered less restrictive because in the CTS loss of power would require a 2 square inch vent while the ITS allows the RHR suction relief or other paths that do not rely on power to be used? If that is the case, isn't that just letting the LTOP TS control? If so, why isn't this an administrative change?

Comed Response to Issue This change is classified as less restrictive because the CTS requires the unit to be depressurized through a two square inch vent upon loss of the required AC source regardless of the availability of the LTOP features. Byron and Braidwood can provide for LTOP using any combination of pressurizer PORVs (2) or RH Suction Relief Valves (2), or by depressurizing through a 2 square inch vent. The proposed ITS will not require the depressurization if LTOP is available. This constitutes a relaxation and has therefore been classified as less restrictive. (Correction Note: This RAI pertains to ITS LCO 3.8.2, not ITS LCO 3.8.1.)

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Rcspense to NRC RAI For ITS Sectinn 3.8_

24-Sep-98 NRC RAI Number NRC issued Date RAI Status 3.8.1-16 4/29/98 Closed NRC Description of Issue 3.8.1-16 ITS LCO 3.8.1 and insert 3.8-9B ITS LCO 3.8.1 states the C3s are capable of supplying "the.. System." Insert 3.8-9B makes ITS LCO 3.8.2 state two DGs capable of supplying "one division of... subsystems." STS LCO-3.8.1 states two DGs " capable of supplying the onsite IE.

subsystems." In order to make it clear that erch DG supplies subsystems (consistent with the STS and LCO 3.8.2) ITS 3.8.1 should read " two DGs each capable of supplying one division of... the Class IE power distribution system."

Comed Response to issue No change. Comed has conformed to the NUREG for ITS LCO 3.8.1. The details of the onsite Class IE AC Electric Power Distribution System are delineated in the LCO Section of the Bases for ITS LCO 3.8.1, stating " separate and independent DGs for each division.." Comed continues to pursue this change.

NRC RAI Number NRC Issued Date RAI Status 3.6.1-17 4/29/98 Closed NRC Description ofissue 3.8.1-17 JFD P25 CTS requires the diesel to stan from " ambient" and the STS requires from " standby" conditions for SRs 3.8.1.2,11,12,19, and 20. It is correct as stated that as the terms are used, they mean the same, llowever, using neither term in the ITS would allow any of the above tests to be run in a situation where the diesel was already at or about full operating temperatures. The STS language should be adopted to ensure that these tests are done only from true standby / ambient conditions.

Comed Response to Issue 9/17/98 Revised Response: The STS language was adopted, with the exception ofITS SR 3.8.1.7 (based on Current Licensing Basis) where the phrase " normal standby" was retained. LCO JFD 3.8-P25 was revised to state, "NUREG SR 3.8.1.7 has been n. vised to add the word " normal" to the phrase, "from standby conditions." As approved by the Staffin the SER for Byron License Amendment 79 and Braidwood License Amendment 71, and as stated in the Byron and Braidwood CTS Bases, the surveillance requirements for demonstrating the OPERABILITY of the diesel generators are based on the recommendations in Revision 3 of Regulatory Guide 1.9, with the exceptions noted in Appendix A to the UFSAR. Appendix A to the UFSAR states that an exception has been taken against the use of the term " standby conditions" to denote " normal standby conditions." Specifically, it is noted that the semiannual fast start test described in Regulatory Position C.2.2.3 (ITS SR 3.8.1.7) is performed from " normal standby conditions." Standby condition and normal standby condition are detined in Appendix A to the UFSAR, as well as in the Surveillance Requirements Section of the Bases for ITS LCO 3.8.1 for SR 3.8.1.2 and SR 3.8.1.7." This change is provided in our comprehensive ITS Section 3.8 closeout submittal Revision L Original Response: No change. As part of CTS Amendment #71 (Braidwood) and Amendment #79 (Byron), Braidwood and Byron Stations committed to performing testing based upon recommendations of Reg Guide (RG) 1.9, Revision 3.

Appendix A of the CTS amendment included proposed exceptions to RG 1.9 Revision 3. The RG 1.9 exceptions associated with positions C.2.2.1 (ITS SR 3.8.1.2 and SR 3.8.1.7), C.2.2.4 (ITS SR 3.8.1.11) and C.2.2.6 (ITS SR 3.8.1.19) address taking exception to " starting from standby conditions". This appendix was reviewed and approved by the NRC as part of the CTS Amendments. Review of RG 1.9 testing requirements shows no specific prerequisite to start the engine from standby for position C.2.2.14 (ITS SR 3.8.1.20). Comed continues to pursue this change.

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m Rtsponse to NRC RAI For ITS Section 3.ii 17-Sep-98 NRC RAI Number NRC Issued Date RAI Status O

3.8.1-18 4/29/98 Closed 1

NRC Description of Issue 3.8.1-18 Insert to Bases for ITS SR 3.8.1.16 The bases discussion has been modified to state the SR is in general conformance with the recommendations of Reg Guide 1.9 paragraph 2.2.11. How is this reflected in the discussion of Reg Guide 1.9 contained in FSAR Appendix A7 That discussion does not appear to contain any qualifications with respect to this testing.

Comed Response to issue The Surveillance Requirements Section of the Bases for ITS LCO 3.8.1 for ITS SR 3.8.1.16 will be revised to conform to the STS. "In general conformance with the recommendations of.. " will be revised to "As required by.." This change will be provided in our comprehensive ITS Section 3.8 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI. (See RAI 3.8.4-01.)

NRC RAI Number NRC Issued Date RAI Status 3.8.1 19 4/29/98 Closed NRC Description ofIssue 3.8.1-19 DOC L28 and JFD P22 Identified as Beyond Scope item #11

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Comed Response to issue No change required. Beyond Scope item #11 was accepted per discussions with NRC Staff during May 7,1998 meeting with Comed and NRC.

NRC RAI Number NRC issued Date RAI Status 3.8.1-20 4/29/98 Closed l

NRC Description ofIssue 3.8.1-20 DOCS L26 and L29, and JFDs P21 and P23 Identified as Beyond Scope item #12 Comed Response to issue 9/17/98 Revised Response: LCO JFD P6 for SR 3.8.1.12 was revised to state, "NUREG SR 3.8.1.12.d and SR 3.8.1.12.e t

have been revised to reflect plant specific testing by deleting NUREG requirements that are not contained in the CTS.

l During the performance of the DG emergency start surveillance, ITS SR 3.8.1.12, relay actuations do not cause a perturbation to the ESF bus. Due to the absence of the undervoltage relay on the ESF bus, the DG output breaker does not receive a closure signal, and therefore does not close onto the associated ESF bus. Actuation of the K611 relay starts the DG on an SI signal. Offsite power continues to feed the loads connected to the associated ESF bus. NUREG SR 3.8.1.15 has been revised to reflect the plant-specific CTS requirements tthat are being retained." This change is provided in our comprehensive ITS Section 3.8 closcout submittal Revision L.

Original Response: No Comed Response required at this time. The subject RAI is currently under review by the NRC as a i p Beyond Scope issue that has not yet received final NRC disposition, in addition, the proposed change is included in WOG-

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89. Comed will address any questions generated as a result of the NRC review for the subject RAI when they are received.

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Response to NRC RAI For ITS Secti::n 3,8 17-Sep-98 NRC RAI Number NRC Issued Date RAI Status 3.8.1-21 4/29/98 Closed NRC Description of Issue 3.8.1 21 DOC L24 and JFD P23 Identified as Beyond Scope item #13 Comed Response to Issue 9/17/98 Revised Response: Per the request of the ITS Section 3.8 Reviewer, ITS SR 3.8.1.10 Note has been revised to limit the application of the Note to only "immediately following load rejection." Therefore, the Note has been revised to state,

" Momentary transients above the voltage limit immediately following a load rejection do not invalidate this test." This change is provided in our comprehensive ITS Section 3.8 closcout subrJttal Revision L.

