Text

Forwards Response to RAI Re Improved TS Sections 3.0,3.7 & 3.9.RAI Contained Questions & Comments Re Util Request to Amend Current TS in Order to Adopt Improved TS of NUREG-1431,Rev 1
	ML20202A928
Person / Time
Site:	Byron, Braidwood
Issue date:	01/27/1998
From:	Tulon T; COMMONWEALTH EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	RTR-NUREG-1431 NUDOCS 9802110025
	Download: ML20202A928 (73)
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January 27,1998 United States Nuclear Regulatory Commission I i

Attn: Document Control Desk Washington, D. C. 20555 i

Subject:

Byron Nuclear Pcwer Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos 50-454 and 50-455 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Nos 50 456 and 50-457 i

Response to Request for Additional Information for ITS Sections l

3,0, 3.7, and 3.9.

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References:

(1) R. Assa (NRC) to i. Johnson (Commonwealth Edison) letter dated l December 5,1997. 1 (2) G. Stanley and K. Graesser (Commonwealth Edison) to NRC letter dated December 13,1996.

The purpose of this letter is to transmit Commonwealth Edison's (Comed's) response to the NRC's request for additional information (RAI) for Improved Technical Specifications (ITS) Sections 3.0,3.7, and 3.9. The responses to the RAI questions are contained in Attachment 1.

The RAI contains questions and comments stemming from the NRC's partial review of a Comed request (Reference (2)) to amend the Current Technical Specifications (CTS) for Byron Units 1 and 2 and Braidwood Units 1 and 2. The amendments were requested in order to adopt the Improved Technical Specifications of NUREG 1431, Revision 1.

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t U.S. Nuclear Regulatory Commission i January 27,1998 I As discuu i with NRC Staffin an August 12,1997 teleconference, this submittal does not include any replacement or CTS Markup pages. The required page changes and ,

3 markups will be submitted at a later date when the NRC review and acceptance of -

l Comed's Response to this NRC RAI is complete.

- Please address any comments or questions regarding this matter to our Nuclear Licensing j- Department /

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Sincerely, t othy J.Tulon ite Vice President Braidwood Nuclear Generating Station l

Attachment 1:- Response to NRC RAI Report i

cc: Regio .al Administrator - Region III, NP.C Byron Project Manager - NRR Braidwood Project Manager- NRR

! Senior Resident Inspector - Braidwood Station 2

Senior Resident inspector - Byron Station -

Oflice of Nuclear Safety - IDNS e

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s Attachment i Response to NRC RAI Report on the Comed ITS Submittal l

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Response to NRC RAI Dated 12/05/97 27 Jtn.9s bMC RAI Number . NRC Issued Date RAI Status

-3.0-01 12/5/97 Open- NRC Action Required i

NRC Description of Issue 3.041 DOC LAl CTS 3.0.5 and 4.0.6__

Doth Byron and Braidwood arc dual unit sites; therefore, CTS 3.0.5.a and b are essential to understanding how the LCOs, in the CTS and now in the ITS, apply equally or individually to cach unit.' The STS was developed based upon a single unit site.- The adaption of the STS to a multiple unit site occurs during this conversion uhich strives to maintain the i

' current licensing basis of the CTS. CTS 3.0.5 and CTS 4.0.6 must be retained as written except for CTS 3.0.5.c which must delete " footnotes". This is because the STS only permits Notes in the body of the requirements. Comment: Identify all Unit I and 2 shared systems or sharci sup[ sorting systems to the ITS LCOs. DOC LAI must be rewritten as an administrative change to retain US 3.0.5 and CTS 4.0.6.

Comed Response to Inn No change. The Byron / mood submittal is consistent with the submittals of other dual unit sites which do not retain the CTS LCO and SR pertaming to dual unit applicability.. Comed believes that DOC 3.0 LAl adequatelyjustifics relocating this information to the TRM. The ITS LCOs and Bases provide adequate clarification of dual unit operating requirements, restrictions, and exemptions. Comed continues to pursue this change.

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Response to NRC RAI Dated 12/05/97-. 27 Jrn-98 i: NRC'RAI Number NRC Issued Date RAI Status 3.0-02 12/5/97 Open NRC Action Required NRC Description of Issue 3.0-2 -JFD BPI-Bases for ITS Section 3.0 The following proposed editorial differences between the STS and ITS Bases are not accepted because they are no clearer than the STS wording and in some cases change the meaning.

Page B 3.0 2 and LCO 3.0.2

+ "In this instance," replaces "where this is the case" e

"and the new LCO is not met" is added

"new" replaces " associated" Page B 3.0 3 and LCO 3.0.3 e

_"no single Condition or combination . . that corresponds" replaces "no combination ... that exactly corresponds"

. warranted. In such cases, the Conditions corresponding, to such combinations state that LCO 3.0.3 shall be entered" replaces ". . warranted, in such cases, the ACTIONS l

specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered" l

. "LCO" replaces " Specification"

' Page B 3.0 4 and LCO 3.0.3

" remedial measures" replaces " appropriate remedial measures" Page B 3.0-5 and LCO 3.0.4

"different MODE" replaces " MODE" Page B 3.0-6 and LCO 3.0.5

"LCO" replaces " Specification" Page B 3.0-8 and LCO 3.0.6

. " systems' Conditions . ." replaces " systems' LCOs' Conditions . "

Page B 3.013 and SR 3.0.3

. " delay period" replaces " time limit" Page B 3.013 and SP 3.0.3

. " c MODE changes imposed by Required Actions or a reactor trip " replaces " , MODE changes imposed by Requited Actions."

- Comment: These differences are not justinabic on a plant-specific or editorial basis. Revisc the Bases for ITS Section 3.0 to adopt the STS language for the cases listed.

Comed Response to Issue No change. In comparmg Comed's proposed Bases editorial differences, the only changes are wording preferences which are strictly editorial. There is no technical or operational benefits gained in using the STS wording. Comed has made these changes to provide consistency throughout ITS, and to reflect NUREG philosophy and terminology. Comed elects to maintain our current wording, and continues to pursue this change.

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Respons t2 NRC RAl D:ted 12/05/97 27.nn-98

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NRC RAI Number NRC Inued Date RAI Status 3.0 12/5/97 Open - NRC Action Required NRC Description of Issue 3.0-03 JFD BC2 Bases for ITS LCO 3.0.1 Proposed differences from the Bases for STS LCO 3.0.1 are based on TSTF-08, Rev.1. Hov.crer, this STS generic change proposal was superceded by TSTF-08, Rev. 2, which :he NRC approved on 8/20/97. Commelt: Resise the Bases for ITS LCO 3.0.1 to coulorm to the Bases foi J s LCO 3.0.1 as modified by TSTF-08, Rev.1.

ComFd Response to Issue TSTF 8, Resision 2, will be incorporated, and Bases JFD 3.0-C2 will be resi,ed to state, "This change is consistent with NUREG 1431, as modified by TSTF 8, Resision 2. This change will be provided in our comprchensive ITS Section 3.0 eloscout submittal resision upon NRC's concurrence with the comed Responses to the ITS Section 3.0 RN NRC RAI Number NRC Issued Date RAI Statui 3 0-04 12/5/97' Open - NRC Action Required NRC Description of Issue 3.0 4 JFDs P1 and C5 JFDs BC7 and P2 l ITS LCO 3.0.4 l Bases for ITS LCO 3.0.4, STS Bases . markup page B 3.0-6 l

(1) The last sentence of the first paragraph ofITS LCO 3.0.4 and the last sentence of the paragraph at the top of the

('N referenced page in the STS Bases markup differ from the STS, as follows. In the LCO, the ITS omits the words "or that

\] _ are part of a shutdown of the unit," in the Bases the ITS replaces the phrase "any unit shutdown" with "a shutdown performed in response to the expected failure to comply with ACTIONS." These differences are based on TSTF-103, w hich has not yet been approved ty the NRC. Comment: Revise the submitta' to adopt the STS wording.

L (2) The ITS replaces the next to last paragraph in the Bases for STS LCO 3.0.4 with a paragraph proposed by TSTF 103.

f - Becau~: there are no Mode restrictions proposed for LCO 3.0.6 in the ITS, nicther of these paragraphs are needed. They should both be omitted. Comment: Resise the Bases to omit the p,r,agraph described.

Comed Responsc to issue No change. As discussed in LCO JFD 3.0-PI, this change it consistent with the current licensing basis of the plant and consistent with the requirements denoted in the Reviewer's Note in NUREG-1431, as modified by TSTF-103.

. Incorporation of the Staft's comment is not a justifiable change. Comed continues to pursue this change.

NRC RAI Number NRC Issued Date R AI Status 3.0-05 12/5/97 Open - NRC Action Required NRC Description of Issue 3.0-05 JFD C3 JFC DC5 ITS LCO 3.0.5 ITS LCO 3.0.5 differs from STS LCO 3.0.5 because it incorporates wording changes based on TSTF-01, Rev.1. NRC rejected this STS generic change proposal on 9/16/96. Comment: Resise the submittal to adopt STS LCO 3.0.5.

Comed Response to issue Comed will withdraw TSTF-1, Revision 1. This change will be prosided in our comprehensive ITS Section 3.0 closcout

'\ submittal resision upon NRC's concurrenn with the Comed P.csponses to the ITS Section 3 0 RAI.

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Response t3 NRC RAI Dated 12/05/97 27-Ja>98 NRC RAI Number NRC Issued Date RAI Status 3.0-06 12/5/97 Open- NRC Action Required NRC Description of Issue 3.0-06 JFD C3 (7)

JFD BC10 ITS LCO 3.0.6 Bases for IL - 9.0.$

The ITS replaces the STS words " testing required" with "rcquired testing" in LCO 3.0.6. It could not be determined which JFD applies to this difference, in addition, the ITS reolaces the STS term "SR" with "rcquired testing" in several places in the Bases for LCO 3.0.5. In one case in the Bases, the ITS replaces the STS phrase " allowed SRs" with "rcquired testing to demonstrate Operability." These differences from the STS Bases are based on not-approved-by-the-NRC WOG-77, which is referenced by JFD BClo. Comment: The term "rcquired testing" is not defined and could be construed to mean testing other than required by TS. The existing language in the STS is clear. Resise the Bases to adopt the STS wording.

Comed Response to issue The changes to the Bases were made in accordance with WOG-77 which was approved by the Staff as TSTF 165. TSTF-1, Resision 1, which made the corresponding changes to the LCO, was rejected. Therefore, for consist:ncy with the l approved Bases changes, Comed will pursue the LCO changes on a plant specific basis. In addition, Bases JFD 3.0-C10 I will replace "WOG-77" with "TSTF 165 "

NRC RAI Number NRC issued Date RAI Status 3.0-07 12/5/97 Open-NRC Action Required l

NRC Description of Issue 3.0-07 JFD C8 O ITS LCO 3.0.6 In the first paragraph of LCO 3.0.6, t'. ITS replaces the STS phrase " additional evaluations and limitations may be required" with "an evaluation sat A performed." This difference is based on not-approved-by the-NRC WOG-78.

Comment: STS LCO 3.0.6 is an industry creation and should be adopted as written. Revise ITS LCO 3.0.6 to conform to the STS wording.

Comed Response to issue

- The changes to the Bases were made in accordance with WOG-78 which was approved by the Staff as TSTF 166. In Mdition, LCO JFD 3.0-C8 will replace "WOG-78" with "TSTF-166." Comed continues to pursue this change.

NRC RAI Number NRC Issued Date RAI Status 3.0-08 12/5/97 Open - NRC Action 2equired NRC Description of Issue 3 0-08 Bases for ITS LCO 3.0.6

- The Bases of LCO 3.0.6 in NUREG-1431, Rey,1, has been revised with an example illustrating the application of the Safety Function Determination Program. This resision was based on TSTF-71, Resision 1, approved by the NRC on 10/2/97. The Bases for ITS LCO 3.0.6 did not propose to adopt this STS generic change. Comment: Resise the Bases for ITS LCO 3.0.6 to incorporate TSTF-71, Revision 1, since it has been approved.

Comed Response to issue The Bases will be resised to incorporate TSTF-71, Revision 1. This change will be provided in our comprehensive ITS

. _ _ . .Section 3.0 closcout submittal revision upon NRC's concurrence with the Comed Responses to 'he ITS Section 3.0 RAI.

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- Respons: t3 NRC RAI Dated 12/05/97 27 Jar-98 NRC RAI Number NRC issued Date RAI Status h

tQ 3.0 09 12/5/97 Open - NRC Action Required NRC Description of issue 3.0 09 JFD BPI Bases discussion of LCO 3,0.7 STS markup page B 3.0-9 in the second paragraph, the deletion of The second sentence, " Compliance with Test Exception LCOs is optional." is not adopted Comment: Ttis s not a justifiable plant specific or editorial difference. Revise the submittal to adopt this sentence.

