ML20199K468
| ML20199K468 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 01/23/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20199J034 | List: |
| References | |
| NUDOCS 9802060192 | |
| Download: ML20199K468 (10) | |
Text
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k UNITED STATES l
i pe NUCLEAR REGULATORY COMMISSION e
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WAsHINef oN, D.c. 3e806 4e01 l
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i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
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i RELATEDTO AMENDMENT NO. 98 TO FACILITY OPERATING LICENSE NO. NPF 37.
AMENDMENT NO. 98 TO FACILITY OPERATING LICENSE No. NPF 66.
AMENDMENT NO. 89 TO FACILITY OPERATING LICENSE NO. NPF-72.
E AND AMENDMENT NO. 89 TO FACILITY OPERATING LICENSE No. NPF-77
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COMMONWEALTH EDISON COMPANY BYRON STATION. UNIT NOS.1 AND 2 i
BRAIDWOOD STATION. UNIT NOS.1 AND 2 DOCKET NO8. 8TN 50454. 8TN 50455. STN 50456 AND STN 50457 j
1.0 INTRODUCTIDN By letter dated May 21,1997, Commonwealth Edison Company (Comed, the licensee) proposed i
changes to the technical specifications (TS) for Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2. The requested changes are the relocation of the pressure temperature (P/7) limit curves and low-temperature overpressure protection (LTOP) system limits to the Pressure and Temperature Limits Repor1 (PTLR) and the referencing of that report in the affected limiting conditions for operation and bases. The proposed changes also include the i
addition of the PTLR to the definitions section of the T8 and the addition of a new section to the reporting requirements in the administrativ& controls section of the TS delineating the necessary i
reports. Guidance on the proposed changes was developed by the Nuclear Regulatory i
- Commission (NRC) on the basis of a proposal by the owners groups during the development of E
I the improved standard technical specificahons (STS). This guidance was provided to all power F
reactor licensees and applicants by Generic Letter (GL) 96 03, dated January 31,1996, L
Comed supplemented the May 21,1997, submittal by letters dated November 18,1997, l
December 3,1997, January 8,1998 and January 13,1998, The January 8,1998 and i
January 13,1998, submittels provided additional clarifying information that did not change the Initial proposed no significant hazards consideration determination,-
in addition, as part of the methodology for developing the P/T limit curves, Comed submitted a
. request to integrate the reactor vessel surveillance programs for Byron, Units 1 and 2, and Brandwood, Units 1 and 2, by letter of May 6,1997, as supplemented in the December 3,1997, letter.
'2.0 - BACKGROSNQ Section 182a of the Atomic Energy Act (the Act) requires applicants for nuclear power plant e
operating licenses to include TS as part of the license. The Commission's, regulatory y
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2-I requirements related to the content of TR am set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories: (1) safety limits, limiting safety system
- settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance _
requirements; (4) design features; and (5) administrative controls, and states also that the Commission may include such additional T8 as A Ands to be appropriate. However, the regulation does not specify the particular requirements to be included in a plant's T8.
f 10 CFR 50.36 identifies four criteria to be used in determining whether a particular matter is j
required to be included in th9 T8, as follows: (1) installed instrumentation that is used to detect, i
and indicate in the control room, a significant a,bnormal degradation of the reactor coolant i
pressure bo'Jndary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design basis acc. dent or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experience or probabilistic safety assessment has show.'n to be significant to public health and safety. As a result, existing T8 requirements which fall whhin or satisfy any of these criteria must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other licensee contro'!9d documents.
3.0 EVALUATION All components of the reactor coolant system (RC8) are designcd to withstand the effects of cyclic loads resulting from system pressure and tempeh:.ture changes. These lodds are introduced by heatup and cooldown operations, power transients, and reactor trips. Ir accordance with Appendix G to 10 CFR Part 50 T8 limit the pressure and temperature changes during RCS heatup and cooldown within the design assumptions and the stress lim'*s for cyclic operation. These limits are defined by P/T limit curves for heatup, cooldown, LTOP, and -
inservice leak and hydrostatic testirig. Each curve defines an acceptable region for normal operation. The curves are used for operational guidance during heatup and cooldown maneuvering, when pressure and temperature indications are monitored and compared to the
-applicable curve to determine that operation is within the allowable region.