Original Response: No Comed Response required at this time. The subject RAI is currently under review by the NRC as a Beyond Scope issue that has not yet received final NRC disposition. Comed will address any questions generated as a result of the NRC review for the subject RAI when they are received.

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NRC RAI Number NRC Issued Date RAI. Status 3.8.1-22 4/29/98 Closed NRC Description ofIssue 3.8.1-22 JFD P9 f"'N

,h This JFD is applicable to LCOs 3.8.2 and 3.8.7, it is unclear why it is used in the markup of STS 3.8.1 (Page 3.8-4).

Comed Response to issue The Note will be revised to adopt the STS wording. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI. Note: This change is applicable to ITS LCOs 3.3.5,3.3.6,3.4.14,3.6.2,3.6.3,3.7.7,3.7.8,3.8.1,3.8.2, and 3.8.7. (See RAls 3.4.14-02, 3.6.2-02,3.7.7-04, and 3.7.8-06.)

NRC RAI Number NRC Issued Date RAIF.

.s 3.8.1-23 4/29/98 Closed NRC Description of Issue 3.8.1-23 Bases for ITS SR 3.8.1.3 Given that the second paragraph of the Bases says that there are no power factor requirements and that the DG is normally l

operated between 0 and 1000 kVars, wouldn't it be better to modify the discussion in the last paragraph to remove the power factor discussion or change it to kVars discussion?

I Comed Response to Issue The fourth paragraph in the Surveillance Section of the Bases for ITS LCO 3.8.1 for SR 3.8.1.3 will be revised to state, "

Note 2 states that momentary transients, (e.g., changing bus loads) do not invalidate this test. Similarly, m : entary kVar transients outside the specified range do not invalidate this test.. " This change will be provided in our comprehensive ITS Section 3.8 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.

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Re.sponse to NRC RAI Fcr ITS Sectisn 3 17-sep.98 NRC RAI Number NRC issued Date RAI Status 3.8.1-24 6/12/98 Closed V

NRC Description of Issue 3.8.1 24 ITS SR 3.8.18 as now proposed is allowed to be done in all modes and must be a manual transfer from normal to attemate/ reserve. Is this a bumpered (make before break) transfer and can it be done in all modes?

Comed Response to Issue Verification of the manual transfer of AC sources from the normal circuit to the reserve circuit is a make before break transfer. With the normal circuit still supplying the 4 kV ESF bus (e.g., circuit breaker 1412 closed), the emergency diesel generator is synchronized to the bus (circuit breaker 1413 closed). The reserve feed breaker on the same unit is closed (circuit breaker 1414) and the normal feed breaker is opened (circuit breaker 1412). Then the reserve feed breaker from the opposite unit is closed (circuit breaker 2414) and the diesel generator supply breaker is opened (circuit breaker 1413). Per the Byron and Braidwood Operating procedures, the transfer from normal to reserve power is applicable in MODES 1-6.

(Correction Note: ITS SR 3.8.18 should be ITS SR 3.8.1.8.)

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R:sponsa to NRC RAI For ITS S:cti:n 3Ji 17-Sep-98 NRC RAI Number NRC Issur a Date RAI Status p

3.8.2-01 4/29 s 8 Clased U

NRC Description of issue 3.8.2-1 DOC A14 The intent ofITS Conditions A and B should be to return the inoperable battery charger to operable status and once returned to that status break the cross-tie with the other unit and begin to use that charger. As proposed in DOC A14, if the charger could be operable sooner than the required Completion Time the cross-tie would not have to be broken for up to 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months .

That may not have been the intent but giving the cross-tie a separate Completion Time certainly makes that reading a reasonable one.

Comed Response to issue 9/17/98 Revised Response: No change. Scenario #1: Assume both units are operating in MODE 1,2,3, or 4. Unit I has an operable battery charger. Unit 2 has an inoperable battery charger. The Unit I and Unit 2 DC crosstie breakers are closed to supply power to the Unit 2 DC bus having the inoperable charger. For this scenario Unit 2 is in ITS Condition A (2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to crosstie to Unit I and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the inoperable battery charger). If, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , Unit 2 does not restore its battery charger to operable status, ITS Condition E is entered and Unit 2 has 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to be in MODE 5. In this situation, Unit 1 is in ITS Condition B as soon as both unit crosstie breakers are closed. Unit I has 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months to open at least one crosstic breaker. As CTS DOC 3.8-A14 explains, the 60 hour6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months Completion Time for Unit 1 is based on the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Unit 2 to restore its inoperable charger plus the 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for Unit 2 to be in MODE 5 if the charger is not restored to operable status. If the Unit 2 charger is restored within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months time periods, as soon as one crosstic breaker is opened, Unit 2 would exit ITS Condition A or E, and Unit I would exit Condition B. Scenario #2: Assume both units are operating in MODE 1,2,3, or 4. If both units' battery chargers are operable and both unit crosstie breakers are closed, both Unit I and Unit 2 would be required to enter ITS Condition D (i.e.,2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to open at least one unit crosstie breaker). As stated in the second paragraph for Action D.1 in the Actions Section of the Bases for ITS LCO 3.8.4, "Ifone of the required DC electrical

,(d power subsystems is inoperable (e.g., inoperable battery or one DC division crosstied to the opposite-unit DC division that s

does not have an inoperable battery charger), the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition." This corresponds to CTS 3.8.2.1 Action d.

Original Response: No change. ITS LCO Condition A applies to a unit in MODES 1-4 with an inoperable battery charger.

Condition B applies to a unit in MODES 1-4 crosstied to the opposite unit in MODES 1-4 with an inoperable battery charger. In either case, Condition A or Condition B, assuming that the battery charger is restored to OPERABLE status sooner than the required Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , in order to avoid a unit shutdown per Condition F, the LCO would have to be met (i.e., at least one unit crosstie breaker per division open). This would require the unit to restore the battery charger and open the crosstic breaker within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and exit Condition A. Comed continues to pursue this change.

(Correction Note: This RAI pertains to ITS LCO 3.8.4, not ITS LCO 3.8.2.)

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NRC RAI Number NRC Issued Date RAI Status 3.8.2-02 4/29/98 Closed NRC Description of Issue 3.8.2-2 JFD C10 Staff has not seen or reviewed changes proposed by WOG-81.

Comed Response to Issue t

WOG-81 will be withdrawn in its entirety throughout the ITS submittal. The submittal will be revised to adopt the STS presentation in the Applicability Section. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl. (See RAls 3.1.5-02,3.4-n G) 01, 3.5-01, 3.7.10-03, 3.'i. ] I-02, 3.7.13-06, 3.9.4-06, and 3.9.7-05.)

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i Response to NRC RAI Fcr ITS S:ction 3.8 17-Sep 98 j

NRC RAI Number NRC issued Date RAI Status r 's 3.8.2-03 4/29/98 Closed i

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V NRC Description ofissue 3.8.23 1

JFD P21 and Bases JFD P26 The LCOs and Bases for STSs 3.8.2,3.8.8, and 3.8.10 have been modified by adding a note stating "LCO 3.0.3 is not applicable". If this is a generic issue a generic change should be proposed for the NRC to consider. On a plant specific basis it is beyond the scope of the conversion.

Comed Response to Issue 9/17/98 Revised Response: The proposed change associated with LCO JFD 3.8-P11 and Bases JFD 3.8-P26 was deemed acceptable per discussions with the ITS Section 3.8 Revit.wer during the June 25,1998 meeting with Comed and the NFr' i

This change is provided in our comprehensive ITS Section 3.8 closecut submittal Revision L.

Original Response: In Comed's original submittal, ITS Revisian A, the proposed change was classified as a generic change (LCO JFD 3.8-C5 and Bases JFD 3.8-C3) based on TSTF-36, Revision 2. However, in ITS Revision C, which withdrew TSTF-ll5 from the submittal, the proposed change was made plant specific (LCO JFD 3.8-Pil and Bases JFD 3.8-P26).