Comed Response to Issuc Com Ed will adopt the scrtence. This ck nge will $c provided in our comprehensive ITS Section 3.0 closcout submittal resision upon NRC's conct.nence with the Comed Responses to the ITS Section 3.0 RAI, (Correction Note: The word

" deletion" in the NRC Description ofIssue should be " addition.")

NRC RAI Number NRC Issued Date RAI Status 3.0 10 12/5/97 Open - NRC Action Required

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NRC Description of Issue 3.010 JFD P2 '

JFD BP5 (and reference to NRC rejected TSTF 4 I) l ITS LCO 3.03 and as:ociated Bases ITS proposes to replace the STS term " Test Exception LCOs" with "Special Exception LCOs" in one place in the Bases for ITS LCO 3.0.7, and with " Exception LCOs" ciscwncre in LCO 3.0.7 and the associated Bases. JFD P2 basis this dilTerence on consistency with TSTF-41, which the NRC has rejected, and an apparent need to expand the provisions of b LCO 3.03 to apply "to more than testing such as special tests and operations." Comment: STS generic change proposal i TSTF 4 I was rejected by the staffon 5/8/97. Revise ITS LCO 3.0.7 and associated Bases to conform to the STS.

Comed Response to issue The word "Special" in the Bases Markup for LCO 3.0.7 will be deleted. The reference to TSTF-41 in Bases JFD 3.0-P5 will be deleted. Comed continues to pursue this change asjustified in LCO JFD 3.0-P2 and Bases JFD 3.0-P5.

(Correction Note: Bases JFD 3.0-P5 references TSTF 41, not JFD 3.0-P2.)

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-3 Response to NRC RAI Daied 12/05/97 27 Jtn 9I~~

- NRC RAI Number NRC lessed Date RAI Status 3.0 11 12/5/97 - Open - NRC Action Required NRC Description of Issue

. 3.011 JFD BC6 Bases for ITS SR 3S.2 The third paragnph of the STS Bases for STS SR 3.0.2 presents en example of a surveillance for which the allowance to ex;cnd the specifiej Frequency by 25% would not be permitted (a contaimnent leakage rate testing surveillance). STS

. generic change proposal TSTF 52 revises this example consi:. tent with the adoption of Option B to Appendix J and the !

creation of an STS administrative controls prograiamatic requirement, the Centainment Leakage Rate Testing Program.

The ITS proposes to adopt the STS changes proposed in TSTF.52. Comment: Staff has not yet approved TSTF 52. In addition, the proposed change to the Bases obscurcs the point trying to be made - the reason the 25% allowance does not apply. _ Revisc the submittal consistent with the plant specific resolution ofissues related to adopting Option B, but make L sure the Bases clearly explain uhy the 25% allowance does not apply to the suncillance described in the exampic.

Comed Response to lanue in the Bases foi SR 3.0.2, to clarify the rea.on that the 25% cxtension does not apply, Comed will retain the portion of TSTF 52 which deleted, "The requirements of regulations take precedence over the TS. The TS cannot in and of themscives extend a test interval specified in the regulations?

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Response to NRC RAI Dated 12/05/97 27 J:n 9s

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NRC RAI Number - NRC issued Date RAI Status 3.7.1 01 12/$/97 Open NRC Action Required NRC Description of Issue 3.7.1 1 DOC A.I DOC A.3 DOCL.1 JFD B.1 JFD B.2 I JFD B.22 JFD C.3 JFD Bases B.1 JFD Bases B.21 JFD Bases C.2 JFD Bases P.1 CTS 3.7.1.1 CTS 3.7.1,1 ACTIONS CTS Table 3.7 1 STS LCO 3.7.1 STS 3.7.1 ACTION A STS 3.7.1 TABLE 3.7.1. l l

ITS LCO 3.7.1 ITS 3.7.1 ACTION A ITS 3.7.1 TABLE 3.7.l land Associated Bases CTS 3/4.7.1.1 has been modified by a number of changes designated as A.3< These changes were approved by the Staffin

. Amendment 79 for Braidwood and Amendment 87 for Byron dated 4/15/97. CTS 3.7.1.1, and its associated ACTION b statements as modified by the approved A.3 and CTS TABLE 3,71 have been further mcdified to reflect the changes made to STS LCO 3.7.1, STS 3.7.1 ACTION A and STS 3.7.1 TABLE 3//.l.1 by WOG-83. These changes are designated as A.1 and L.I in the CTS markup and B l., B.2, B.22, C.3, Bases B.1, Bases B.21, Bases C.2 and Bases P.I .

in the ITS markup. WOG-83 has not been submitted to the staff by the Owner's Group for review and is thus, considered to be a beyond scope of review item for this conversion. Comment: Delete this generic change, revise the CTS and STS/ITS markups to either reflect the cut rent CTS as modified by A.3 or the STS, and provide the appropriate discussions andjustifications for the changes Comed Response to lasue No change. Comed disagrecs. The STS added requirements to verify that the MSIVs and MFIVs be verified to be closed once every 7 days. In the CTS, both the MSIVs and MFIVs appear in the Containment Isolation Valve ( 'lV) Table. This is current licensing basis and therefore, acceptabic. The sebject valves were considered the same unless specifically noted. Based on the NUREG, these valves have been broken out into their own Specifications. In applying these new STS Specifications and forming the ITS, it was noted that the closure verification times of these valves were reduced from once every 31 days to once every 7 days. Comed supported the industry generic change TSTF-102 which changed the 7 day verification time. In addition, Comed added a statement, "The MSSVs also serve as containment isolation Valves

. (CIVs), however the CIV function is addressed in LCO 3.6.3, " Containment Isolation Valves."" Thisjustification will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. This statement is being maintained in the Bases since it does not change any technical information or intent as provided by NUREG 1431. This change does not alter any Re, . ired Actions, Completien Times, or Surveillance Testing frequencies. The only intent of his change is to provide a more accurate description of bon 'he Byron and Braidwood plant designs and to better assi(srthe operators in locati Although part of me TSTF, the human factors benefit and enhancement obtained from this changejustifies it being pursued on a plant specific basis.

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Response ta NRC RAI Dated 12/05/97 27 Jin-98

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NRC RAI Number NRC Issued Date RAI Status 3.7.1 02 12/5/97 Open NRC Action Required NRC Description of lasue 3.7.12JFD Bases C.4 STS B3.7.1 Bases BACKGROUND ITS B3.7.1 Bases - BACKGROUND ITS B3.7.1 Bases BACKGROUND modifies STS B3.7.1 Bases - BACKGROUND in accordance with TSTF-44 Revis'on

1. TSTF-44 Rev. O was rejected by the staff and TSTF-44 Resision I has not been submitted for staff review. Thus this change is considered a beyond scope of resiew item for this conversion. See item Number 3.6.3 1. Delete this generic change.

Comed Response to issue No change Comed disagrees that the paragraphs added to the Background and Applica51c Safety Anansis Sections of the Bases for LCO 3.7.1 are beyond scope. The CIV function of the MSSVs is addressed by LCO 3.6.3 in bcth CTS and ITS.

One of the several changes TSTF-44 proposed, provided additional information in Bases B.3.7.1. The specific statements Comed added were, "The MSSVs also scric as Containment I;olation Valves (CIVs); however, the ClV function is addressed in LCO 3.6.3, " Containment Isolation Valycs"," and "The MSSVs are also credited as CIVs (refer to LCO 3.6.3)." These statements are being maintained in the Bases since they do not change any technical information or intent as provided by NUREG 1431. The changes do not alter any Required Actions, Completion Times, or Surveillance Testing Frequencies. The only intent is to provide a more accurate description of both the Byron and Bn.idwood plant designs and to better assist the operators in locating assocated LCOs. Although originally part of TSTF 44, the human factors benefit and enh9ncement obtained from these changesjustifies them being pursued on a plant specific basis, Bases JFD 3.7-C4 will be deleted and a 'P' Bases JFD created tojustify these changes. Comed continues to pursue this change. (See RAI t

3.7.4 3.)

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Q NRC RAI Number 3.7.1 03 NRC Issued Date 12/$/97 RAI Status

- Open - NRC Action Required NRC Description of Issue 3.7.1 3 None STS B3.7.1 Bases - LCG ITS B3.7.1 Bases - LCO ITS B3.7.1 Bases SR 3.7.1.1 ITS B3.7.1 Bases - LCO relocates the third paragraph of STS B3.7.1 Bases - LCO which states "The lift settings, . and -

pressure" to ITS B3.7.1 Bases SR 3.7.1.1, Nojustification is provided for this generic change. Comment: Delete this genenc change or provide a discussion andjustification for the relocation based on current licensing basis, system design or operational constraints.

Comed Response to Issue Comed will develop a 'P' Bases JFD to describe moving the third paragraph of the LCO Section of the Bases to the end of the second paragraph of the Bases for SR 3.7.1.1 in the Surveillance Reqmrements Section of the Bases for LCO 3.7.1.

- This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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Response to NRC RAI Dated 12/05/97 27 Jan-98 NRC RAI Number NRC issued Date RAI Status 3.7.2-01 12/5/97 Open NRC Action Required NRC Description of hsue 3.7.2 IDOC A.2 DOC A.10 DOC M.2

] DOC L 6 DOC L 7 JFD C.6 JFD C 8 JFD Dases D.2 i JFD Bases C.7 JFD Dases C.8 CTS 3.7.1.5 ACTIONS STS 3.7.2 ACTIONS and Associated Bases ITS 3.7.2 ACTIONS and Associated Bases CTS 3.7.1.5 ACTIONS have been modified by a number of changes designed A 2. A.10, M.2, L 6, L7 to reficct the changes made to STS 3.7.2 ACTIONS and Associated Bases by TSTF 102 and WOG-64. These changes are designed C 6 and Bases C.7 for TSTF 102 and C.8, Bases B.2 and Bases D.8 for WOG-64. TSTF-102 has been rejected by the sta!T u hile it is our understanding that WOG-64 has been withdrawn. Comment: Revise the CTS /ITS markups to delete these generic change and provide the appropriate CTS /ITS markups to reficct the CTS or the STS. Provide any additional discussions and justifications for the changes.

Comed Response to Issue Comed will revise the ITS submitial to delete the changes proposed by TSTF 102. However, WOG-54 is under TSTF G consideration and Comed continues to pursue the change on a plant specific basis. WOG-64 was created for consistency with the changes to NUREG LCO 3.6.3 (CIVs) Condition C for extending the Completion Time to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change was approved by the NRC in TSTF-30, Revision 2, in May 1997. The justification is that the MSIVs fall into the same classification of valves that NUREG LCO 3.6.3 Condition C valves tall into. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concarrence with the Comed Responses to the ITS Section 3.7 RAl.

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NRC RAI Number NRC Issued Date RAI Status 3,7.2-02 12/5/97 Open - NRC Action Required NRC Description of Issue 3.7.2 2 DOC A.10 CTS 3.7.1.5 ACTION - MODE 1 ITS 3.7.2 ACTION D CTS 3.7.1.5 ACTION MODE I requires (nat if one MSIV cannot be restored to OPERABLE status in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , then be in HO'l STANDf5Y (MODE 3)in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in llOT SHUTDOWN in another 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ITS 3.7.2 ACTION D only requires the unit in MODE 2 for one inoperable MSIV not restored within the Completion Time. This is not an administrative change as identified by A.10 but a less restrictive change. Coiament: ' evise the submittal, provide additional discussion and technical justification for this Less Res:rictive change.