The licensee used the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) Case N-514 or the igg 6 Addenda to the ASME Code, and requested an exemption from Appendix G by justifying why Appendix G can not be met and demonstrating that a specific exemption was warranted under 10 CFR 50.12. The exemption to permit use of code Case N 514 was granted on November 2g,- igg 6, for Byron, Units 1 and 2; July 13, igg 5, for Braidwood, Unit 1; and December 12, igg 7, for Braidwood, Unit 2. The plants were granted an exemption to permit use of the 1996 Addende to the ASME Code on January 16,1998.
The licensee integrated the reaclor vessel weld metal surveillance program for Byron, Units 1 and 2, and for Braidwood, Units 1 and 2, pursuant to 10 CFR Part 50, Appendix H, Section Ill.C.
The data integration is consistent with 10 CFR 50.61 (c)(2), which indicates that licensees should consider information from related surveillance programs in assessing the embrittlement of their vessel. The lunitations on the data integration are specificled in the PTLR methodology that was approved by the NRC and documented by letter dated January 16,1998.
3-The LTOP system controls RC8 pressure at low temperatures so that the integrity of the reactor coolant pressure boundary is not compromised by violating 10 CFR Part 50, Appendix G. The LTOP system for pressure relief consists of power-operated relief valves (PORVs), residual heat removal (RHR) auction relief valves, or a combination of both. The LTOP system limns consist of PORV and RHR suction relief valve setpoints. The RHR suction relief valves do not have s
variable pressure and temperature lift setpoints like the PORVs and, therefore, are still addressed in the T8. The LTOP system is reevaluated each time the P/T limn ourves are revised to ensure that N meets Ms intended function.
I The licensee-proposed changas to the T8 are in accordance with the guidance in GL g6 03, as follows:
(1) ' The definitions secJon of the TS was modified to include a definition of the PTLR to which the figures, values, and parameters for P/T and LTOP system limits will be relocated on a unit specific basis in accordance with a methodology approved by the NRC that maintains the acceptance limits and the limits of the safety analysis. As noted in the definition, plant i
operation within these limits is addressed by individual specifications.
(2) The following specifications were revised to replace the P/T and LTOP system limits with a reference to the PTLR that provides these limits:
LCO 3.4.g.1, ' Pressure / Temperature Limits," and LCO 3.4.g.3, " Overpressure Protection Systems."
(3)
Specification 6 g.1.10, ' Reactor Coolant System Pressure and Temperature Limits Report,"
was added to the reporting requirements of the administrative controls s3ction of the TS.
This specification requires that the PTLR be submitted, upon issuance, to the NRC Oocument Control Desk with copies to the regional administrator and resident inspector.
The report provides the explanations, figures, values, and parameters of the P/T and LTOP -
system limits for the applicable effective period. Furthermore, this specification requires that the figures, values, and parameters be established using the methodology approved by the NRC for this purpose in the NRC letter approving a plant specific methodology as referenced in the TS and be consister t with alline applicable acce9tance limits and the limits of the safety analysis.
- Finally, the specification requires that all changes in values of these limits be documented in the PTLR oech effective period and submitted upon issuance to the NRC.
Relocation of the F,T curves and LTOP setpoints does not eliminate the requirement to operate in accordance wl'h the limits specified in Appendix G to 10 CFR Part 50. The requirement to operate within the limits in the PTLR is specified in, and controlled by, tle TS. Only the figures, values, and parameters associated with the P/T limits and LTOP setpoints are to be relocated to the PTLR; in order for the curves and setpoints to be relocated to a PTLR, a methodology for their de', alopment must be reviewed and approvsd in advance by the NRC. The methodology to be approved in, ihe NRC is to be developed in acco dance with GL g6-03.' This GL provides
. uidance regarding referencing the methodology and development of the PTLR including, but not g
limited to, the requirements of Appendix G to 10 CFR Part 50. Since the methodology is
- referenced in the TS, changes t tree methodology must be 6pproved by the NRC. Further, when 4
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4 changes are made to the figures, values, and parameters contained in the PTLR, the PTLR is to be updated and submitted to the NRC upon issuance.
On this basis, the NRC staff concludes that the licensee provided an soceptable means of establishing and maintaining the detailed values of the P/T limit curves end LTOP system limits.