Comed will withdraw the plant specific change for ITS LCOs 3.8.2,3.8.8, and 3.8.10. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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1 NRC RAI Number NRC issued Date RAI Status 3.8.3-01 4/29/98 Closed g3 NRC Ducription ofIssue

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3.8.3 -1 JFD Cl Staff approval of TSTF-2 Rev 1 is pending.

Comed Response to Issue 9/17/98 Revised Response: No change. TSTF 2, Revision I was approved by the NRC.

Original Response: No Comed Response required at this time.

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Rispanss to NRC RAI For ITS S:ction 3.8 17-sep-98

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NRC RAI Number NRC Issued Date RAI Status 3.8.3-02 6/12/98 Closed L

NRC Description ofIssue 3.8.3-2 Pl4 The justification that the diesels in use at Byron /Braidwood do not use much lube oil while in operation is not sutlicient as other plants use similar diesels and have adopted the STS.

Comed Response to Issue Experience has shown that the emergency diesel generators (EDGs) at Byron and Braidwood consume approximately 55 gallons oflubricating oil per year, or 82.5 gallons per fuel cycle (18 months). The lube oil reservoir contains approximately 1300 gallons of oil and is monitored once per shift, every 30 minutes during a diesel run, and before and after any planned starts. Spec F/L-2742 states that the guarameed lube oil consumption is less than 0.00014 gal /kW-hr. (Spec F/L 2742 is the purchase spec that outlines the various parameters that the vendor certified the equipment to.) This corresponds to a consumption of 0.77 gph. There are 486 gallons oflube oil from the " fill" line until the EDG is inoperable. There are 354 gallons of tube oi! Aom the low level alarm until the EDG is inoperable. This represents approximately 400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months of operating time from the low level alarm until the EDG is inoperable. Based on an average of 110 hours0.00127 days 0.0306 hours 1.818783e-4 weeks 4.1855e-5 months of run-time per j

cycle, the EDGs can operate over 2 cycles without adding oil concurrent with a loss of offsite power and still meet the 7 day requirement [354 gal X 1 hr/0.77 gal = 459 hr; and (459 hr - 168 hr) X 1 cycle /l10 hr = 2.65 cycles). Using the loading schedule in Calculation DGDO9301 over the 7 day worst case LOCA scenerio, the consumption would be much lower than above. Since the oil is drained and refilled to the " fill" line every outage, worst case would be operating for a cycle with the low level alarm inoperable and the Operators and System Engineer not performing their oil checks for the entire cycle.

Based on the very low amount of oil consumption, and on the fact that a modification to Byron and Braidwood Stations would be required in order to adopt the NUREG Condition, Comed continues to pursue not adopting the proposed generic requirements of NUREG-1431 for LCO 3.8.3.

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NRC RAI Number NRC lssued Date RAI Status 3.8.4-01 4/29/98 Closed NRC Description ofIssue 3.8.4-1 ITS 3.8.4 Bases Background in the Background discussion, the word " generally" has been added when discussing conformance with Reg Guide 1.6 and IEEE 308. Byron & Braidwood FSAR Section 8.1 and FSAR Appendix A do not appear to contain any exceptions to either of the standards with respect to DC electrical power. What requires the insertion of the " generally" qualifier?

Comed Response to Issue The Background Section of the Bases for ITS LCO 3.8.4 will be revised to conform to the STS by deleting the word

" generally" in the first paragraph. This change will be provided in our comprehensive ITS Section 3.8 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl. (See RAI 3.8.1 18.)

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Respons to NRC RAI For ITS SecticU5 17-Sep-98

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3.8.4-02 4/29/98 Closed

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NRC Description of Issue 3.8.4-2 Bases JFD P30 in the ITS Bases the phrase "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " is deleted. While 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months may not be appropriate for Byron & Braidwood, Sections 5 and 6 ofIEEE 308 require that the battery charger time be within a time consistent with the design basis and that the battery charging available. Therefore, the charging time for Byron & Braidwood should be available and should be put in place of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Comed Response to Issue Comed agrees. The Background Section of the Bases for ITS LCO 3.8.4 will be revised to conform to the STS. In addition, JFD 3.8-P30 will be deleted. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.

NRC RAI Number NRC Issued Date RAI Status 3.8.4-03 4/29/98 Closed NRC Description of Issue 3.8.4-3 Insert 3.8.24A Why is ITS Condition B "that has an inoperable battery charger. " and Condition C "with an inoperable source.."?

b Comed Response to Issue 9/17/98 Revised Response: Per the request of the ITS Section 3.8 Reviewer, C.I and C.2 Actions Section of the Bases for ITS LCO 3.8.4 have been revised to clarify that a " source" can be either a battery or a battery charger. This change is provided in our comprehensive ITS Section 3.8 closcout submittal Revision L.

Original Response: ITS LCO 3.8.4 Condition B pertains to an inoperable " battery charger" while Conditior. C pertains to an inoperable " battery." Refer to the Actions Section of the Bases for ITS LCO 3.8.4.

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R:spons3 to NRC RAI For ITS S:ction 3.8 17-sep-98 NRC RAI Number NRC lssued Date RAI Status i

q 3.8.4-04 4/29/98 Closed j

NRC Description of Issue 3.8.4-4 l

ITS SR 3.8.4.7 (Byron only) & JFD P28 and Bases JFD P35 The STS state that a modified discharge test can be substituted for a service test but not with a discharge performance test as specified in the ITS SR. Further, JFD P28 states (quoting IEEE 450) "a modified performance discharge test can be used in l

lieu of a service test at anytime" This implies that if a performance discharge test can be used (which would be contrary to the STS Bases) it could only be used on some limited basis and not the unlimited basis proposed. Finally, use of the performance discharge test in place of the service test appears contrary to the Reg Guide 1.129 discussion in the Byron &

Braidwood FSAR Appendix A. Further explanation andjustification is needed.

Comed Response to issue Comed will revise Byron ITS SR 3.8.4.7 Note I to perform the modified discharge test ins'. cad of the performance discharge test in lieu of the service test. This is consistent with the STS and Braidwood ITS. Performance of the modified discharge test in lieu of the service test is Current Licensing Basis in CTS, an acceptable practice in the industry, and is also acceptable per the IEEE-450. The modified discharge test encompasses the service test whereas the performance discharge test does not encompass the entire service test. In addition, the Byron Bases will be revised to be consistent with the subject change. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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l NRC RAI Number NRC issued Date RAI Status 3.8.4-05 4/29/98 Closed NRC Description of Issue 3.8.4-5 1TS 3.8.4 Bases References (Braidwood) it appears that there should be an additional page following B3.8-58a containing the section references.

Comed Response to issue Comed agrees. In the "Brwd ITS" tab of the submittal, B.3.8-58b is missing for the References Section of the Bases for ITS LCO 3.8.4. Copies of this page are included with this RAI Response.

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Response to NRC RAI Fcr ITS Sectinn 3.8 17-Sep.98

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NRC RAI Number NRC Issued Date RAI Status 3.8.4-06 4/29/98 Closed

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NRC Description ofIssue 3.8.4-6 ITS 3.8.4 Bases References (Byron) l

_lEEE 450 -1995 is the version of the standard in the Reference section and is the referenced standard for the dii frequency and acceptance criteria for a number of the ITS 3.8.4 (and 3.8.6) SRs. However, the Byron UFSAR states that the frequencies of battery tests are established in accordance with IEEE 450 -1975 (as modified by the proposed 1978 revision).

Do the references to different version of the standard create any inconsistencies in application of the SRs and/or are there i

l other instances in which the ITS updates standards from those in the FSAR?