Comed Response to issue No change. Comed (lisagrees CTS 3.7.1.5 " Action for MODE 1" requires that if one MSIV cannot be restored to OPERABLE status in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months then action must bc taken to place the unit in HOT STANDBY (MODE 3) in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Once the unit reaches MODE 2, CTS 3.7.1.5 " Action for MODES 2 and 3" allows subsequent operation in MODE 2 or 3 9 provided the MSIV is closed Otherwise, the unit must continue shutting down in accordance with the Action for MODE

1. Comed continues to pursue tlus change.

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R:sponse to NRC RAI Dated 12/05/97 27-JtnitI NRC RAI Number NRC l'oued Date - RAI Status 3.7.2 03 12/5/97 Open-NRC Action Required

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NRC Description of Issue 3.7.2 3 DOC M.3 JFD P.6 JFD Bases P.7 CTS 4.7.1.5

- STS SR 3.7.2.1 ITS SR 3.7.2.1

- ITS SR 3.7.2.2 and Associated Bases l CTS 4.7.1.5 requires the verification of full closure of each MSIV in 5 seconds u hen tested in accordance with CTS 4.0.5.

l The equivalent STS SR for this CTS requirement is STS 3.7.2.1. The ITS markup breaks STS SR 3.7.21 into two SRs -

ITS SR 3.7.2.1 (verification of closure is 5 seconds) and ITS SR 3.7.2.2 (verification of closure by actual or simulated signal). The justification for this change (9.6) is that if the valve fails the closure time SR, there is no need to perform a full actuation tes.t (ITS SR 3.7.2.2) since closure iime can be measured without this test. This change is considered to be a generic change which is beyond the scope of review for this conversion. See item Number 3.7.3 2. Comment: Delete this generic change.-

! Comed Response to luuc

{. No change. Comed disagrees that this is a beyond scope change since it does not change any technical requirements,

( testing procedures, or isolation times supporting the UFSAR anelysis. This change is consistent with current licensing basis and the methodology currently used to test the subject valves. The CTS requires, Each MSlV shall be demonstrated OPERABLE by verifying full closure within 5 seconds when tested pursuant to Specification 4.0.5, This provided the means of testing the full closure of the MSIVs within their UFSAR required time. The CTS testing did not restrict this testing solcly on using the actuated or simulated signals. Based on the Braidwood and Byron design basis, verifying that the valves fully close within the required time is adequate. STS SR 3.7.2.1 requires verifying that cach MSIV actuates to the isolation position on an actual or simulated actuation signal. Although an approved method, this requirement is by no means the only test verifying that the MSIVs close within the time supporting the accident analysis. Comed chose to divide the STS SR into two separate SRs. The reason is that if an alternate, but reliable and accepted, method is used and the valves do not met the required stroke time, then it is unnecessary to cycle the MSIVs on additional timejust for the

sake of using an actual or simulated actuation signal. Both ITS SR 3.7.2.1 and 3.7.2.2 provide the same level of assurance an't verification that the MSIVs are OPERABLE with regard to their closure time. Comed continues to pursuc this change.

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Resptnse t3 NRC RAI Dated 12/05/97 27 Jan-9n NRC RAI Number NRC lasued Date RAI Status f]

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3.7.2-04 12/5/97 Open NRC Action Required NRC Description of Issue 3.7.2-4 JFD P.28 JFD Bases P.5 JFD Bases PS CTS 3/4.6.3 CTS 3/4.7.1.5 ITS 3 6.3 APPLICABILITY STS 3.7.2 APPLICABILITY ITS 3.7.2 APPLICABILITY and Associated Bases.

The APPLICAlllLITY of CTS 3.6.3 and ITS 3.6.3 is MODES 1,2,3, and 4. The APPLICABILITY of CTS 3.7.1.5 is MODES 1,2, and 3. The APPLIC, ABILITY cf STS 3.7.2 is h10DE I and hiODES 2 and 3 except when the . . valves are closed and de-activated. ITS 17.2 APPLICABILITY changes the STS ATPLICABILITY to h10 DES 1,2 and 3.

Contrary to P.28 this is not consistent with CTS 3.6.3 or ITS 3.6.3. Also, this doc snot address the importance of the phrase "except when . deactivied" w hich means the valves are performing their isolation function when they are closed and hence the LCO does not apply. This change is considered to be a generic change and is a beyond scope of review item for this conversion. See item No. 3.7.3 5. Comment: Delete this generic change.

Comed Response to lasue Consistent with the Comed Response to RAI 3.6.3-01, TSTF-44 wi'l be withdrawn from the ITS submittal. Comed is deleting LCO 3.7.3, "FW isolation Valves," from the ITS submittal and retaining the requirements for feedwater valves in ITS LCO 3.6.3, " Containment isolation Valves " consistent with Byron /Braidwood Current Licensing Basis. In addition, LCO JFD 3.7 P28 will be resised to read " Consistent with CTS LCO 3.7.1.5, the Applicability ofITS LCO 3.7.2 is revised to h10 DES 1,2, and 3, wth no provisions for exclusion if all the valves are closed." This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS V. Section 3.7 RAI NRC RAI Number NRC Issued Date RAI Status

-3.7.2-05 12/5/97 Open - NRC Action Required NRC Description of issue 3.7.2 5JFD Bases C.4 ITS B3.7.2 flases Comment: Sec item Number 3.6.3 1 Comed Response to issue Comed will develop a 'P' Bases JFD for thejustification of adding the paragraph to the Background Section of the Bases for LCO 3.7.1. This is still a true statement even with TSTF-44 withdrawn. In addition, Bases JFD C4 will be deleted.

This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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Response to NRC RAI Dated 12/05/97 27 Jan-98 NRC RAI Number - NRC issued Date RAI Status 3.7.2 4 - 12/5/97 Open - NRC Action Required NRC Descript on of Issue 3.7.2-6STS B3 A.2 Bases SR 3,7.2.1 -

ITS B3.7 2 Bases SR 3.7.2.1 STS B3.7.2 Bases SR 3.7.2.1 states the following in the last paragraph: "The test is conducted in MODE 3 with the unit at operating temperaere and pressure as discussed in Reference 5 cxercising requirements." ITS B3.7.2 Bases - SR -

3.7.2.1 deletes the last part of this sentence "as discussed . requirements." Nojustification is prmided for this deletion.

Comment: Prmide a discussion and justification for this deletion based on currcnt licensing basis, system desigr, or operational constraints.

Comed Response to Issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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Response to NRC RAI Dated 12/05/97 27 Jtn-98

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NRC RAI Number NRC losued Date RAI Status g 3.7.3-01 12/5/97 Open NRC Action Required NRC Description of Issue 3.7.3 1 DOC A.5 .

DOC A.37 DOC A.38 DOC A.39 DOC A.41 DOC A.47 DOC M.I1 DOC LA.34 DOC LA.35 DOC LA.37 DOC L.25 DOC L.26 JFD C.6 JFD P.6

' JFD P.20 JFD P.27 JFD P.28 JFD Bases C.4 JFD Bases C.7 i JFD Bases P.6 -

JFD Bases P.7 JFD Bases P.36 p JFD Bases P.48

' t' CTS 3/4.6.1.1 CTS 3/4 6.3 STS 3,7.3 and Associated Bases ITS 3.6.3 ITS 3.7.3 and Associated Bases CTS 3/4 6.1.1 and 3/4.6.3 contain the requirements for all feedwater valves u hich perform a containment isolaJon fimetion These requirements have been retained in the ITS in 11 S 3.6.3 (Sec Item Number 3.6.3 1). The CTb does not contain a feedwater isolation valve LCO that addresses the other safety function OPERABILITY requirements. (Sce STS B3.7.3 Basesh it is acceptable to add ITS 3.7.3 under the guidance of NUREG 1431, based on these other safety function OPERABILITY requirements, not the containment isolation function, even though some of the ACTIONS and SRs may be the same as required by CTS 3/4.6.1.1, and 3/4.6.3, and ITS 3.6.3. In addition, Ois new LCO as described by justifications A 5 and M.11 have been altered by rejected generic changes - TSTF-44 (see item Numbers 3.6.3-1,3.7.1-2, 3.7.2-5, and 3.7.4 3) and TSTF-102 (see item Number 3.7.2 1), as well as other changes which the stalTconsiders to be gencric. Comment: Revise the CTS /ITS markup to deletc 'hc reference to and markups of CTS 3/4.6.1.1 and 3/4.6.3 and TSTF- 44 and TSTF 102. Refer to item Numbers 3.7.3-2,3.7.3 3,3.7.3-4, and 3.7.3 5 for additional comments that reflect changes to the CTS markup ofjustification M.ll (CTS Insert 3.6.1 A).

Comed Response to Issue Consistent with the Comed Response to RAI 3.6.3-01, TSTF-44 will be withdrawn from the ITS submittal. Comed is deleting LCO 3.7.3, "FW lsolation Valves," from the ITS submittal and retaining the requirements for feedwater valves in ITS LCO 3.6.3," Containment Isolation Valves," consistent with Byron /Braidwood Current Licensing Basis. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the ComLd Responses to the ITS Section 3.7 RAI. (See RAI 3.7.3-02.)

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Response to NRC RAI Dated 12/05/97 27-Jtn-98

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NRC RAI Number NRC Issued Date RAI Status !

.O- 3.7.3-02 12/5/97 Open- NRC Action Required I V

NRC Description of lasue

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3.7.3 2 DOC M.I1 DOC L25 JFD P.6 JFD Bases P.7 STS SR 3.7.3.1 ITS SR 3.7.3.1 ITS SR 3.7.3.2 and Associated Bases -

The ITS markup breaks STS SR 3,7.3.1 into two SRs - ITS SR 3.7.3.1 (verification of closure in specified time limit) and ITS SR 3.7.2.2 (verification of closure by actual or simulated signal). Thejustification for this change (P.6) is that if the valve fails the closure time SR, there is no need to perform a full actuation test (ITS SR 3.7.3.2) since closure time can be measured without this test. This change is considered to be a generic change which is beyond the scope of resiew for this conversion. See item Number 3.7.2-3. Comment: Delete this generic change.

Comed Response to Issue Sec Comed Response to RAl 3.7.3-01.

NRC RAI Number NRC Issued Date RAI Status 3.7.3 03 12/5/97 Open -NRC Action Required NRC Description ofIssue 3.7.3 3 DOC M.1I

(~g JFD P.6 t

) JFD P20 JFD Bases P.36 STS SR 3.7.3.1 and Associated Bases ITS SR 3.7.3.1 and Associated Bases STS SR 3.7.3.1 and its Associated Bases specifics the closure time of [7] seconds for each main feedwater isolation valve.

Justification P.6 separates STS 3.7.3.1 into two SRs (sec Item 3.7.3-2). Justification P.20 and Bases P.36 relocates the closure time for the FW isolation valves to the TRM. While the statifinds the modificadon made by ITS SR 3 7.3.1 of STS SR 3.7.3.1 in which the specific closure time is changed to "within limits" due to the number of valves involved and the different closure times, we do not find the relocation of the times to the TRM as acceptabic. The times should be listed in the ITS B3.7.3 Bases - SR 3.7.3.1 as is specified in the STS and to be consistent with other multi-limit components in other LCOs. In addition the staff finds that the relocation of the closure times to the TRM and associated changes to the Bases (Bases P.36) to be generic. Comment: Resisc ITS B3.7.3 Bases - SR 3.7.3.1 to inclutic the closure times for cach FW isolation valve.

Comed Response to issue See Comed Response to RAI 3.7.3-01.

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Response ta NRC RAI Dated 12/05/97 27-Jan 98 NRC RAI Number NRC Issued Date RAI Status 3.7.3-04 12/5/97 Open NRC Action Required NRC Description of Issue 3.7.3 4 DOC M i!

JFD P.27 JFD Bases P.48 STS 3.7.3 ACTIONS Note ITS 3.7.3 ACTIONS Note 2 and Associated Bases ITS 3.7.3 adds the following Note to the ACTIONS section: "2. Flow path (s) may be unisolated intermittently under administrative controls." While this statement is acceptable in STS/ITS 3.6.3, it has not been approved for STS 3.7.3, nor according to CTS 4.6.1.la and CTS Table 3.61 have the FW isolation valves been granted this exceptica. Thus the staff considers this change to be generic and beyond the scope of review for this conyctsion. Comment: rulete this generic change.

Comed Response to Issue See Comed Response to RAI 3.7.3-01.

NRC RAI Number NRC lss sed Date RAI Status 3.7.3-05 12/5/97 Open NRC Action Required NRC Description of Issue 3.7.3 5 DOC M.I1 JFD P.28 l JFD Bases P.6 CTS 3/4 6.3 ITS 3.6.3 APPLICABILITY STS 3.7.3 APPLICABILITY ITS 3.7.3 APPLICABILITY and Associated Bases The APPLICABILITY of CTS 3,6.3 and ITS 3.6.3 is MODES 1,2,3, and 4. The APPLICABILITY of STS 3.7.3 is MODES 1,2, and 3 cxcept when ... is closed and [de-activatedllor isolated by a closed manual valycl. ITS 3.7.3 APPLICABILITY changes the STS APPLICABILITY to MODES 1,2 and 3. Contrary to P.28 this is not consistent with CTS 3.6.3 or ITS 3.6.3. Also this does not address the importance of the phrase "except when ... valve." which means the valves are performing their isolation function when they are closed and hence the LCO does to apply. This change is

[

considered to be a generic change and is a beyond the scope revicw item for this conversion. See item Number 3.7.2-4.

Comment:. Delete this generic change.

Comed Response to Issue See Comed Response to RAI 3.7.3-01.

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Response to NRC RAI Dated 12/05/97 27-Jtn-98 NRC RAI Number NRC issued Date RAI Status 3.7.3 06 12/5/97 Open NRC Action Required l NRC Description of Issue 3.7.3 6JFD Bases P.36 STS B 3.7.3 Bases LCO

. ITS B 3.7.3 Bases - LCO

, STS B 3.7.3 Bases LCO the last sentences in the first paragraph states the following: "These valves will also isolate the l

non-safe;y related portions from the safety related portions of the system." ITS B 3.7.3 Bases LCO deletes this sentence. Nojustification is provided except for the generaljustification (Bases P.36) on system design. " tis is an inadequatejustification for the change. The deletion of this statement implies that all of the main feedwater system is safety relaicd. Comment: Provide additional discussion andjustification for this deletion based on cmtent licensing basis, system design, or operational constraints.