- Further, because plant opt ration continues to be limited in accordance with the requirements of Appendix G to 10 CFR Part 50 and the P/T and LTOP system limits in the T8 will be established using a methodology approved by the NRC, these changes will not impact plant safety.
The staff also concludes that the above-relocated requirements relating to the P/T limits and LTOP system limits are not required to be in the TS under 10 CFR 50.36, and are not required to ubviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety. Accordingly, the staff concludes that the proposed changes are acceptable and that these requirements may be reloosted from the TS to the PTLR, A detailed discussion of the stats basis for acceptance of the licensee's proposed methodology is provided in the attached letter from R. Capra to O. Kingsley, " Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 Acceptance of Referencing of Pressure Temperature Limits
- Report (TAC Nos. M9879g, M98800, M98801 and M98802), dated January 21,1998.
During review of the proposed amendment, the staff identified the need for changes to TS 6.9.1.10. The changes which were made to improve the clarity of TS 6.9.1.10, were discussed with the licensee during a telephone conversation on January 22,1998. The licensee l
agreed with the stars suggested changes.
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4.0 STATE CONSULTATION
l In accordance with the Commission's regulations, the Illinois State official was notified of the pioposed issuance of the amendments. The State official had no comments.
5.0-- ENVIRONMENTAL CONSIDERATION The amendments change a requirement with respect to the Insta.llation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (62 FR 66394) - Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
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6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities wi.I be conducted in compliance with the Commission's rogdations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of ths public.
Attachment:
As stated Principal Contributor: 8 Bailey Date: January 23, 1998 l
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NUCLEAR RESULATORY COMMIS#lEN tanweweton, e.c. sess.mn January 21, 1998 Mr. Oliver D. Kingsley, President Attn.: Regulatory Servloes Nuclear Genemtion Group Commonwealth Edison Company Executive Towers West til 1400 Opus Place, SuNe 500 Downers Grove,IL 60515 SUSJECT: BYRON STATION, UNITS 1 AND 2 AND BRAIDWOOD STATION, UNITS 1 AND 2, ACCEPTANCE FOR REFERENCING OF PRESSURE TEMPERATURE LIMITS REPORT (TAC NUMBERS M98799, M98600, M98801, AND M98802)
Dear Mr. Kingsley:
REFERENCES:
1, Letter from R. R. Assa, NRC, to D. L. Farrar, CommonweWth Edison Company, " Exemption from Requirements of 10 CFR 50.00. Sraidwood Sistion, Uni; 1,' July 13,1995.
2.
Letter from C.1. Grimes, NRC, to R. A. Newton, Westinghouse Electric Corporation, " Acceptance for Referencing of Topical Report WCAP-14040, Revision 1 ' Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Umit Curves,'" October 16,1995. (Also known as WCAP.14040 NP A).
i 3.
Letter from G. F. Dick, NRC. to 1. M. Johnson, Commonwealth Edison i-Company, " Exemption from Requirements of 10 CFR 50.60, ' Acceptance j
Crtteria for Fracture Prevention Measures for Ughtwater Nuclear Power Reactors for Normal Operation' Byron Station, Units 1 and 2,'
j November 29,1996.
4, Letter from J. B. Hosmer, Commonwealth Edison Company, to NRC Document Control Desk, " Reactor Vessel integrated Surveillance 1
Program 10 CFR 50, Appendix H, Section Ill C,' May 6,1997.
(WCAP 14824, Revision 1 is Attached).
5.
Letter from J. B. Hosmer, Commonwealth Edison Company, to NRC Document Control Desk, ' Application for Amendment to Appendix A, Techn! cal Specifications, for Facility Operating Licenses Relocation of L
Pressure and Temperature Limits," May 21,1997.
r 6.
Letter from J. B. Hosmer, Commonwealth Edison Company, to NRC Document Control Desk, " Supplement to the Application for Amendman*
to Appendix A Technical Specifications, for Facility Operating Ucenses Relocation of Pressure and Temperature Limits," November 18,1997.
(WCAP 14940 and Errata b WCAP-14940 and WCAP 14970 are Attached).
1
Contact:
- Maggalean W. Weston, (301) 415 3151 i
i ATTA00ENT
Mr. OWyer D. Kin 0sley 2
January 21, 1998 7.