Comed Response to Issue No change. Byron submitted a License Amendment Request (LAR)in March of 1997 and received a Safety Evaluation l

Report (SER) dated November 25,1997 addressing the replacement of the original 125 VDC Gould batteries with C&D batteries. The SER noted the change in the referenced standard to IEEE 450-1995 and the change was addressed in an RAI response dated August 7,1997. Replacement of the Gould batteries with the C&D batteries on both units has occurred during the last two refueling outages in November of 1997 and April of 1998. The Byron UFSAR will be revised to address proper reference ofIEEE 450-1995.

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l NRC RAI Number NRC Issued Date RAI Status i

3.8.4-07 4/29/98 Closed NRC Description ofissue 3.8.47 f

Bases JFD P18 STS 3.8.4.6 raommends that specific battery ratings be provided in the SR. However, consistent with CTS SR 4.8.2.1.2.c.4, the wording "a load equal to manufacturer's rating" is adopted in the ITS (JFD P16). Consistent with that change, it is proposed that the ITS Bases contain the same wording. If the Bases merely repeat the words of the TS, how is a basis for the TS being provided? Why isn't a specific value (which can be modified in accordance with the Bases control program) provided in the Bases?

Comed Response to Issue The Surveillance Requirements Section of the Bases for ITS LCO 3.8.4 for SR 3.8.4.6 will be revised to state, "This SR requires that each battery charger be capable of supplying 400 amps and 125 V for greater than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . These requirements are based on the (design capacity) of the chargers (Ref. 4)." In addition, Bases JFD 3.8-P18 will be deleted.

This change will be provided in our comprehensive ITS Section 3.8 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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Response to NRC RAI For ITS Secti:n 3.8 21-Sep-98 kRChiNumber

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NRC Issued Date RAI Status t'~~\\

3.8.5-01 4/29/98 Closed ib)

NRC Description of Issue 3.8.5-1 JFD C9 l

TSTF 204 has not yet been approved by the NRC.

Comed Response to issu'e 9/17/98 Revised Response: Comed has omitted any reference to TSTF-204 in the ITS submittal and has adopted the associated change based on our current licensing basis. CTS DOC 3.8-M3, LCO JFD 3.8-P31, and Bases JFD 3.8-P49 have been added as justification for this change. This change is provided in our comprehensive ITS Section 3.8 closeout ; 3mittal Revision L Original Response: No Comed Response required at this time.

L NRC RAI Number NRC issued Date RAI Status 3.8.6-01 4,29/98 Closed NRC Description of issue 3.8.6-1 Bases JFD P46 TSTF 203 has not yet been approved by the NRC.

Comed Response to issue v

No change. In Comed's original submittal, ITS Revision A, the proposed change was classified as a generic change (Bases JFD 3.8-C6). However, in ITS Revision C, which withdrew TSTF-IIS from the submittal, the proposed change was made plant specific (Bases JFD 3.8-P46), but stated that this change is consistent with TSTF-203. TSTF-203 is pending NRC approval. The purpose of the change was to correct an error in the NUREG that omitted a Bases discussion addressing the ACTIONS Note in NUREG LCO 3.8.6. Comed continues to pursue this change.

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R:spons: to NRC RAI For ITS Sectio 7-Segw98 NRC RAI Number NRC Issued Date RAI Status 3.8.6-02 4/29/98 Closed NRC Description ofIssue v

l 3.8.6-2 DOC L19 The DOC states that ITS SR 3.8.6.3 requires "this same verification. " when referring to CTS SR 4.8.2.1.2.b.3. However, the CTS requires that the average temperature of all connected cells be checked, while the ITS requires only the average temperature of representative cells be checked. This less restrictive change has not been justified.

Comed Response to Issue Comed agrees and will revise DOC 3.8-L19 to state " CTS SR 4.8.2.1.2.b.3) requires that once every 92 days and within 7 days after a battery discharge, the average electrolyte temperature of all connected cells is verified to be above 60oF. ITS SR 3.8.6.3 requires that once every 92 days the average electrolyte temperature of representative cells is verified to be 600F. Deletion of the SR after a battery discharge is acceptable because a large discharge of the battery will tend to heat the battery electrolyte, not reduce the temperature. Therefore, the requirement to measure electrolyte temperature after a discharge is not necessary. In addition, CTS requires the average electrolyte temperature for all connected cells be verified.

ITS requires the average electrolyte temperature of the representative cells be verified. Changing the SR to representative cells is consistent with IEEE-450 testing requirements and terminology. Based on the above, both of these changes are considered to be less restrictive, however since the changes are consistent with an approved NRC and industry standard, there is no impact on safety." This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

r_

NRC RAI Number NRC Issued Date RAI Status 3.8.7-01 4/29/98 Closed NRC Description ofIssue 3.8.7 1 JFD PIB and Bases JFD P43 TSTF 202 has not yet been approved by the NRC.

Comed Response to Issue 9/17/98 Revised Response: Comed has withdrawn TSTF-202 from the ITS submittal. This change is provided in our comprehensive ITS Section 3.8 closcout submittal Revision L.

Original Response: No Comed Response required at this time. In ITS Revision C, which withdrew TSTF-115 from the submittal, the proposed change was made plant specific (DOC 3.8-L23, LCO JFD 3.8-P18, and Bases JFD 3.8-P43), but stated that this change is consistent with TSTF-202. TSTF-202 is pending NRC approval. The purpose of the change was to incorporate the guidance ofIEEE-450 (1995) for maintenance and testing oflead-acid batteries. The recommendations of the standard provide guidance for the optimization oflife and performance of the batteries in use for emergency applications at nuclear power plants. IEEE-450 indicates that the subject surveillances should be performed "at least monthly."

Typically, the battery cell parameters of electrolyte level, float voltage, and specific gravity (or charging current) change slowly and a monthly Frequency provides an adequate assurance of safety. Additionally, battery terminal voltage is typically monitored and the monthly inspections are supplemented with an abnormal condition alarm. Therefore, monthly Surveillances are sufficient to assure the appropriate operation of this equipment. Comed continues to pursue this change.

21

Rispense to NRC RAI[cr ITS ShetIc 8

17-Sep-98 NRC RAI Number NRC Issued Date RAI Status

(

3.8.7-02 6/12/98 Closed j

r NRC Description of issue 3.8.7-2 The ITS Bases reference the FSAR when describing the operation of the inverters. What is left unexplained is whether an inverter that is capable of supplying power from only its AC or DC source would still be considered Operable. Is the auctioneering/ swapping necessary to call the inverter Operable?

Comed Response to Issue The 480 VAC bus is the normal source of power to the inverter with the 125 VDC bus taking over automatically if the AC input fails or drops below a certain value. The three phase,480V input is first transformed then rectified to a DC value slightly greater than the 125 VDC bus. A blocking diode in the feed from the 125 VDC bus will normally be reversed biased thus blocking the 125 VDC bus input. If the AC power supply fails or goes below a certain value the diode will conduct (become unblocked) and the 125 VDC bus will supply the inverter automatically. If the diode fails in such a manner that the inverter is unable to be energized from the DC bus, the inverter would be declared inoperable.

The third paragraph in the LCO Section of the Bases for ITS LCO 3.8.7 states, " OPERABLE inverters require the associated j

instrument bus to be powered by the inverter with output voltage within tolerances, and power input to the inverter from the associated 125 VDC battery. The power supply may be from an AC source via rectifier as long as the battery is connected as the uninterruptible power supply." With only the 125 VDC bus powering the invener (and with the battery connected to the DC bus), the inverter would be considered operable. However, with only the 480 VAC bus powering the inverter, the inverter would be considered inoperable.