Comed Response to lasue See Comed Response to RAI 3.7.3-01.

NRC RAI Number NRC lasued Date RAI Status 3.7.3-07 12/5/97 Open - NRC Action Required NRC Description of Issue 3.7.3 7JFD Base M6 STS B 3.7.3 Bases - SR 3.7.3.1 and REFERENCES ITS 13 3.7.3 Bases SR 3.7.3.1 and REFERENCES tq _

STS B 3.7.3 Bases SR 3.7.3.1 states the following in the first paragraph: "These valves should not be tested at power .

ASME Code,Section XI (Ref.2) . . operation in MODES I and 2." ITS B 3.7.3 Bases SR 3.7.3.1 deletes these sentences and Reference 2 from the REFERENCE Section. Nojustification is provided except for the generaljustification (Base P.36) on system design. This is an inadequatejustification for this change. Comment: Provide additional discussion and justification for this deletion based ut current licensing basis, system design, or operational constraints.

Comed Response to Issue See Comed Response to RAl 3.7.3 01.

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Response is NRC RAI Dated 12/05/97 27 J:n-9s -

NRC RAI Number NRC lasued Date R Al Status

-3.7.4-01 12/5/97 Open NRC Action Required NRC Description ofissue 3.7.4.1 DOC M. ll JFD B.19 JFD P.2' JFD Bases P.2 JFD Bases B.15 STS 3.7.4 APPLICABILITY STS 3.7.4 RA C.2 and Associated Completion Time ITS 3.7.4 APPLICABILITY and Associated Bases ITS 3.7.4 RA C.2, Associated Completion Time and Associated Bases -

STS 3.7.4 APPLICABILITY and the APPLICABILITY of a number of other 3.7 STS require the SG PORVs to bc OPERABLE in " MODE 4 w hen the steam generator is relied upon for heat removal." STS 3.7.4 RA C.2 requires if the .

Required Action and Associated Completion Times are not met, the plant must "Be in MODE 4 without reliance upon steam generator for heat removal" in a Completion Time of 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . The other 3.7 STS cither have similar ACTIONS or l different ACTIONS as well as additional notes to LCOs and SRs which relate to the system's OPERABILITY in MODE 4

) when the steam generator is relied upon for heat removal. ITS 3.7,4 and the other 3.7 STS have been modified to delete this OPERABILITY requirement and change the associated ACTIONS, Completion Times and Notes. These changes in ITS 3.7.4 arc designated as B.19, P.2, Bases P.2 and Bases B.15 (see Item Numbers 3.7.5 3 and 3.7.6-1 for applicable DOCS and JFDs). This proposed change was submitted to the staffin TSTF 29 and rejected, based on the fact that the

- change over from Auxiliary Feedwater (AF) System to Residual Heat Removal (RHR) System does not take place exactly at the MODB 3 to MODE 1 change oves but at some time into MODE 4, as well as the fact that the AF System is also used for startup in MODE 4. Comment. Delete this change Comed Response to issue x

No change. Comed disagrecs. The proposed changes discussed by the resicwcr are not as a result of TSTF-29 although I many of the Comed changes are also addressed in the subject TSTF. The changes made by Comed are current licensing basis changes and reflect the design and operation of our plant. The proceduralized point for RHR initiation and the design of the RHR System is such that RHR is placed in shutdown cooling at the MODE 3/ MODE 4 transition point.

Comed continues to pursue these changes on a plant specific basis. (See RAI 3.7.5-03 and RAI 3.7.6-01.) (Correction Note: Auxiliary Feedwater is not used for startup at Byron and Braidwood Stations.)

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Response (2 NRC RAI Dated 12/05/97 27-Jan-98 NRC RAI Number NRC Issued Date RAI Status j

v ) 3.7.4 02 12/5/97 Open - NRC Action Required NRC Description of Issue 3.7.4 2 DOC M.1I JFD P.24 JFD Bases P.44 STS 3.7.4 RA A 1 Completion Time ITS 3.7.4 RA A.1 Completion Time With one SG PORV line inoperable, ITS 3.7.4 RA A.1 Completion Time has been extended from the STS specified 7 days to 30 days. The basis is that it has taken longer than 7 days in the past to restore a SG PORV line to OPERABLE status.

This is an inadequatejustification because th: issue not addressed should be re-esbblishing in a timely manner the safety assumption for an SGTR crent. In addition no information is provided to show that the SG PORVs at Byron /Braidwood are any different than the PORVs/ADVs at other plants that would require this 4 fold increase in the Completion Time.

Comment: Delete this change or provide additional discussion and technicaljustification to show that the valves are sufficiently different from the PORVs/ADVs at other plants.

Comed Response to issue CemEd disagrees. NUREG LCO 3.7.4 Required Action A.! Completion Time was changed from 30 days to 7 days. The 30 days was based on past history to perfc maintanence and Environmental Qualification overhauls on the SG POP Vs.

In addition, Comed has performed a plan. specific PRA w hich was appros ed by NRC letter dated October 27,1997.

Contained in the PRA was an evaluation of the SG PORVs being out of senice for 30 days which was documented in Probabilistic Safety Assessment (PSA) sensitivity calculation BWR-97-0338 The risk associated with having the SG PORV out of-service for 30 days every 2 years was 1.14E-05. This value shows that there is no significant difference in the probability or severity of core damage that would result during an accident. This 30 days out-of senice time has also

, been incorporated into the Comed Maintenance Rule Program. There are only four (4) plants that have similar actuators (V) as the Braidwood/ Byron BW/IP, Elector Hydraulic Operator. The four plants are Beaver Valley, Nine Mile, River Bend, and Vogtle. Of the four plants, only Beaver Valley & Nine Mile riate these actuators installed in sirnilar applications.

Beaver Va';cy & Nine Mile have seen the same performance problems as Braidwood & Byron. River Bend and Vogtle have the actuator installed in continuously modulating applications. Comed continues to pursue this change.

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Response to NRC RAI Dated h2/05/97 27-Jen-98 hC RAI Number NRC lasued Date RAI Status

, 3,7.4-03 12/5/97 Open.NRC Action Required x

NRC Description of lasue -

3.7.4 3JFD C.4 ITS B3.7.4 Bases- BACKGROUND AND APPLICABLE SAFETY ANALYSES ITS B3.7.4 Bases add words to the BACKGROUND and APPLICABLE SAFETY ANALYSES section that states that the SG PORVs are containment isolation valves (CIV) and the CIV function is addressed ITS 3.6.3 " Containment Isolation

. Valves " While the statements are true the justification (C,4) used to add the statements is unacceptable. C.4 refcts to TSTF-44, Rev.1. TSTF-44 Rev. O has been rejected by the statiand TSTF-44 Rev. I has not been submitted for staff approval. This change is considered a beyond scope of review item for this conversion. See item Number 3.6.3 1 Comment. Delete this gencric change.

Comed Response to issue No change. Comed disagrees that the paragraphs added to the Background and Applicable Safety Analysis Sections of the Bases for LCO 3.7.4 are beyond scope. The CIV function of the SG PORVs is addressed by LCO 3.6.3 in both CTS and ITS. One of the several changes TSTF-44 proposed, provided additional information in Bases B.3.7.4. The specific statements Comed added were, "The SG PORVs also serve as Containment 1sulation Valves (CIVs), however, the CIV function is addressed in LCO 3 6.3, " Containment isolation Vahes"," and "The SG PORVs are also credited as CIVs (refer to LCO 3 6.3) " These statements are being maintained in the Bases since they do not change any technical information or intent as provided by NUREG 1431. The changes do not alter any Required Actions, Completion Times, or Surveillance Testing Frequencies. The only intent is to provide a more accurate description of both the Byron and Braidwood plant designs and to better assist the operators in locating associated LCOs. Although originally part of TSTF-44, the human factors benefit and enhancement obtained from these changesjustifics them being pursued on a plant specific basis. Bases JFD 3.7 C4 will be deleted and a 'P' Bases JFD created tojustify these changes. Comed continues to pursue this change. (See RAI 3.7.102.)

NRC RAI Number NRC issued Date RAI Status j 3.7.5-01 12/5/97 Open - NRC Action Required NRC Description of issue 3.7.51 DOC A.29 JFD P.14 JFD Bases P.40 CTS 4.7.1.2.2 STS SR 3.7.5.5 ITS SR 3.7.5.5 and Associated Bases CTS 4.7.1.2.2 requires "an auxiliary feedwater flow path to cach steam generator shall be demonstrated OPERABLE following each COLD SHUTDOWN.. " STS SR 3.7.5.5 requires this SR be performed w henever the unit has been in MODE 5 or MODE 6 for greater than 30 days. ITS SR 3.7.5 5 adds "or defueled for a cumulative period of" to the STS SR Frequency. This is a generic change w hich is a beyond scope of review item for this conversion. Comment: Delete this generic change.

Comed Response to issue No change. Byron /Braidwood Station, presented this generic change to the Westinghouse Owner's Group. The traveler is under TSTF consideration as WOG-96. The STS does not provide any specific guidance w hen the unit is in an undefined condition such as "defueled." Adding the phrase, "whenever unit has been in MODE 5. MODE 6, or defueled for a cumulative period of greater than 30 days " clarifics when the SR is applicable. Comed continues to pursue this change on a plant specific basis.

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ltisponse to NitC Rhl Dated 12/05/97 27.Jan 98

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NRC' RAI Numh'er NiiC lasued Ibite RAI Status 3 7.5-02 12/5/97 Open NRC Action Required NHC Dmrlption of Inue 3 7.5 2 DOC LA 4 CTS 331.2h CTS 4 7.12.3 CTS 3 7.12 b specifies the minimum diesel day tank volume of the diesel-driven AF system pump and CTS 4.7.1.2.3 f.pecifies the SR needed to be performed and the frequency to demonstrate that the AF system diesel driven pump is OPERABl.E. Thejustincation (LA 4) states that these OPERADILITY requirements are to be relocated to the TRhi, The staff finds this unacceptable The discussion and justification used would also allow the OPERABILITY requirements for the Emergency Diesel Generator (EDG) Fer, Oil System in ITS 3 8 to be relocated to the TRh1 *"he staff finds that CTS 4 7.1.2 3 c may be relocated to the TRhi, based on thejustifications in the staff Safety Evaluation issued wnh Amendments 71 for tiraidwood and 79 for D) ton dated 2/16/97 ul,kh relocated the similar EDO requirement (CTS 4.H.1.1.2 f.1)).

Ilased on STS/ITS 3 H, CTS 3.7.12 b (day tank vehime only) and CTS 4 7.1.2.3 a needs to be retained as SRs in ITS 3.7.5 in addition the fuel oil testing for CTS 4 7.1.2.3 b needs to be retained as an SR in ITS 3.7.5, however the details of the testing (ASThi Standards) may be relocated to ITS 5.5.13. Comment: Revise the CTS and ITS submittals accordingly and provide any additional discussion and justincation to support these changes.

Comed F ,ponse to luuc No change. Comed disagrecs that CTS 3.71.2 b and 411.23 need to be incorporated into the ITS. The information contained in these two CTS subparts require that in order for inc auxiliary feedwate, pump dicsci to be demonstrated OPERAHLE, the dicsci day tank shall maintain a solume of 420 gallons of dicscl fuel oil. This is to be verified escry 31 day s in addition, cury 18 months the dicsci shall be inspected in accordance with the manufacturcr's recommendations The NRC resicuct ..ates that the staff finds relocating these requirements to the TRh1 is unacceptable and they are needed to demonstrate OPERABILITY of the dicsci pump. Essentially all Ci'S SRs make a generic introductory statement that a O specific component or piece of equipment shall be dt"nonstrated OPERABLE by the successful performance of a specific SR Almost all of the CTS SPs relocated to t'c TRhl contain the cwict same statement of demonstrating OPERABILITY through the performance of the SR. The odierence between retaining specine requirements in the ITS or relocating them to a licemcc controlled document (i c., TRhi)is if the requirement meets the NRC criteria as stated in 10CFR$0 36(c)(2)(ii) In this specinc case, the requirements being relocated do not meet the N3C acceptance enteria as stated in 10CFR50.'6(c)(2)(ii) Relocating the subject SRs to a licensec controlled document dou nct climinate these requirements, does not change frequency of verifying the dicsci fuct oil "olume, nor chminate an3 inspections being performed in accordance with the manufacturcr's recommendations. Comed feels that these requirements are still essential and relocating them to a licensec controlled document does not in any way lessen their importance. Once these requirements are maintained in a licensec controlled doct. ment any changes would be subject to a 10CFR50 59 cvaluation.