Letter from J. B. Hosmer, Commonweshh Edison Company, to NRC Document Control Desk, *Supplementalinformation Portainir9, to B Braidwood's Reactor Vessel Integrated Surveillance Pro 9 tam December 3,1997. (WCAP.14824, Revision 2, and Ern'um to WCAP.
14824 Revision 2 are Attached).
8.
Letter from G. F. Dick, NRC, to 1 M. Johnson, Commonweshh Edison Company,
- Exemption from Requirements of 10 CFR 50.00 Braidwood Nuclear Station, Unit 2,* Dooomber 12,1997.
9.
Letter from H, G. Stanley, Commonwealth Edison company, to NRC Document Control Desk,
- Supplemental information Pertaining to Technical Specification Amendment Regarding Pressure Temperature Curves. Byron and Braidwood Nuclear F,: wor Stations," January 8,1998.
(Ensta to WCAP.14824 Revislor.2, WCAP.14940 and WCAP 14970 are Attached),
10.
Lette %m H. O. Stanley, Commonwealth Edison Company, to NRC Docs
't Control Desk,
- Supplemental Information Pertaining to Technical Specification Amendment Regarding Pressure Temperature Curves. Byron and Braidwood Nuclear Power Stations,* January 13, 1998.
11.
Letter from G. F. Dick, NRC, to O. D. Kingsley, Commonwealth Edison.
Company, " Exemption from Requirements of 10 CFR 50.60. Byron Units i
1 and 2, and Braidwood, Units 1 and 2,* January 16,1998.
12.
Letter from R. A. Capra, NRC, to O. D. Kingsley, Commonwealth Edison Company,
- integration of Reactor Pressure Vessel Surveillance Program for Byron and Braidwood, Units 1 and 2,* January 16,1998.
We have completed our review of the pressure temperature (P/T) Jimit curves and low temperature overpressure protection (LTOP) system limits methodology and the pressure '
temperature limits report (PTLR) (as referenced above), submitted by the Commonwealth Edison Company (Comed). We find the methodology to be acceptable for referencing in the administrative controls section of the Byron Station, Units 1 and 2, and Broldwood Station.
Units 1 and 2, technical specifications (TS) to the extent specified and under the limitations -
delinesP,d in your submittals and the associated NRC safety evaluation, which is enclosed. The safety evaluation defines the basis for acceptance of the submittals. Our acceptance applies only to the matters described in the submittals.
The NRC reviewed Comed's method forintegrating the data from the reactor pressure vessel surveillance capsules as a part of the methodology for developing the P/T limit curves. While the -
staff finds the method acceptable, as stated in the safety evaluation, the NRC notes that Comed should (1) re-evaluate the appropriate method for determining the best-estimate chemical composition as additional chemical composition data become available, (2) assess the impact of the assumption that the vessel wold has the same RTecnu value as determined from the surveillance wold in future revisions to the PTLR and/or when additional surveillance data
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Mr. Oliver D. Kingsley 3
January 21, 1998 become available, and (3) address the method for essessing the credibility of the surveillance capsule data, including the method for accounting for irradiation environment and c',emical composition differences, in future revisions to the PTLR.
The methodology for review relating to the P/T limit curves and the LTOP system limits was provided in the references listed above. Reference 2 included WCAP 14040 NP A which c
provided parts of the methodology used for determining the acceptance of the Byron and Braidwood methodology.
4 The methodology in WCAP 14040 NP-A, along with supplements provided by Comed will be used to calculate future changes to the P/T limM curves and LTOP system limits. Comed may generate new P/T 16mn curves and LTOP system limits in accordance with this methodology without prior approval of the staff. Howsver, changes to the methodology must first be reviewed j
and approved by the staff. System limits may be subject to audit by the staff through inspections as necessary.
1 i
We do not intend to repeat our review of the matters described in the submittels if the sub nittels appear as references in other license applications relating to you ;! ants, except to ensure that the material in the submittals is still applicable to your plants as indicated in the conclusion section of the safety et aluation.
Should our criteria '.< regulations change so that our conclusions as to the acceptability of the methodology is invalidated, licensees referencing these documents will be expected to revise and resubmit their respective documentation, or submit justification for the continuer' effective applicability of the documents without revision of their respective documentation.