NRC RAI Number NRC Issued Date RAI Status 3.8.9-01 4/29/98 Closed

p NRC Description of Issue 3.8.9-1 JFD C4 How was the editorial comment provided to the NRC7 Comed Response to Issue This and other minor editorial comments throughout the STS were discussed and approved by the NRC during various meetings with Excel Services Corp., NEl, and the NRC. The subject editorial change revised STS 3.8.9 Condition B and Required Action B.1 to change "AC vital bus" to "AC vital bus electrical power distribution subsystem." The insertion of the phrase, " electrical power distribution subsystem" makes the Conditions consistent with the LCO. In discussions with the NRC, it appears that this was an editorial omission.

J 22 i

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Response to NRC RAI Fcr ITS Secti::n 3.8 17-sep-98

'NRC RAI NuSE[

NRC Issued Date RAI Status

~

3.8.9-02 4/29/98 Closed V

NRC Description ofIssue 3.8.9-2 DOC L18 On a generic basis the change proposed here was rejected when the staff considered TSTF 16. If arguing for it on a plant specific basis it is beyond the conversion scope.

Comed Response to Issue Comed will revise our submittal to conform with the requirements of CTS and the NUREG. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.

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3.8.1-9 3.8.1-17 3.8.1-10 3.J.1-12 3.8.1-17 3.8.2-1 3.8.1-22, 3.8.2-2 3.8.4-1 3.8.4-2 3.8.4-3 3.8.4-4 (By only) 3.8.4-5 3.8.5-1 3.8.2-2

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3.8.6-2 3.8.7-1 3.8.6-4 3.8.7-1 3.8.1-22 3.8.8-1 3.8.2-2 3.8.9-2 3.8.9-2 3.8.9-3 3.8.9-2 3.8.10-1 3.8.2-2 B 3.8.1-1 3.8.1-8 B 3.8.1-5 3.8.1-17 B 3.8.1-8 3.8.1-6 B 3.8.1-15 3.8.1-17 B 3.8.1-17 3.8.1-23 B 3.8.1-21 3.8.1-21 B 3.8.1-24 3.8.1-17 B 3.8.1-26 3.8.1-18 l

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Table A - Administrative Changes to CTS -

Discussion Description ITS CTS of Change of Change Requirement Requirement ITS Section 3.8, Etectrical Power Systems 3.8 A1 Editorial rewording, reformatting, and renumbering changes were made to conform with 3.8

~

3/4.8 conventions used in Westinghouse Standard Technical Specifications NUREG-1431 (STS).

3.8 A2 The requirement to enter LCO 3.0.3 was explicity stated as an action for the condition of three 3.8.1 Action G 3.8.1.1, or more AC electrical power sources being inoperable to clarify current requirements.

3.0.3 3.8 A3 The restriction for performing various surveillances "during shutdown" were presented with the SR 3.8.1.9 Note, 4.8.1.1.2.f, operational Modes, consistent with current intent and practice, during which the surveillances SR 3.8.1.10 4.8.2.1.2.d.

may not be performed.

Note 2, 4.8.2.1.2.e, SR 3.8.1.11 Note, 4.8.2.1.2.f SR 3.8.1.14 Note 2, i

SR 3.8.1.16 Note, SR 3.8.1.17 Note, SR 3.8.1.18 Note, SR 3.8.1.19 Note, SR 3.8.4.7 Note 2 SR 3.8.4.8 Note 3.8 A4 The requirement to visually inspect the batteries for physical damage or abnormal degradation SR 3.8.4.3 4.8.2.1.2.c.1 was clarified by adding the phrase "that could degrade battery performance."

.e (By)- Byron specific (Bw)- Braidwood specific Byron and Braidwood A_TBL3.8 1

(

Table A - Administrative Changes to CTS Discussion Description ITS CTS of Change of Change Requirement Requirement 3.8 A S The stated minimum DG frequency response criteria was eliminated for the single largest post-SR 3 8.1.9 4.8.1.1.2.f.2 accident load rejection surveillance since this test induces an over-frequency transient.

3.8 A6 Reference to the DG 24-hour run surveillance as a prerequisite to the 5-minute restart SR 3.8.1.15 4.8.1.1.2.f.7 surveillance was deleted since the option to run the DG for a 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or until operating temperatures stabilize encompasses this prerequisite.

3.8 A7 The listing of some of the causes that could be ruled out as potential common mode failures 3.8.1 Action B 3.8.1.1 Actions was eliminated and replaced by an action to demonstrate the absence of any potential common a and b mode failures.

3.8 A8 The current requirements allow, with one unit in Mode 5,6, or defueled and the opposite unit in LCO 3.8.5 Note 3.8.2.2 Act',n a r

Mode 1,2,3, or 4 with an inoperable DC bus due to an inoperable charger, the shutdown unit to supply the opposite unit's DC bus without load restriction. This allowance was reformatted, without change to current intent, as an LCO Note.

3.8 A9 Because power sources are considered support sg: ems to the Distribution System, notes were 3.8.1 Action D 3.8.1.1 Action b, included to clarify that the appropriate actions when one required division is de-energized are Note, 3.8.2 3.8.1.2 Actions, those of the supported systems rather than those of the support systems, as would normally be Action A Note, 3.8.3.1 Action b the application of LCO 3.0.6.

3.8.7 Action A Note 3.8 A10 The actions stipulated for less than the required AC electrical power sources Operable were 3.8.2 Actions 3.8.1.2 Actions revised to address the required offsite power source inoperable and the required DG inoperable A and B separately for clarification.

Cy)- Byron specife (Bw)- Braidwood specific Byron and Braidwood A_TBL3.8 2

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Table A - Administrative Changes to CTS Discussion Description ITS CTS of Change of Change Requirement Requirement 3.8 A11 DG fuel oil requirements were provided in a separate Specification and the Diesel Fuel Oil 3.8.3 4.8.1.1.2.a.2, Testing Program.

4.8.1.1.2.c, 4.8.1.1.2.d, 4.8.1.1.2.e 3.8 A12 (By)

References to Gould batteries were deleted since Byron Station does not use these batteries.

N/A 3.8.2.1 Action c.1, 4.8.2.1.2 Table 4.8-2, 3.8.2.2 Action b.1 3.8 A13 Not used.

3.8 A14 The allowance for one unit to power, via the crosstie breakers, the opposite unit's inoperable 3.8.4 Action B 3.8.2.1 Action b DC bus having an inoperable charger was reformatted as an action to open one of the breakers within 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months . The 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months corresponds to time required for the opposite unit to reach Mode 5 if unable to restore the inoperable charger.

3.8 A15 An explicit action which requires immediate shutdown actions be commenced when two 3.8.9 Actions, 3.8.3.1 Actions, inoperable subsystems result in a loss of safety function, along with the Safety Function LCO 3.0.6 3.0.3 Determination Program, ensure that no loss of function will occur without the appropriate action.

6 (By)- Byron soecire (Bw)- Braidwood specific Byron and Braidwood A_TBL3.8.

3

O O

O Table R - Relocated CTS Discussion Relocated Description of New Control of Change CTS Relocated CTS Location Process CTS Section 314.8, Ekctrical Power Systems 3.8 R1 3/4.8.4.1 Containmont Penetration Conductor Overcurrent Protective Devices TRM 50.59 t

3.8 R2 3/4.8.4.2 Motor Operated Valves Themal Overload Protection Devices TRM 950.59 I

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4 (By)- Byron spectre (Bw)- Braidwood specific Byron and Braidwood 1

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Table M - More Restrictive Changes to CTS Discussion Description ITS

' CTS of Change of Change Requirement Requirement ITS Section 3.8, Electrical Power Systems 3.8 M1 The surveillance to verify the transfer of fuel oil from the diesel generator (DG) storage tank to SR 3.8.1.6 4.8.1.1.2.a.3 the day tank was modified to specify the automatic transfer capability.

3.6 M2 Not used.

3.8 M3 Additional requirements were imposed regarding energization of the required AC engineered 3.8.2 LCO and 3.8.1.2 LCO and safety feature (ESF) divisions from offsite and DG sources.