In addition, all the STS 315 SRs as stated in NUREG 1431, are maintained it: the ITS with minor changes made to accommodate plant design and current licensinj basis. These SRs have been identined by the NRC and industry as adequate to demonstrate OPERABILITY from a STS point of view. Based on the fact that the subject requirciaents are maintamed in a licensec controlled document as required by he NRC 10CFR50 36(c)(2)(ii) the ITS will not be revised to incorporate these requirements Comed continues to pursue this change.

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Response to NRC RAI Dated 12/05/97 27 Ja> 9 t NRC RAI Number NRC Issued Date RAI Status 3.7.5 03 12/5/97 Open NRC Action Required NRC Description of Inue 3.7.5 3 DOC L 2 JFD P.2 JFD Bases 11.2 JFD 11asesP.2 JFD 11ases P.8 CTS 3.7.1.2 ACTION b.

ITS LCO 3.15 Note ITS 3.'.5 APPLICABILITY ITS 3.7.5 ACT!ONS .

ITS SR 3.7.5.3 Note ITS SR 3.77 4 Note and Associate Bases Comment: Sec item Number 3.7.41.

Comed Response to luue Reference Comed response to RAI 3.7.4 01.

NRC RAI Number NRC Inved Date RAI Status 3.7.! 04 12/5/97 Open NRC Action Required NRC Description of Inue 3.7.5-4JFD D 6 r

q JFD C.I Q ITS 3.7.5 Condition B ITS 3.7.5 Condition B contains a C.1 c.ange identifier; however, the justifications listing states that C.I was not used This appears to be an error since il 6 deletes this portion of the Condition statement. Comment: Revisc the submittal to correct this discrepancy.

Comed Response to issua Comed will delete the 'C1' designamr in Condition B of LCO 3.7.5. This change will be provided in our comprehensive iTS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NRC RAI Number NRC lasued Date RAI Status 3.7.6-01 12/5/97 Open NRC Action Required NRC Description of lune 3.7.6 1JFD B 2 JFD P.2 JFD Bases B 2 JFD Bases P.2 ITS 3,7.6 APPLICABILITY ITS 3.7.6 RA B 2 and Associated Bases c Comment: Sec item 3.7.4 1 Comed Response to Inue See Comed response to RAI 3;7.4-Ot z -

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Response to NRC RAI Dated 12/05/97 2N 2n

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

NRC RAI Number NRC lieued Date RAI Status 3.7.6 02 12/5N7 Open.NRC Action Required NRt' Description of lanue 3.7.6 21FD Bases P 1 STS1137.6 Bases APPLICAULE SAFETY ANALYSES ITS 113.7.6 Bases APPLICAllLE SAFETY ANALYSES ITS 113.7.6 !!ases APPLICAllLE SAFETY ANALYSES deletes from the third paragraph, second sentence of STS 113.7 6 the following words: "r.ince the Emergency Feedwater Actuation Syste.n would not detcet a difference in pressure between the steam generators for this break location." This deletion isjustified as an editorial change when it is a technical ,

, change Nojustification provided for this change. Comment: Provide additional discussion and justification to explain !

this deletion or adopt the STS text.

l Comed Response to issuc Comed will provide additionaljustification for deleting the statement, since Emergency Fecdwater Actuation System would not detect a ddLrence in pressure betuccn the steam generators for this break locauon Thitjustification will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

g NRC RAI Number NRC Inued Date RAI Status 3.7.6 03 12/5N7 Open NRC Action Required NRC Description of luuc 3.7.6 3JFD flases P8 STS B3.7.6 Ilase LCO p ITS 113.7.6 Bases LCO 1,') ITS 113.7.6 flases LCO deletes from STS B3.7.6 the entire second paragraph. Ilowever, the isst sentence in this paragraph w hich states; "This basis is established in Reference 4 and cxeceds the volume requiled by the accident analysis" appears to be applicable. Comment: Revise the submittal to adopt the STS wording, or provide additional discussion or justification to support its deletion.

Comed Response to Inue No change. Comed disagrec, Rc crencer 4 was deleted from the ITS submittal since there is no Reference 4 listed in the NUREG References Sectinn of the Bases for LCO 3.7 6. The proposed insert il 3.7 33A refkets both the tiraidu s.ad and Dyron designs. .Without ocmg able to verify w hat the refercru is or the analysis it uses, Comed cannot make the generic statement in the NOREG Dases, and cxeceds the volume reqmred by the accident analysis. Comed continues to pursue this change.

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Respontw 13 NRC RAI Dated 12/05/97 27 Ja>9N

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, NMC RAI Number NMC Innued Date RAI Status 31701 12/$!97 Open.NRC Action Required NMC Description of Isnoe 3,7,7.lDOC A.12 DOC M 4

- DOC LA 6

. JTD P 1 JFD P.7 JFD P.2$

IFD liases P.15 t 7.3 CC '/.3 ACTIONS STS 3.77 ACTIONS ITS LCO 317

'ITS 317 ACTIONS and Associated Bases

-ITS 11317 !!ases . DACKGROUND states that the CC System is a shared s) stem consisting of Dvc pumps (four unit.

specine and one common), three heat exchangers (two unit specific and one common), and two unit specific surge tanks.

There are no indications in the CTS or ITS associated Dases that this system is shared betwccn the units and no indication ofinter unit dependence in the CTS. For example when the common heat cxchanger is inoperable and regardless of u hich MODE cach unit ;nay be in, both units must simultaneously enter the appropriate ACTIONS. The STS did not consider shared unit operation of a system ITS LCO 3.7.7 and its associated Bases seems to address shared system OPERABILITY, however, ITS 3,7.7 ACTIONS still are based on a per unit basis i ith no indication of the various system alignments or ofinter unit dependence. Desed on the staffs review of the information submitted and the FSAR we belicyc that CTS 313 ACTIONS and the proposed ITS 3.71 ACTIONS do not seem to cover all potential system configurations, unit operational MODES and inoperabilitics. Ccmment: In order to fully undet;tand the system and the prcposed ITS, g prmide a complete listing of all possible system configurations. The listing for the plant (both units) is to hclude the following for cach configuration.

a. The pumps, heat exchangers and loops required to bc OPERABLE.

b. The operating MODE for each unit (both operating and one unit operating with the other unit shutdown.

c. The ACTIONS to be taken with one or more components inoperabic.

Resise ITS 317 ACTIONS based on the results of the above listing and unit inter dependence. The items that may have to be considered in the revised ACTIONS arc loss of function (LCO 3.0.3 cntry), entering more than one ACTION currently (STS 1.3 Exampic 1.3 3 and correct placement of Notes. Note: A Note such as that proposed for ITS 3110, ITS 3111, and ITS 3112 (see item Jumbers 31101,3111 1 and 3112 1 respectively) may not be adequate to resolve this concern. Provide any additional discussions and justiEcations as appropnate.

ComFd Remp<mse to Issue No change. Comed disagrecs that 'there are no indications in ITS Bases that this system is shared between the units."

- The first sentence in the ITS Bases for LCO 3.7.7 states, "The CC System is a shared system which . ", the first sentence ,

in Insert B 3.7 36A states, "The shared CC system consists of... *, among several other places in tW ITS Bases. The pumps, heat exchangers, and loops required to be operable are delineated in Insert B 3.7 37A in the LCO Section of the Bases. The operating mode for cach unit is specified in the LCO Applicability, and pertains to cach unit individually and independently. The actions to be taken uith one or more components inoperable are delineated in the Required Actions for the corresponding Conditions. Again, the Conditions apply to cach unit individually and independently. Comed does not believe that any changes need to be made to the ITS LCO or Bases. Each affected unit uould independently enter the

apphcable LCO for this shared s3s,cm LCOjust like cach unit would independently ccter the applicable LCO for non-shared system LCOsf Comed continues to pursue this change.

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Response to NRC RAI Dated 12/05/97 27 Ja-9st

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NRC RAI Number NRC issued Date RAI Status 3.7.7 02 12/5/97 - Open . NRC Action Required NRC Description of innue 3.7.7 2 DOC A 40 JFD P.17 JFD 13ases P.15 CTS 4.7.3.3 b ITS SR 3.7.7.2 and Associated Bases CTS 4.7.3.3 b requires verifying that the Essential Service Water (SX) system is available to cach CC llcal Exchanger.

The ITS adds this requirement at ITS SR 3.7.7.2 and modifics it to verify correct SX system valve position. ITS B3.7.7 11ases . SR 3.7.7.2 states that the SR verifics that the valves are in the correct position or can be aligned to the correct position. In light of the SX system serving a shared system as well as being a shared system with regards to CTS 3.7.4.1, the 13ases for SR 3.7.7.2 should be modified to desenbc w hat is meant by" can be aligned to the correct position" with regard to the shared portions of the CC and SX Systems. Comment: Revise the Bases for SR 3.7.7.2 accordingly, and provide any additi)nal discussion and justification as necessary.

Comed Response to issue No change. Comt d disagrees The structure and wording of the SR Bases is consistent with other statements concerning valve alignments in other Bases. Comed has procedurcs that identify the correct valve position of each associated valve for a spc tfic plant / valve alignment. With plant procedures maintaining this level of detail, Comed does not believe that the 11ases also need to maintain this level of detail. For consistency, the entire ITS Bases would require review and revision to add this level of detail for similar SRs Comed continues to pursue this change.

t. ==========... -

- NRC RAI Number NRC Issued Date RAI Ctatus 3.7.7-03 12/5/97 Open - Comed Action Required NRC Description of Issue 3.7.7 3 DOC M.4 JFD P.25 CTS 3.7.3 ACTIONS . Insert 3.7 I1 A STS 3.7.7 RA A 1 Note ITS 3.7.7 ACTIONS Note Justification M 4 states that a Note is added to CTS 3.7.3 ACTIONS consistent with NUREG 1431 STS 3.7.7 RA A.I Note. The Note requires that the al plicable Required Actions be entered if the residual llcat Removal (RilR) System is made inoperable by the inoperable CC system Whi!c the addition of this type of Note is acceptable, M.4 states that this change represents r.n additional restriction on plant operation. The staff disagrees. The Note does not represent an a( ttional restriction on plant operation. Since the CTS requires cascading with regards to inoperable support systems (CC system is a support system to the RHR system), the NOTE rep.esents current requirements and therefore is en Administrative change. Sec ltem Numbers 3.7.71 for Note location and 3.7.7 4 for concerns on Note wording).

Comment: Provide additional discussion and justification for this Administrative change.

ComLd Resp <mse to issue No change. Comed disagrees. Due to the alignment of Allord Outage Times within the CTS, cascading for single train inoperabihties is not necessary and only creates an administratwe burden without a compensating increase in safety. For

' redundant train inoperabilitics, the cumulative effect is considered and LCOs are entered commensurate with the level of degradation experienced Situations uhich result in a loss of safety function absent a single failure are not permitted.

Comed continues to pursue this change. (Sec RAI 3,7MS and RAI 3.7.13-04.)

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Response to NRC RAI Dated 12/05/97 274c.>98

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NRC RAI Number NRC lasued Date RAI Status 3.7.7 464 12/5/97 Open NRC Action Required NRC Description of Issue 3.7.7 4 DOC M 4 JFD P.25 CTS 17.3 ACTIONS Insert 3.711 A STS 3.7.7 RA A.1 Note ITS 3.7.7 AC110NJ Note STS 3.7.7 RA A I Note states the following: "Entc* spplicable Conditions and Required Actions of LCO 3.4.6, 'RCS Loops MODE 4', for residual heat removal loops made inoperable by CCW.* ITS 3.7.7 moves the Note from RA A.1 to under AC110NS (See llem Number 3.7.71 for concern on location) and changes the wording from " loops made inoperabic" to " loops if made inoperable..." The sta!T finds this change to be generic and beyond the scope of resicw for this conversion. Sec item Number 3.7.8-3. Comment: Deletc this generic change.

Comed Response to issue The relocation of the Note is neither a generic not beyond scope change, but rather a plant specific change based on the

!!yron/Braidwood CC sy stem design. The CC system is a shared system that employs two CC pumps per unit, one l

' common CC pump, one CC heat exchanger per unit, and one corumon heat exchanger. The NUREO was developed based on a stand-alone two train CC system. The proposed change reflects current design which resulted in NUREO Condition j A being split into two separate conditions (i c., Conditions A and B) in ITS Ilowever, the Note was revised to adopt the i

STS wording. This change will be provided in our comprehensive ITS Section 33 ;loscout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (Sec RAI 3.6 2 02 and RAI 3.7.8-06.)

NRC RAI Number NRC lasued Date RAI Status 3.7.7 05 12/3/97 Open NRC Action Required NRC Description of Issue 3,7,7 5)FD P.7 C FS 4,7.3.2.b STS SR 3.7,7.3 ITS SR 3.7.73 and Associated Bases CTS 4.7.3.2.b requires verifying that cach CC pump starts automatically on a Si test signal at least once per 18 months.