Sincerely, V s> U G. f y ]
Robert. A. Capra, Director Project Directorate 1112 Division of Reactor Projects lil/IV i
Office of Nuclear Reactor Regulation i
Docket No. 8TN 50-454, STN 50 455 STN 50-456 and STN 50 457
Enclosure:
Safety Evaluation oc w/end: See next page i
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O.Minosley eyewarniewood siemens Commonweem m %
January 21, 1998 OC.
Mr.WImam P. Poirler, Director Amomer General i
Wesenghouse Electric Corporaton 500 8.Second Street Energy systems Businese Unit spetngleid,innois 82701 Post Ofiloe Sox 355, Boy 238 W.
Plantaph,Penneyhenie 15230 Pinois Department of Nucieer Safety i
ollke of Nucieer Fact'ty safety i
Joseph Gallo 1035 Outer Park Dr6ve Gallo & Ross Springleid,tunois 82704 1250 Eye St. N.W., Subo 302 WeeNngton, DC 20005 Commonwoollh Edenn Company byron stenon Meneoer MichaelL MNier, Esquire 4450 N. German Church Rised i
Sidley and Austin Byron, Illinois $10104794 One First National Plate Chloe0o,innois 80603 Commonwoolth Edson Company Site Vlos President. Dyron Howard A. Lemmer 4450 N. German Church Road i
Erwironmentallaw and Policy Byron, Illinois 61010 8794 Center of the Mdwest 203 H. LaSalle St. Seilte 1890 U.S. Nucieer Regulatory Commiselon i
Chloe00.tilinois 60601 Braidwood Roaldent inspectors ofRoe RR 1, Box 70 i
U.S. Nuclear Regulatory Commiselon tracewme, Illinois 80407 l
Byron Residentinspectors ofRee 4448 N. German Ch irch Road Mr. Mon Stephens Byron, Illinois 81010-9750 llEncis Emer0ency Services I
and Disaster Agency Regional Administrstor, Region lli 110 E. Adame Street U.S. Nuclear Ro0ulatory Commlesion SprineSeld,lilinois 62706 4
801 Warrerwille Road l
Lisle, Illinois 60532-4351 Chairman Will County Board of Supervisors j-Ms. Lorraine Creek WillCounty Board Courthouse j
RR 1, Box 182 Jolet,INinois 80434 Monteno,lilinois 60950 Commonwealth Edison Company Chelrman, Ogle County Board traidwood 8tetion Manaper i
Post Oftco Box 357 RR 1 Box 84 0.ogon, Illinois 81061 Braceville,innois 90407 l-Mrs. Phimp B. Johnson Ms. Bridget unie Rotem 1907 Stretford Lane Appleseed Coordinator Rockford,Innois 81107 117 N. Unden Street i
Essex, Illinois 60935 George L Edgar Morgen, Lewis and Bochs Document ControlDesk Uooneing i
1800 M Street. N.W.
Commonwealth Edison Company Washin0 ton,DC 20036 1400 Opus Place, Sulle 400 Downers Grove, Illinois 60515 i
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Dyrontreldwood Stolons January 21, 1998 Commonwealth Edson Company See Moe President Breldwood RR 1. Box 84 traoessie.L tWO407 W.hechselJ. Walloos Nuclear Serviose Senior Vlos Preelsent Commonwealth Edison Company Emoougve Towers West til 1400 Opus Piece, Sulle 900 Downers Grove, L 00515 Mr. Gene H. Stanley PWR's Moe Proeident Commonwealth Edison Company Enoculke Towers West til 1400 Opus Place, Sulle 900 Downers Grove, L 00515 Mr.SlovePony BWR's Vice President Commonwealth Edison Company Execu#ve Towers West 111 1400 Opus Place, Suite 900 Downers Grove, L 60515 Mr. Dennis Ferrer Regulatory Serv 6ces Manager Commonwealth Edison Company ExecuWve Towers West 111 1400 Opus Place, Sulle 500 Dcwners Grove, L 60515 Ms. Irone Johnson, Ucensing Director l
Nuclear Regulatory Services Commonwealth Edison Company Execullve Towers West til 1400 Opus Place, Suite 500 Downers Grove, L 90515 Commonwealth Edison Company Reg. Assurance Supervisor - Breldwood RR 1. Box 79 Braceville, Illinois 90407 C&TTw,c..;;lth Edison Company Reg. Assuram Supervisor-Byron 4450 N. German Church Road Byron, Illinois 81010-8794 l