Action A Actions Additional requirements were imposed regarding energization of the required DC ESF divisions 3.8.5 LCO and 3.8.2.2 LCO and from the attendant batteries and chargers.

Action A Actions Additional requirements were imposed regarding energization of the required AC and DC ESF 3.8.8 LCO and 3.8.3.2 LCO and divisions, and AC instrument bus power distribution subsystems and the attendant inverters.

Action A, Actions 3.8.10 LCO and Action A 3.8 M4 The Applicauhty was expanded to include "during movement of irradiated fuel assemblies" so 3.8.2 Applicability, 3.8.1.2 App!icability that electrical power systems will be available to mitigate a fuel handhng accident when the 3.8.5 Applicability, 3.8.2.2 Applicability reactor vesselis defueled.

3.8.8 Applicability, 3.8.3.2 Applicabihty 3.8.10 Applicability 3.8 MS The action to immediately initiate action to restore inoperable electrical power systems was 3.8.2 Actions A 3.8.1.2 Actions, revised to apply regardless of whether reactor coolant loops are ' de 1 or whether the reactor and B, 3.8.3.2 Actions vessel cavity is flooded.

3.8.8 Actions, 3.8.10 Actions 3.8 M6 With at least one of two inoperable offsite AC circuits not rec.tured within the prescribed time, an 3.8.1 Action F 3.8.t1 Action d action was included to further shutdown the unit from Mode 3 to Mode 5 in order to place the unit in a condition in which the LCO does not apply.

(By) - Byron specific (Bw)- Braidwood specif:c Byron and Braidwced 1

M_TBL3 8

Table M - More Restrictivt Changes to CTS Discussion Description ITS CTS of Change of Change Requirement Requirement i

3.8 M7 The completion time for restoration of inoperable electrical power distribution subsystems was 3.8.9 Actions A, B.

3 A2.1 Action d, restricted to "16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO' to prevent indefinite operaten ! and C.

3.8.3.1 Actions a while not meeting the LCO.

and b 3.8 M8 An action was included to declare the Residua! Heat Removal subsystem (s) incperable and not 3.8.10 Action A 3.8.3.2 Actions in operation when its supporting instrument bus is inoperable so that appropriate consideration is given to shutdown cooling systems without required power.

3.8 M9 A requirement was included that restricts the DG 60 minute load run to be performad SR 3.8.1.3 Note 4 4.8.1.1.2.a.5 immediately following, without shutdown, a 10 second start surveillance.

3.8 M10 An additional completion time of "once per 7 days thereafter" to venfy ba'tery cell pararreters are 3.8.6 Action A Table 4.8-2 Note 1 within allowable limits was included with the initial performance.

3.8 M11 The DG minimum acceptable output voltage was increased to 3950 VAC to ensure adequate SR 3.8.1.2, 4.8.1.1.2.a.4, voltage is available for equipment to perform their safety related functions in the event of a loss SR 3.8.1.7, 4.8.1.1.2.f.2 of offsite power.

SR 3.8.1.15, l

SR 3A1.9 l

3.8 M12 The time for which a charging current of < 2 amps can be used to sctisfy specif!: g avity Table 3.8.6-1 Table 4.8-2 Note 5 requirements of connected battery cells was limited to 7 days following a battery recharge and Note d the specific gravity shall be measured prior to the expiration of the 7 days.

3.8 M13(Bw)

The allowance that the modified performance dischage test as well as the performance SR 3.8.4.7 Note 1 4.8.2.1.2.e discharge test may be performed in lieu of the battery service 'est was restricted to allow on!y the modified performance discharge test to be substituted.

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I Table LA - Details Relocated from CTS l

Discussion CTS Description of New Control of Change Reference Relocated Details Location Process Type ITS Section 3.8, Electrical Power Systems I

3.8 LA1 LCO 3.8.1.1, Details of the Class 1E 4160 volt buses

offsite power sources were replaced by a Rases ITS 5.5.14 1

LCO 3.8.12 simpler description for Operability and design features of the diesel generators

)

(DGs).

L i

3.8 LA2 SR 4.8.1.1.2.a Listing t

.ionals that may be used for the monthly DG start sufveillance.

Bases ITS 5.5.14

.3 3.8 LA3 SR 4.8.1.1.2.a.6 Surveillance to verify the DGs are aligned to the associated Emergency Safety Bases ITS 5.5.14

.2 Feature (ESF) buses.

3.8 LA4 SR 4.8.1.1.2.a.4 Details describing the engine conditions for the modified DG start surveillance.

-Bases ITS 5.5.14 3

3.8 LAS SR 4.8.1.1.2.f.2 Details of the single largest post-accident load each DG must be capable of Bases ITS 5.5.14 1

rejecting without incurring an engine overspeed trip.

t 3.8 LA6 SR 4.8.1.1.2.f.7 Details regarding the loading acceptance criteria for the first two hours of f.he DG Bases ITS 5.5.14 3

l 24-hour run surveillance.

I i

3.8 LA7 SR 4.8.1.1.2.f.7 Details regarding the voltage and frequency acceptance criteria for the DG 24-TRM

$50.59 3

SR 4.8.1.1.2.f.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months run and auto-start surveillances.

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3.8 LA8 SR 4.8.1.1.2.f.8 Details to ensure each DG loading is maintained within acceptable design rating.

UFSAR

$50.59 1

3.8 LA9 SR 4.8.2.1.2.b.2, Method for obtair'ing the 125-volt battery connechon resistance.

Bases ITS 5.5.14 3

i SR 4.8.2.1.2.c.3 l

.t I

f f

t Relocated Detail Types f

1 Details of System Design 3

Promdural Details for Meeting TS Requirements i

2 Desenption of Systern Operation j

(By)- Byron specific (Bw)- Braidwood speci*ic Byron and Braidwood 1

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O Table LA - Details Relocated from CTS Discussion CTS Description of New Control of Change Reference Relocated Details Location Process Type 3.8 LA10 SR 4.8.1.1.2.1, Surveillances to verify the cross-tie capability of the DGs to power the opposite

.TRM

$50.59 1

SR 4.8.1.1.2.j unit's ESF bus.

3.8 LA11 SR 4.8.1.1.2.f.13 Surveillance to verify the DGs lockout features prevent starbng only when TRM

$50.59 3

required.

3.8 LA12 SR 4.8.1.1.2.h Surveillances to clean the DGs fuel oil storage tanks and ta perform a pressure TRM

$50.59 3

test of portions of the diesel fuel oil system.

3.8 LA13 3.8.1.2 Achons, Achon to suspend crane OpenathEi with loads over the spent fuel pool when AC TRM

$50.59 3

3.8.3.2 Achons electrical power sources or buses are inoperable.

3.8 LA14 LCO 3.8.2.1.a.

Details defining the Operability of the DC electric sources, instrument buses, and UFSAR

$50.59 1

LCO 3.8.2.2, instrument bus inverters.

TRM

$50.59 LCO 3.8.3.1, 3.8.3.1 Achon b.

LCO 3'8.3.2.c 3.8 LA15 SR 4.8.2.1.2.f Details defining degradation of battery capacity Bases ITS 5.5.14 3

3.8 LA16 SR 4.8.1.1.2.g Details of Operability demonstration after modL ^ cris which could anect DG TRM

$50.59 3

u interdependence

,e Relocated Detad Types 1

Details of System Design 3

Proadural Details for Meeting TS Requirements 2 Desenption of System Operation (By)- Byron specific (Bw) - Braedwood speedic Byron and Braidwood 2

LA_TBL3.8

)

J Table L - Less Restrictive Changes to CTS i

Discussion Description ITS CTS Change of Change of Change Requirement R: f_f ;...;..:

Category ITS Section 3.8, Electrical Power Systems t

3.8 L1 The completion time for restoring multiple concurrent AC electnc source to Operable 3.8.1 Achons 3.8.1.1 Achons IV was revised from *72 hours from initial loss" to allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for the initial restorabon A and B b, d, and e and a separate tW.ng 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for restoring a subsequent inoperabihty, limited to a total of 6 days.

i l

3.8 L2 The requirement to verify tile other unit's A diesel generator (DG) is Operable when a 3.8.1 Action B 3.8.1.1 Achon

' ill unit-specific DG 5 inoperable was deleted since this backup source of power is not c.2 credited in any design basis event.