STS SR 3.7.7.3 performs the same surveillance on cach pump. ITS SR 3.7.7.3 changes the STS wording from "cach CC pamp" to " required CC pump." This change is not in accordance with the CTS requirements of each pump and no justifications is provided In addition this hc ange would allow on. of the five CC pumps to be inoperaMe indefinitely.

This is unacceptable to the staff. Comment Revisc ITS SR 17.7.3 to conform to CTS 4.7.3.2.b with regards to testing of all the CC pumps ComFd Response to issue No cienge. Comed disagrecs. CTS 4.7.3.2 states, "At least two component cooling water pumps slull be demonstrated OPERABLE by performing the following: Verifying . that cach component cooling water pump starts , ,n a Si test signal." Therefore, by each unit testing it, issociated unit specific CC pumps the CTS SR is satisfied. Although not good

. operating practice, the common CC pump would not be required to be tested per CTS. Therefore, the addition of the word

" required" in ITS SR 3.7.7.3 is in accordance the CTS requirements Additionally, the Staff commented that " . this change wwld albw one of the five CC pumps to be inoperable indefinitely." Agam, w hile not good operating practice, CTS LCO 3.7.3 does not require a fifth CC pump to be operable as long cs cach unit has two operatic CC pumps. Comed continues to pt rsue this change.

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Response is NRC RAI Dated 12/05/97 27 Ja>98 NRC RAI Number NRC Innued Date- RAI Status 3.7.7 06 12/5/97 Open NRC A: tion Required NRC Dcocription of issue 3.7.7 6JFD P.8 STS SR 3.7.7,3 ITS SR 3.7.7.3 ITS SR 3.7.7.3 show s that changes were made to this SR as a result of P.8. Justification P.8 deals with 'hc deletion of STS SR 3.7.7.2 and no changes are show in ITS SR 3.7.7.3 which relate to P.8. Comment: Correct this discrepancy.

. Comi:d Memponne to Innue Comed agrecs that LCO JFD 3,7 P8 is not applicable to ITS SR 3.7.7.3. The LCO markup for ITS SR 3.7.7.3 will bc revised in our comprehensive ITS Section 3.7 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

! NRC RAI Number NRC Innued Date RAI Status 3.7.8 01 12/$/97 Open . NRC Action Required NRC Description of innue

, 3.7.81 DOC A.I4

! DOC M 6 DOC LA.12 JFD P.9 JFD bases P 18 CTS 3.7.4.1 CTS 3.7.4.1 APPLICABILITY ITS LCO 3.7.8 b and Associated Bases CTS 3.7.4.1 and ITS LCO 3.7.8.b require th: opposite unit SX train to be OPERABLE for the unit.spacific support u hen the opposite unit is in MODES 5 or 6 or defueled With the opposite unit in MODE 5 or 6, the SX system scaves as a support system with no TS imposed icquirements for opposite unit. Thus, its OPERABILITY is determined by the definition of OPER ABLE and the system (s)it supports. It is unclear u hich opposite unit train is required to bc OPERABLE for tha unit specinc support. For example, ITS 3.8.2 requires a Emergency Diesel Generator to be OPERABLE in MODES 5 and 6. By the dermition of OPERABLE OPERABILITY, the associated SX train would be required to bc OPERABLE to support EDO operations. Would this opposi te unit SX train also be considered as the opposite unit SX train required to bc OPERABLE per ITS LCO 3.7.8.b for the unit specific requirement or would the other opposite unit SX train be the one used This may involve a reevaluation of the CTS /ITS APPLICABILITY (sce item Number 3.7.8 2) Comment: Provide additional discussion 'mdjustification for this concern. Resisc the submittal as appropriate.

Comtid Responne to issue No change. Since the SX trains are cross-tied, it is not necessary nor desirable to specify in the LCO or Conditions u hich SX pumcis the designated ' opposite-unit SX pump

Comed believes that through continuing operator training, approved plant procedures, and the requirements of CTS, the ITS LCO is not confusing and is understandable as u ritten.

omEd contmucs to pursue this change.

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Response to NRC RAI Dated 12/05/97 27 Ja2 9a NRC MAI Number NRC Issued Date RAI Status 3.7.8-02 12/$/97 Opeu NRC Action Required NRC Description of Innue j

3.7.8 2 DOC A.14 IX)C LA.12 CTS 3.7.4.1 CTS 3.7.4.1 ACTION in CTS 3.7 4.1 ACTION, LA.12 indicates a change has been made to refer to the Essential Senice Water pump as the "SX trains" in two places, whereas the same change isjustified in CTS 4,7.4.1 under A.14. A.14 is acceptable while LA 12 already applies to the relocation of CTS 3.7.4.1. Therefore, the CTS markup should be changed to be consistent.

Comment: Revisc the CTS markup and provide additional discussion and technicaljustification for this Administrative change.

Comed Responne to lanue Comed agrecs that in the CTS 3.7.4.1 markup, the 'LAl2'in the Actions should be changed to 'A13', consistent with the change made to CTS SR 4//.4.1. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NRC RAI Number NRC lasued Date RAI Status 3.7 8-03 12/5/97 Open NRC Action Requiied NRC Description of Inue 3,7 E 3 DOC A.15 DOC hl.6 JFD Bases P.18 CTS 3.7.4 APPLICABILITY CTS 3.7.4.1 APPLICABILITY CTS 3.7.4 2 APPLICABILITY STS 3.7.8 APPLICABILIT" ITS 3.7.8 APPLICABILITY and Associate Bases CTS 17.4 APPLICABILITY specifies that the unit specific SX S3 stem shall bc OPERABLE in hiODES 1,2,3, and 4.

CTS 3.7.4.1 includes an ADPLICABILITY for the opposite-unit SX system when the opposite unit is shut down to support the requirements for the specific unit. CTS 3.7.4.2 APPLICABILITY specifies that the unit cross-tic shall bc OPERABLE when cither unit is in htODES 1,2,3 or 4. These three CTS show an inter unit dependence as well as a sharing of the two units SX system. In converting from the CTS to the ITS the licensec used STS 3.7.8 APPLICABILITY, Thus, ITS 3.7.8 APPLICABILITY is only for htODES 1,2,3, and 4. The STS did act consider shared unit operation or inter unit dependence of a system. Thus, ITS 3.7,8 APPLICABILITY is not equivalent and could lead to confusion since the ITS is presented as a combined TS. !nsert B.3.7 2C it. ITS B3.7.8 Bases APPLICABILITY sect's to describe the intent of the ;

CTS. Thus, the follewing is proposed in ordei to make 11S 3.7.8 APPLICABILITY fit the situation, as claimed by h1.6: i

" APPLICABILITY: h10 DES 1,2,3 and 4 for the Unit Specific SX; and at all times for the Opposite-unit SX train unit-specific support." The change to the nomenclature of" opposite unit" and " specific unit" is accepted. SX performs many functions but foremost is to support the RilR heat exchangers. In a GL 91 13 scarch for alternate SX water sour es, it is reasonable that opposite unit requirements would apply at power in order have another SX train available to achicyc a COLD SilUTDOWN, when required This is the object of the requiren. cats in the new proposed APPLICABILITY. See item Number 3.7.81 for additional concerns in this area Comment: Revisc the CTS /ITS markup and provide additional discussion nnd technicaljustification for changes.

Comed Response to luue s ITS LCO 3/t.8 Applicability will be modified to read, h10 DES 1,2,3, and 4 for the specific unit. This change will be

- provided in our comprehensive iTS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed 4

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Responws to the ITS Section 3.7 RAl. (Correction Note: Insert B 3.7 2C should be Insert B 3.7-42C.)

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NRC MAI Number NRC issued Date RAI Status 3.7.8 04 12/5/97 Open.NRC Action Required NRC Description of laruc 318 4 DOC A.17 JFD P.9 JFD llases P.18 CTS 414.2 t' ITS 318 and Associated flases CTS 414.2 b states that the provision of CTS 4.0.4 does not apply w hich allows entry into the specified MODE without CTS 4 7 41a having been performed ITS 3.7.8 does not contain this provision, but A.17 states that "precisc icquirements for performance of SRs are specified in the ITS such that exceptions to SR 3.0.4 are noi necessary." These requirements can not be located in ITS 3.7.8 and associated flases. Comment: Identify what these requirements are and u here they are located to verify thisjustification. Provide additional discussion and technicaljustification for this Administrative change as necessary.

Comed Response to lan9e Ivo change. CTS SR 4.7.4.2.b states that the provision of CTS 4.0.4 does not apply. DOC 3.7 A17 states, ". . The CTS has been res ised to delete this surycillance requirement provision since precise requirements for performance of SRs are specified in the ITC such that exceptions to SR 3.0.4 are not nacssary . ." ITS LCO 318 applies to unit-specific SX trains and opposite-unit SX trains. Further, ITS SR 3.7 8 3 surveils opposite unit SX crosstic valves. Therefore, failure to meet SR 318.3 would constitute failure to meet LCO 318, and Condition 11 would be entered for an opposite unit SX train inoperabic. Ilowever, since Condition 13 Noic states, "LCO 3.0.4 is not applicable," the unit ca.n change modes w hile in Condition il This translates into the unit being ahic to change modes with SR 3.7 8 3 not met. Therefore, an exception to SR 3.0.4 is not necessary for SR 318.3 Comed continues to pursuc this change.

NRC RAI Number NRC linued Date RAI Status 31805 12/5/97 Open . Comed Action Required NRC Description of lanue 31P.5 DOC M.5 JFD P.25 CTS 314 ACTIONS Inscit 3.712 A STS 318 RA A.i Notes ITS 318 RA A.I Notes Justification M.5 states that Iwo Notes are added to CTS 3.7.4 ACTIONS consistent with NURFG-1431 STS 318 RA A.1 Notes The Notes require that the applicable Required Actions be entered if the Residual licat Removal (RilR) System and Emergency Diesel Generator (EDG) are made inoperable by the inoperable SX System. While the addition of these Notes is acceptable, M 5 states that this change repicsents an additional restriction on plant operation. The staff disagrees. The Notes do not represent an additional restriction on plant operation. Since the CTS requires cascading with regards to inoperable support system (SX system is a support system to the RliR system and EDG), the Note represec current requirements and thereforc is an Administrative change. Sec item Nmrber 318-6 for concerns on Note wording)

Comment: Proivde additonal discussion and justification for this Administratisc change.

Comed Respanne to issue No change Comed disagrees. Due to the alignment of Allowed Outage Times within the CTS, cascading for single train inoperabilitics is not necessary and only creates an administrative burden without a compensating increase in safety. For redundant train inoperabilitics, the cumulative effect is considered and LCOs arc entered commensurate with the level of degradation experienced Situations which result in a loss of safety function absent a single failure are not permitted Comed continues to pursue this change. (Sec RAI 317 03 and RAI 3.7.13-04.)

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Response to NRC RAI Dated 12/05/97 27-Jan-98 i t . . _ _ . _ - . _ _ - ._. _ . _ . _ _ . _ . . _ _ _ i

NRC RAI Number

NRC Inoued Date RAI Status

, 3.7.8 416 12/5/97 Open NRC Action Required NRC Description of innue 4 3.7 8 6 DOC M.$

JFD P.25 1

CTS 3.7.3 ACTIONS Insert 3.7.12A -

STS 3.7.8 RA A.1 Note ITS 3.7.8 RA A.) Note STS 3.7.8 RA A.1 Notes state the following: " Enter applicable Conditions and Required Actions ...made inoper. ole by SWS, ITS 3.7 A changes the wording from "made inoperabic" to "if made inoperabic..." The staff finds this change to be generic and beyond the scope of review for this conversion. Sec item Number 3.7.7 5, Comment: Delete this gencric -

change, Comed Response to Innue The Note was revised to adopt the STS wording. Thic change will be provided in our comprehensive ITS Section 3.7 closcout n.bmittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RA! (Sec RAI 3 6.2-02 and 3.7.74)4).

NRC R Al Number NRC issued Date RAI Status 3.7.84)7 12/$/97 Open NRC Action Required c NRC Description of Innue 3.7.8 7 DOC M 6 CTS 3.7.4 p CTS 3.7.4.1 ACTIONS U' Justification M 6 states the following: "ITS 3.7.8 Condition B allows a 7 day Completion Time w hile CTS would allow a total of 7 days and 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months " This was based on CTS 3.7.4 ACTIONS (37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months ) and 3.7.4.1 ACTIONS (7 days). The basis for tbc statement is incorrect. CTS 3 0.3 not CTS 3.7.4 is the correct action to Reference. Comment: Correct this discrepancy injustification M 6.

Comed Responne to Innue IX)C 3.7 M6 will be revised to state, " . If for example, Unit I and Unit 2 were operating and both Unit I pumps became inoperable, CTS 3.7.4.1 would not be applicable to Unit 2 until Unit I had shutdown in accordance with 3.0.3 Actions (37

. hours) and then Unit 2 would have 7 days from the time Unit I reached Mode $ . . ." This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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Resp <mse to NRC RAI D:ted 12/35/97 27 Jan 98

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i NRCENumber NRC issued Date RAI5E~~

3.7.8-08 12/5/97 Open NRC Action Required NRC Description of innue 3.7.8 81XX: LA.12 l JFD 11ases P.18 l CTS 3.7.4.2 ACTION a l

ITS 3.7 8 ACTION 11 ITS B 3.7.811ases LCO CTS 33.4.2 ACTION a states "With one or both of the crosstic valves (s) closed and not capable of being opened from the Main Control Room, within 7 da)s restore the valve (s) to available status or open the alTected vatte(s) and maintain the affected valvc(s) open .." ITS 3.7.8 Condition 11 changes this to opposite unit SX train inoperabic". Thcre is no discussion provided as to why an explicit ITS Required Action is ret retained to " ..or open the affected valvc(s), and mamtain the affected valyc(s) open,..

This is not covered in LA.12 and there should be a justification for this change.

ITS 113.7.8 Bases LCO states that the fiow path from the unit is established or capable or being established This statement would suffice to meet the CTS ACTION requirement since it would allow the valve to remain inoperable indefini'ely. Comment: Revise the CTS /ITS rnarkup to include this CTS ACTION requirement and provide additional discussion and technicaljustification for these changes.

Comed Responne to issue Comed disagrecs. DOC 3.7 LA12 discusses uhy a specific ITS Required Action is not required for this level of detail and states, " CTS 3.7.4.1 and 3.7.4.2 include details of what constitutes operability of the opposite umt SX System (pump, and crosstic cither npen or capable of being opened from the main control room) In addition CTS SR 4.7.4.2 lists equipment t - part numbers for the crosstic valves. These details are relocated to the ITS Bases These details are not necessary to -

f- casute the SX System is Operable. The definition of Operability suffices, The requirements ofITS LCO 3,7.8 are adequate for ensuring the SX System is operable. These details are not necessary to be in the TS to ensure the SX System O can perform its inter.ded safety function. As such, these details are not required to be in the TS to provide adequate protection of the public health and safety, including this level of detail in the Bases rathct than the Specifications is consistent with ITS format guidelines. Any change to these details is made in accord.ence with the Bases Control Program desenbed in ITS Section 5.5." The crosstic velve is only one example of uhat would require entry into ITS LCO 3.7.8 Condition B In addition. Insert B 3.7 42B (Item b W the LCO Section of the Bases states, "An opposite unit SX train is considered OPERABLE during MODES 1,2,3, f ..d 4 when: ... b. A tiow path from the opposite unit is established, or capable of being established (including the opposite unit crosstic valves ISX005 and 2SX005) ." . Inherent in the phrase, "A flow path from the opposit. mit is established " is the fact that the valvc(s) arc open and maintained open.

Further, ITS SR 3.7.8.3 surveils this requvement. Comed continues to pursue this change.

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Response to NRC RAI Dated 12/05/97 27 Jes 9si f hRC RAI umherT NRC Innued Date Rkillatus 318-09 12/5/97 Open NRC Action Required NRC Dencription of Innue 318 9 DOC LA.13 JFD P.18 CTS 4 7.41 a i ITS SR 318.2 and Associated Bases CTS 414.1.a.1 requires that the opposite-unit $X pump is capable of being manually started from the hiain Control Room at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Justification LA.13 states that this requiren4nt is relocated to the TRht, since these requirements consist of panel checks and verification that the pump can be stated. This is not entirely true. ITS U 3 7 8.2 Bases SR 318.2 states that the pump shall be started from the main control room on a 31 day frequency. Thus, CTS 4.7.4.1.a.1 is included in ITS SR 318 2 but with a Less Restrictive frequency. Comment: Revise the CTS markup to reficct this Less Restrictive change, and proside additional discussion and justification for this Less Restrictive change.

Comed Responne to Innue Comed disagrecs. CTS 414.1.a.1 only requires a verification that the SX pump is capable of being manually started from the hiain Control Room every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (i c., an indication and availability check only). This SR does not require starting the pump The SR that requires the pump to run is CTS 414.1.b w hich is consistent with ITS SR 3.7.8.2. The ITS nor the NUREG require any verincation that the pump can be started from the Main Control Room. This requirement in the CTS did not meet the NRC 10 CIT.50.36(c)(2)(ii) criteria for inclusion into the ITS and therefore, is relocated to the TRM. Verifying the pump can start every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and actually tunning the pump every 31 days are two difictut requirements. Comed continues to pursue this chtnge. DOC 3.7.LA13 will be resised to state, " . These requirements consist of panel checks and verification that the opposite-unit pump can be started from the control room, and verification that a flowpath is established or capable of being estabbshed from the control room . , " This change will be provided in

our comprehensive ITS Section 3.7 closenut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

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NRC RAI Number NRC l$nued Date RAI Status 31810 12/5/97 Open.NRC Action Required NRC Description of lasue 31810 DOC LA.13 CTS 4.7.4.1.a 2 ITS SR 3.7.8.1 ITS SR 318.3 and Associated Bases CTS 414.1.a 2 requires verifying that the SX system crosstic is established or capable of being established from the Main Control Room at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This requirement is shown as being ruo; ate by LA.13. LA.13 only discusses the relocation of CTS 4.7.1.a.1 (SX pump availabin.y), not the cross-tic. This requirement is encompassed by ITS SR 318.1 and ITS SR 318.3 but hot specincally stated in the associated Bt.se;. In addition, the following would bc Less Restrictive (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 31/92 aays). Comment: Resisc the CTS /ITS markup to reflect this Less Restrictive change and provide additional disc:.ssion and justification for this Less Restrictive change.

Comed Response to instic DOC 3.7.L A13 will be resised to state, ' , These requirements consist of panel checks and verincation that the op, .' c.

unit pump can be started from the control room, and verifi ation that a flowpath is established or capable of being established from the con'rol room . " This change will be provided in our comprehensive ITS Section 3.7 closcout submittal res ision upcn NRC's concurrence with the Comed Responses to the ITS Section 17 RAl.

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Response to NRC RAI Dated 12/05/97 27 Jam 9s NRC RAI Number NRC issued Date RAI Status 3.7.8 11 12/5/97 Open NRC Action Required NRC Description of issu:

3.7811 l' C L9 CTS 3.7.4.1 ITS 3.7.8 RA B.I CTS 3.7.4.1 is associated uith opposite unit SX pump requirements. An exception to CTS 3.0 4 cxists in CTS 3 "'.4.2 for the SX crosstic, which provides the flow path for the opposite i. 't pump. Therefore, the ITS 3.7.8 RA B.1 adds a Note w hich states "LCO 3.0.4 is not applicabic" This is acceptabic, however, the Not: should additionally state that this is -

applicable "for the unit specific SX System only", as is stated in the L9. Since the Note as written could apply to both uaits uhen in this conditon, which is not the intent. Also, is the last sentence of L9 correct in referencing ACTION A.

rather that ACTION D; or, is there more than one subject being addressed? It appears there should be a . ACTIONS Note to keep the opposite unit SX train from being used for opposite unit MODE changes while supgv ng the

" remaining" unit specific SX train. Com'nent: Provide the additional discussion and technicaljustia.aition as required for this change.

Comed Mengumne to Insuc Comed disagrees. As stated in DOC 3.7 L9, the LCO 3,0.4 cxception is associated with the opposite unit, not the specine unit. Therefore, the Note is appropriately located in ITS LCO 3.7.8 Condition B Required Actions Ilowever, in the last sentence of DOC 3.7 L9, a typo was corrected to change " Action A" to "Actica B." The sentence now reads, "This will allow the unit specinc unit to change modes while relying on Action D of ITS 5 L8 which requires restoration of the opposite-unit pump in 7 days." This change will be provided in our comprehensive ITS Section 3.7 closcout submittal

- revision upon NRC's es surrence with the Comed Responses to the ITS Section 3.7 RAl.

p NRC RAI Number NRC Issued Date RAI St Ms 3.7.9-01 ,12/5/97 Open NRC Action Required NRC Description of Issue (Byron only) 3.7.91 DOC A.!

(Byron) JFD Bases P.41 CTS 3.7.5 ACTIONS ITS 3.7.9 ACTIONS and Associated Bases The UllS is shared between Units 1 and 2. There are no indications in the CTS that this system is shared between the units and no indication ofinter unit dependence in the CTS. For example, when the system or a component in the system is inoperabic and regardless of u hich MODE cach unit may be in both units must simultaneously enter the appropriate ACTIONS. The STS did not consider shared unit operation of a systam. Therefore, this ITS needs an ACTIONS Note to clarify that both units will enter the appropriate ACTIONS. The new ACTIONS Note should state: "These ACTIONS shall apply to both units simultaneously." This note will create the inter unit dependence of the design. Comment:

Revise the CTS /I's S markups and Bases to include this ACTIONS Note and provide the appropri:.tc discussions and justifications.

Comed Response in Innue

~No change. Comed disagrecs. There are several systems that arc shared hetwcen the two units uhich do not have any such note added. Operators arc trained that if a common system between the two units becomes inoperable, a unit specine OPERABILITY determination is made, in this case, if the UI-IS becomes inoperabic, both units will be made aware and appropriate unit specinc action will be taken. This is consistent with other commonly shared systems, structures, or components. Comed continues to pursue this change.

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_ _ _ _._ _ _ _ _ _ _ _ _ __ ___._ -._.__- _ _ _ . . _ f Response to NRC RAI Dated 12/05/97 27 Jtn-9st NRC RAI Number NHC Issued Date RAI Status !

3.7.9-02 12/5/97 Open. Comed Action Required 4 NHC Description of Inouc

' l (Dyron only) 3.7.9 2 DOC A1 (Dyron) DOC A.14 t

DOC A 35 DOC A 4it 3 DOC 1.A 30 4

DOC LA.31 DOC L.22 DOC L23 DOC L 24

JFD P.21 JFD Bases P.42 CTS 3.7.5 ACTIONS i

A number of CTS 3.7.5 ACTIONS have been overlooked and/or mod.5ed by the lack of a complete definition of '

OPERADILITY for the UllS. Some of these CTS requirements have no equivalent ITS 3.7.9 ACTION requirements, others have been proposed as ITS 3,7.9 SRs, and others have been included in plant specific ITS 3.7.9 ACTIONS. Thesc changes have been proposed and justified as Administrative (A), Less Rewictive . Relocated (LA) and Less Restrictive (L) changer some of w hich have inadequatejustifications, are beyond scope or review items, or cor.stitute major changes in the oper:' tion of the UHS. The succeeding comments highlight the major concerns and problems found by the staff. See item Numbers 3 7.9 3,3.7.9 4,3.7.9 5,3.7.9-6,3.7.910,3.7.911 and 3.7.913. Comment: In light of the above and the succeeding comments (see item Numbers 3.7.9 3,3.7.9 4,3.7.9 5,3.7.9 6,3.7.910,3.7.911, and 3.7.913). Licensec '

should re-evaluate or rethink the CTS ACTIONS and the ITS ACTIONS to assure that all the CTS UllS OPERABILITY requirements have been addressed Comed Response to issue Comed has reviewed the NRC RAls and corrected the ITS ACTIONS where applicable. Sec Comed responses to RAI 3.7.9 03,04,05,06,10,11, rmd 13. These changes will be provided in our c>.uptchensive ITS Sec'. ion 3.7 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (Scc RAls 3.7.9 03, 04,05,06,10,11, and i3.)

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Response to NRC RAI Dated 12/05/97 27 Jax-98

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NHC M AI Number NHC lasued Date RAI Status 3.7.9-03 12/$/97 Open. Comed Action Required NRC Description of leeue i (113 rorwnly) 3.7.9 3 DOC A 34 (B3ron) JFD P.21 l JFD llases P.42 l CTS 3.7.5 ACTION a l ITS 3.7.5 ACTION 11 and Associated flases C15 3.7.5 ACTION a specifics that with a water level ofless than $0*4 in either UllS cooling towcr basin, restore the

- water level to at least 50% in each UllS cooling tower basi,i within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The CTS markup changes "cither to "onc" and "cach" to "the" so that ITS 3.7.5 Condition 11 would read 'One basin level <$0%" with a Rcquired Action and Completion Time of ' Restore basin level to >$0% in *6 hours" respectively. This change has been characterited as an Administr"ive change (A.34) This change is not an administrative change but a More Restrictive change. As currently written CTS 3.7.5 ACTIO* nould allow one or both UllS cooling tower basins to be inoperable due to water level. In that situation, particularl vai both basins out,6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed to restore both basins to OPERABLE status, before a shutdown is required The ITS would require an immediate shutdown per ITS LCO 3.0.3. Comment: Provide a discussion and justification for this more Restrictive change.