3.8 L3 With a DG inoperable, CTS requires that unless all required features that depend on 3.8.1 Achon B -

3.8.1.1 Achon c ill

[

the remaining Operable DG are also Operable, a unit shut down be a es.orced within t

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . STS was relaxed to require that the feature (s) supported by tha inoperable i

DG be declared inoperable if its redundant counterpart is inoperable such that the i

appropriate acbons for two divisions of a feature inoperable may be less restnchve

+

than an immediate shut down. STS also allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months rather than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to commence the actions dictated by the inoperable feature (s) in order to provide additional time for restoration.

3.8 L4 The completion bme for demonstrating the remaining DG Operable was relaxed from 8 3.8.1 Achon B 3.8.1.1 Action b IV i

hours to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in order to provide additional time to restore the inoperable DG to i

prevent a unit shutdowrt

(

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Less Restricte Change Categories I

Relayation tMCO requkements V

Relaxation of TR acceptance enteria l

It Relaxation of Aghtity VI Relaxatica of Survedlance Frequency i

til Reiszahn of Acnes requiremeri's VII Deleton of requirements redundant to regulation

~

IV Relaxatnn of ccmpWm time Vill Deleton of Surwnllanca requwements i

(By)- Byron specife (9w)- Brakiwood specth

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G Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS Change of Change of Change Requirement Requirement Category 3.8 L5 The frequency for performing the monthly DG surveillances was relaxed from testing SR 3.8.1.2, 4.8.1.1.2.a V!

one DG every 15 days to testing each DG every 31 days. Also, the elimination of the SR 3.8.1.3, staggered test basis for the 60 minute load test was replaced by the restriction that SR 3.8.1.4, only one DG be tested at a time.

SR 3.8.1.6 3.8 L6 Battery cell surveillance re auirements were relaxed such that 1) the specific gravity Tab!e 3.8.6-1 Table 4.8-2 V

need not be corrected fc" electrolyte level during float charge of < 2 amps,2) electrolyte level may temporari!y exceed the maximum level mark during equalizing charge, and 3) any of.he specific gravity limits may be satisfird if a cell's float charging current is < 2 amps.

3.8 L7 The frequency for removing any accumulated water from the DG fuel oil day tanks SR 3.8.1.5 4.8.1.1.2.b VI t

after each 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months run was deleted since it is unlikely that water would be transferred from the storage tank during this operation.

3.8 L8 For the DG single largest post-accident load rejection test, the acceptable voltage SR 3 8.1.9 4.8.1.1.2.f.2 V

band was applied to steady state conditions after the transient rather than during the transient because the transient voltage response is a secondary concem.

3.8 L9 The requirement to verify various DG functions on a loss of offsite power or SR 3.8.1.11, 4.8.1.1.2.f.4, V

Emergency Safety Feature (ESF) actuation test signal was changed to allow the use of SR 3.8.1.12, 4.8.1.1.2.f.5, i

an actual as well as a simulated actuation signal since Operability can be adequately SR 3.8.1.19, 4.8.1.1.2.f.6, demonstrated with either sigt:al.

SR 3.8.1.13, 4.8.1.1.2.f.6.c, SR 3.8.1.17 4.8.1.1.2.f.10 l

Less Restrictive Change Categones I

Relaxation of LCO requirernents V

Relaxaton of SR acceptance criteria il Relaxation of Appicability VI Re!axation cf Surveillance Frequency ill Relaxation of Action requirements VII Deleten of requirements redundant to regulation IV Relaxation of completion trne Vill Deletion of Survedlance requirements (By)- Byron specific (Bw)- Braidwood specife Byron and Braidwood 2

L_TBL3.8 i

s s

v Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS Change of Change of Change Requirement Requirement Category 3.8 L10 Surveillance to verify the capability to transfer fuel from the storage tank to the day N/A 4.8.1.1.2.f.11 Vill tank of each DG was deleted since this function is not necessary to ensure the Operability of the DGs.

3.8 L11 Various DG surveillances were relaxed by the addition of notes which allow that SR 3.8.1.3 4.8.1.1.2.a.5, V

momentary transiants outside the specified load ranges do not constitute a failure of Note 2, 4.8.1.1.2.f.7 the surveillance since these transients do not reflect an inabiiity of the DGs to fulfill SR 3.8.1.14 l

their safety-related functions.

Note 1, SR 3.8.1.i5 Note 2 3.8 L12 The requirement for the 10-year simultaneous start of both DGs to be performed SR 3.8.1.20 4.8.1.1.2.g V

during shutdown was deleted since this restriction is unnecessary to assure continued safe operation of the facility, t

3.8 L13 The requirement to verify the DG(s), upon starting, accelerate to a minimum SR 3.8.1.7 4.8.1.1.2.a.4, V

acceptable speed within 10 seconds was reduced from 600 rpm (equivalent to a SR 3.8.1.15, 4.8.1.1.2.g i

generator frequency of 60 Hz) to 58.8 Hz, at which point the permissive is met to close SR 3.8.1.20

{

the output breaker and accept loads.

i i

l Less Restrictive Change Categories i

Relaxation of LCO requirements V

Relaxation of SR acceptana criteria Relaxation of Applicabihty VI Relaxation of Surveillance Frequency Ill Relaxation of Action requirements VII Deletion of requirements redundant to regulation 1

IV Relaxation of completion tune Vill Deletion of Surveillance requirements t

r (By)- Byron specire (Bw)- Braidwood spectre Byron and Braidwood 3

L_TBL3.8

m Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS Change of Change of Change Requirement Requirement Category 3.8 L14 Because the condition "during movement of irradiated fuel assemblies" was added to 3.8.2 Actions 3.8.1.2 Actions, 111 the Applicability, a note was included that provides an exception to the requirements of Note, 3.8.5 3.8.2.2 Actions.

Specification 3.0.3. Without this exception a unit shutdown would be required if the Actions Note, 3.8.3.2 Actions LCO and associated actions are not met while moving irradiated fuel assemblies in 3.8.8 Actions Mode 1, 2, 3, or 4.

Note, 3.8.10 Actions Note 3.8 L15 The action to depressurize and vent the Reactor Coolant System (RCS) through at 3.8.2 Action A, 3.8.1.2 Actions, Ill least a 2 inch square vent when any of the required buses are inoperable was 3.8.5 Action A, 3.8.2.2 Action c, replaced with an action to declare affected Low Temperature Overpressure Protection 3.8.8 Action A, 3.8.3.2 Actions (LTOP) features inoperable. This change defers to a separate Specification for LTOP 3.8.10 Action A for the appropriate actions to assure the RCS is depressurized and vented when conditions dictate.

3.8 L16 Three surveillances were deleted from the list of surveillances required to be SR 3.8.2.1, 4.8.1.2, Vill performed for DG and offsite sources while shutdown. Surveillances testing the SR 3.8.2.1 Note 4.8.1.1.1.b, transfer of incoming offsite source from normal to attemate and the simultaneous start 4.8.1.1.2.f.10, of both DGs were deleted since only one of each of these power sources is required in 4.8.1.1.2.g these Modes. The DG test mode override surveillance was deleted since the DGs are i

not required to be tested paralleled to the grid in these Modes. Also, though the function Operability continues to be required, several survei!!ances are not performed in order to prevent a single event which could compromise both the required offsite and DG source.

l t

Less Restrictive Change Categories i

Relaxation of LCO requirements V

Relaxation of SR acceptance criteria g-11 Relaxation of Applicability VI Relaxation of Surveillance Frequency Ill Relaxation of Action requirements Vil Deletion of requirements redundant to regulation IV Relaxation of completion tirne Vill Deletion of Surveillance requirements Cy)- Byron specific (Bw) - Braidwood spectric Byron and Braidwood 4

L_TBL3.8 i

m Table L - Less Restrictive Changes'to CTS Discussion Description ITS _

CTS Change

' of Change of Change

. Requirement Requirement

. C: :; --,

3.8 L17 in establishing a new Specification for new and stored DG fuel oil requirements, times 3.8.3 3/4.8.1.1, IV were provided to restore the following conditions: 1) supply of < 7 days but > 6 days,2)

LCO 3.8.1.2.b.2 total particulates not within limit, and 3) other new fuel propertes not within limits.

These achons provide time to restore ronditions which, under current requirements,

[

would result in the DG being immediately declared inoperable.

3.8 L18 Not used.

3.8 L19 The frequencies for determining the minimum average electrolyte temperature within 7 SR 3.8.6.3 4.8.2.1.2.b.3 VI l

days after a battery discharge or overcharge were deleted since disd,&yes and overcherges of the specified magnitude increase rather than decrease the temperature. Also, the method for verifying the average electrolyte temperature was i

relaxed from measuring all connected cells to only representative cells.

}

3.8 L20 Not used.

3.8 L21 Not used.

l i-3.8 L22 Although the funchon Operability continues to be required, several surveillances -

SR 3.8.5.1 Note 4.8.2.2 Vill

[

required to be performed for the DC power subsystem in Modes 1,2,' 3. and 4 are not

[

performed while shutdown in order to prevent a single event which could compromise both divisions of DC power.

l

{

f Less Restncirve Change Catecones I

I Relaxation of LCO requirements V

Relaxation of SR acceptana crimna il Relaxation of Appiscatnhty VI Relaxation of Survemance Frequency ill Relaxation of Action requirements Vil Deletion of requirements redundant to regulation IV Relaxation of completion time Vlil Deletion of Surveslience n;g.;.

.-a.

I (By)- Byron speedic f

(Bw)- Braidwood specrfic

_t

.[

Byron and Braidwood 5

L TBL3.8 4

f

O O

Table L - Less Restrictive Changes to CTS

[

Discussion Description ITS CTS Change of Change of Change Requirement Requirement C _ ^:;:-y l

3.8 L23 In establishing a new Specification for battery cell parameter requirements, an 3.8.6 3/4.8.2.1 appropnate Applicability and Actions Note to allow separate Condition entry were included consistent with CTS intent.

i With Category A or Category B parameter (s) out of specified limits,. the completion 3.8.6 Acton A Table 4.8-2 111, IV i

times to restore the parameters was relaxed from a total of 7 days to 31 days since Notes 1 and 2 these parameters contain substantial margin for the batteries to perform their safety i

function. Also, an acton to verify, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the pilot cells' electrolyte level and float voltage is within Category C limits was incit ~xi so that the affected battery may be considered Operable provided the specified venfication and restoration actions are taken.

3.8 L24 A note was added to the DG full load rejecton test which states that momentary SR 3.8.1.10 4.8.1.1.2.f.3 '

V transients above the specafied voltage limit do not invalidate the test since a Note momentary voltage spike is expected, though usually undetected by plant instrumentaten, immediately following the load rejecten.

l 3.8 L25 The acceptance criteria for several surveillances to load the DGs to a 5500 kW(the SR 3.8.1.3, 4.8.1.1.2.a.5, V

DGs continuous rating) was relaxed in accordance with industry guidance to specify a SR 3.8.1.10, 4.8.1.1.2.f.3, loading band of 4950 kW to 5500 kW (90% to 100% of the continuous rating) to reduce SR 3.8.1.14, 4.8.1.1.2.f.7 I

wear on the DGs while still banding the maximum expected accident load.

SR 3.8.1.15

[

i i

Less Restrictive Change Categones f

I Relaxation of LCO requirements V

Relaxation of SR acceptance critens 11 Relaxation of Apphcability VI Relaxation of Survedance Frequency i

111 Relaxation of Action requirements Vil Deletion of requirements redundant to regulation

[

Relaxation of completion time Vill Deletion of Survemance requirements IV l

I I

(By)- Byron specific

[

(Bw)- Braidwood specific Byron and Braidwood 6

L_TBL3.8 1

i

v Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS Change.

of Change of Change Requirement Requirement Category 1

3.8 L26 The restriction for performing the manual transfer of power supply from the offsite SR 3.8.1.8 4.8.1.1.1.b VI circuit to the DGs "during shutdown" was removed since this surveillance may be satisfied while performing Station Auxiliary Transformer maintenance during power operation.

3.8 L27 The loading criteria for the first two hours of the DG 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months continuous run was SR 3.8.1.14 4.8.1.1.2.f.7 V

relaxed from 5900 - 6050 kW to 5775 - 6050 kW to correspond to 105 - 110% cf the I

continuous duty rating in accordance with industry guidance. The revised lower limit of the load band continues to represent loads greater than the maximum expected accident load.

i 3.8 L28 An action was included to address the situation of an inoperable DG and a bus with 3.8.1 Action D 3.8.1.1 Actions, Ill two required qualified circuits inoperable. The action allows continued operation 3.0.3 provided either the DG or the required qualified circuits are restored within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months since the Byron /Braidwood design includes a reserve qualified circuit to each AC electrical power division.

3.8 L29 The restrictions for performing the DG auto-start on an ESF actuation signal and the SR 3.8.1.12, 4.8.1.1.2.f.5, VI noncritical trip bypass surveillances "during shutdown" was removed since these SR 3.8.1.13 4.8.1.1.2.f.6.c j

surveillances may be satisfied during power operation by required post-maintenance testing or by a valid actuation signal.

i Less Restrictive Change Categories 1

Relaxation ofI.CO requirements V

Relaxation of SR acceptance enteria

!! Relaxation of Applicability VI Relaxation of Surveillance Frequency 111 Relaxation of Action requirements Vil Deletion of requirements redundant to regulation IV Relaxation of completion trne Vill Deletion of Surveillance requirements t

(By)- Byron specific (Bw)- Braidwood specific Byron and Braidwood 7

L TBL3.8

p p

~N G

v J

Table L - Less Restrictive Changes to CTS Discussion Description ITS CTS Change-of Change of Change Requirement Requirement Category 3.8 L30 The acceptance enteria for the average electrolyte temperature of the battery cells was SR 3.8.6.3 4.8.2.1.2.b.3 V

relaxed from "above 60*F' to "a 60*F" for consistency with manufacturer's recommendations and other considerations.

3.8 L31 The loading requi:ements for the monthly DG 1-hour run surveillance was relaxed to SR 3.8.1.3 4.8.1.1.2.a.5 V

provide flexibility in applying the manufacturer's recommendations for gradual loading Note 1 so that wear on the engine is reduced and reliability increased.

3.8 L32 (Bw)

The allowance to extend the frequency of the battery capacity test from 12 months to SR 3.8.4.8 4.8.2.1.2.f VI 24 months provided the battery delivers " greater than 100%* of the manufacturer's rated capacity was relaxed based on the capacity being "2100%" for consistency with industry standards.

f

?

Less Restrictive Change Categories 1

Relaxation of LCO requirements V

Relaxation of SR acceptance criteria il Relaxation of Applicability VI Relaxation of Survet!!ance Frequency 111 Relaxation of Action requirernents Vil Deletion of requirements redundant to regulation IV Relaxation of completion time Vill Deletion of Survedlance requhnts (By)- Byron specific (Bw)- Braidwood specrfic Byron and Braidwood 8

L_TBL3.8 F

ENCLOSURE 1 t O ITS REVISION L ITS SECTION 1.8 l

1 O

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ML20154A865

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