Comed Responne to Inouc No change. Comed disagrecs with the Staffs discussion in detcimining that this change is a more restrictive change.

CTS 3.7.5 Action a, with a water level of less than 50% in either (one or the other, OA or OD) UllS co: Jing tower basin, requires the water level be restored to at least 50% in cach (both) Ulls cooling tower basin within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If the level in either cooling tower was still below the TS levtl requirement of $0% after the 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , CTS would require an immediate shutdown per LCO 3.0.3 of both units. Comed continues to pursue the identified CTS markup changes of"cither" to "onc" and "cach" to "the" consistent with station operating philosophy. (Sec RAls 3.7.9 02,04,0$,06,10,11, and 13.)

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Response to NRC RAI Dated 12/0N97 27 Ja 9N

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NRC RAI Number

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NRC lesued Date RAIStatus

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3.7.9 04 12/$/97 Open . Comed Action Required NMC Descriptkm of issue (Hyron only) 3.7.9-4 DOC A.35 (llyron) DOC LA.30 DOC L 22 DOC L23 JFD P.21 JFD 11ases P.42 l

CTS 3.7.3 ACTIONS c and d l.

ITS 3.7.9 ACTION C and Associated Bases -

l. CTS 3.7.5 ACTION C requires the restoration of the inoperable essential senice water (SX) makeup pump in either 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (ACTION c.1) or 7 or 14 days depending on the plant conditions specified in ACTION c 2. A.3$ states that the restoration time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is not included in the ITS 3.7.9 ACTION C because ITS 3.0.2 allows restorative of the affected component within the time limits of the specified Required Action.- L 22 states that the 7/14 day restoration time =

is based on the availability of other basin makeup sources Thus, ITS 3.7.9 ACTION C is based on ITS. ACTION c I for an inoperabic cooling tower basin switch ( Automatic SX makeup pamp start switch) w hich nilows indefinite operation with an inoperable switch. This is unacceptable to the staff, however, the change in CT S 3.7.5 Action c ftom cooling tower basin nitch to SX makeup pump is acceptable since the switch is a support component necessary for pump OPERADIL11Y. Th: current licensing basis requires pump restoration, which ITS 3.7.9 ACTION C does not require. In addition certain assumptions are made with regards to the alternate makeup sources which were not part of the initial stati resiew. Therefore, the change based on L.22 is considered to be a beyond scope of review item for this conversion, Comment: Resisc ITS 3,7.9 ACTION C to iriclude the restoration of the inoperable SX makeup pump to OPERABLE statut in accordance with the CTS and prmide additional discussions and justifications to support these required changes.

p Comed Response to issue Comed will resise ITS 3.7.9 Required Action C to include the restoration of the SX makeup pump to the OPERABLE status as Required Action C.3. This will require that the SX makeup pump be restored to the OPERABLE natus within 7 days if both units are in MODE l 4, or 14 days if either unit is in MODE 5 or 6. The ITS Bases will be enhanced for RA C.3 to include the reason for the 14 day allowance with cither unit in MODE 5 or 6 and a pump inspection and extended maintenance work window scheduled. CTS DOC L22 will be deleted This change will be provided in our comprehensive ITS Section 3.7 closcout submittal resision upon NRC's concurrence with the Comed Fesponses to the ITS Section 3.7

- RA1. (Sec RA1s 3.7.9p,03,05,06,10,11, and i3.) .

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NRC RAI Number NRC issued Date RAI Status 3.7.905 12/5/97 Open . ComBd Action Required 1

NRC Descriptkm of lance (Byron only) 3.7.9 5 DOC A.48 4

(11yron) DOC L24

JFD P.21 i

, JFD P.22 l JFD 11ases P.42 i JFD llancs P.43 l CTS 3.7.5 AC110N g ITS ACTION D i ITS SR 3.7.9.1

ITS SR 3.7 9.4 and Associated Dases

, CTS LCO 3.7.5 ACTION g provides one hout to cenntm river level and flow, if thcr level it below 670.6 feel MSL ITS SR 3.7.9,4 conGrms river level on a 24 hout basis, w hile SR 3.7.9.1 confirms river ! cycl and flow on a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months basis if ITS SR 3.7.9.4 is not met. Thejustification (A 48) states that 'If SR 3.7.9.4 is not met. ITS LCO 3.7.9 Condition D would be entered Condition D requires verificatlan of basin levels and operability of one makeup source within I hour. There is always the option to testore compliance with the LCO within the stated Completion ' lime. Therefore, within the I hour, ITS SR 3.7.9.1 could be performed and if the SR was met, Condition D cxited " This is not true. IfITS SR 3.7.9.4 is not met, then ITS SR 3.7,9.1 must be met, w hich would require the immediate performance of this SR. It is conceivable at this time that ITS SR 3.0.3 could apply thus allowing 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to peiform this SR, before entering ITS 3.7.9 ACTION D.

This is not the intent of the CTS or the ITS. The staff believcs that CTS 3.7.5 ACTION g i should be retained as a

- separate ITS ACTION, ITS SR 1.7.9.1 be deleted and ITS ACTION D be m(vhfixt to include an additional condition for Required Action and Associated Completion Time of the rncr levelITS AC11DN not met. Comment: Revise the CTS /ITS submit'al along the lines suggested and provide appropriate additional discussions and justifications.

i O CemEd Response to insuc Comed agiccs that the requirement to verify river level and flow within one hour in accordance with the requirements of CTS 3.7.5 g should be included in SR 3.7.9.1 and not depend on the Required Action nf Condition D. SR 3,7.9.1 would requite an initial I hour, and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thercafter, surveillance frequency if river level is below 670.6 feet MSL Com Ed does not agree that ITS Required Action D should be modified to !nclude the additional actions for river level. ITS SR 3.7.9.4 will continue to confirm riwr level on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months basis, while SR 3.7.9.1 confirms dver level and flow within I hour from tne failure to meet the requirements ofITS SR 3.7.9.4 and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thercafter if ITS SR 3.7.9.4 is not i

met. DOC A48 will be deleted and JFD P22 will be revised to include the requirements cf CTS 3.7.5 g. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl - (See RAls 3 7M 02,03,04,06,10,11, awl 13.) ,

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5RC5Ai5u'mlc~r $ E Elseved D W __ . . R IStatus 37946 12/$/97 Open. Comed Action Required NRC Description of leaue (Byron only) 3194 DOC LA 24 (Byron) DOC L 22 CTS 4.7.5 c 4 CTS 4.7.$ 1 CTS 41$ c 4 and CTS 4.7.S.i require starting the deep well pumps every 31 days and wifying the flow rate once per 18 months The deep well pumps are noi included in ITS 3.7_.9 s: ce they are consider as the backup to the SX makeup -

pumps. The CTS requirements are relocated to Ibn TPM which is acceptable.- llowever, the justification (LA.24) states that the pumps are not directly related to UllS OPERABILITY. This is incorrect. Even though this backup system is a Class 11 system (per L22), it serves as a support system to the UllS, thus is directly related to UllS OPERABILITY in that ifit is directly related to UllS OPERABILITY in that if it is inoperable ITS 3.7.9 ACTION E would have to be entered Commen" Corrected this error in justification LA 24.

Comed Responte to lanue Comed will delete the t.cntence that states the deep well pumps are not directly related to UMS OPERABILITY in DOC LA24. This change will be provided in our cornptchensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (Sec RAls *.1.9 02,03,04,05,10,11, and 13 )

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Response to NRC RAI Dated 12/05/97 27 Jan 9s NRC MAI Number NRC Issued Date RAI Status 3.7.9 07 12/3/97 Open.NRC Action Required NRC Deuription of Issue

-(D> ton only) 319 7 DOC LA 2$

(D) ton) CTS 415 c.)

CTS 4.7.5 f CTS 4.7 $.h CTS 4.7.5 c.1,415 f and 415 h detail requirements foc the OPERAlllLITY of the dicsci portions of the dicsci driven SX makeup pumps. These requirements are not included in ITS 319 but have twen relocatal to TRM. While the dicsci inspection requirement for CTS 4.7 5 h (see item Number 319 8 for valve requirements) can be relocated (Sec item Number 315 2), the other dicscl requirements must be maintained in the ITS Sec item Number 315 2 for the reasons

for retention. Comment: Revise the CTS and ITS submittals according the discussion in item Number 31$ 2 and

i. provide any additional discussion and justification to support these changes.

Comed Response to lanue No change. Comed disagrecs that CTS 415 c.1,41$.f and 415 h need to be incorporated into the ITS. The information contained in these CTS SRs requite that in order for the dicsci powered essential service watcr makeup pump to be demonstrated OPERAULE, the fuct supply tank shall maintain a volume of 36% dicscl fuel oil. This is to be verified every 31 days. Every 92 days the drain satnple of dicsci fuel from the fuel storage tank is obtained and tested in accordance with a specified ASTM. In addition, every 18 months the dicsci shall be inspected in accordance with the manufacturer's recommendations The NRC reviewer states that the staff finds relocating these requirements to the TRM is unacceptable and they are needed to demonstrate OPERAi!!LITY of the dicscl pump. Essentially all CTS SRs make a generic introductory statement tha' a specific component or picec of equipment shal be demonstrated OPERAI1LE by the successful performance of a specific SR. Almost all of the CTS SRs relocated to the TRM contain the exact same statement of demonstrating OPERABILITY through the performance of the SR. The difTerence between retaining specific O requiremcets in the ITS or relocating them to a licensec controlled document (i c., TRM)is if the requirement meets the NRC criteria as stated in 10CFR$0.36(c)(2)(ii), in this rpecific case, the requirements being relocated do not meet the NRC acceptance criteria as stated in 10CFR50.36(c)(2)(li). R$ locating the subject SRs to a licensec controlled document does not clim,nate these requirements, does not change frequency of verifying the dicsci fuct oil volume, not climinate any inspections being performed in accordance with the manufacturer's recommendations. Comed fccis that these requirements are still essential and relocating them to a licensec controlled document does not in any way lessen their importance. Once these requirements are maintained in a licensee controlled doemnent any changes would be sebject to a 10CFR50.59 cvaluation. In addition, all th STS 315 SRs as stated in NUREG 1431, are maintained in the ITS with minor changes made to accommodate plaat design and current licensing basis. These SRs have been identified by the NRC and industry as adequate to demonstrate OPERADILITY from a STS point of view. Based on the fact that the subject requirements are maintained in a licensec controlled document as required by 10CFR$0.36(c)(2)(ii) the ITS will

-not be revised to incorporate these requirements Comed continues to pursue this change.

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Resporise to NRC RAI Dated 12/05/97 27 Ja9s NRC MAI Number NRC lanced Date RAI Status 3.7.948 12/5/97 Open NRC Action Required NRC Description of Innue (Dyron only) 3.7.9 M DOC LA.25 (Dyson) CTS 4.7.5.h CTS 4.7.5.h in addition to requiring an 18 month inspection of the SX pump dicsci also requires " cycling cach testabS valve in the flow path through at least one complete cycle of full travel " The CTS n.arkup shows this requirement as being relocaicd (LA.25), but nojustification is provided to show that it can te relocated or to w hich licensee controlled document. Since other C'IS LCOs which require valve cycling have incloded this requirement in the associated ITS SRs, this requirement should also be included in ITS 3.7.9. Comment: Revise the CTS /ITS markup to retain this valve cycling require and provide appropriale discussion andjustification.

Comed Renponse to Innue This requirement is being relocated to the TRM in accordance with tne NRC 10CFR50.36(c)(2)(ii). DOC LA25 will be revised to specifically state this relocation. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal rcvision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NFC RAI Number NRC lieued Date RAI Status 3,7.9-09 12/5/97 Open.NRC Action Required NRC Description of Innue (Dyron onl3 ) 3.7.9 9 DOC LA.28 -.

(llyron) CTS 4.7.5 d ITS B3,7.9 Dases - SR 3.7.9.5 r

CTS 4.7.5 d details design attribetes of how to perform the UllS fan surveillance (e g , by starting from the control ren).

These items are to be relocated to the TRM and to the ITS Dases. The detail on starting the fan from the control room for -

this surveillance has not been relocated to ITS 13 3.7.9 Bases SR 3.7.9.5 as stated above. Comment: Include this item in the discussion ofITS D 3.7.9 Dases . SR 3.7.9 5 or provide additional discussion and justification to . how why .t should not be relocated there.

Comed Responnt to Issue Comed will relocate the det::il of starting the fan from t!.c control room for the performance of SR 3.7.9.5 to the Surveillance Requirements Section of the Bases for ITS LCO 3.7.9. This change wil! be provided in our comprehensive ITS Section 3.7 closcout subtrittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

39-

Response to NRC RAI Dated 12/0N97 27.hn9s

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NRC RAI Number NRC Innued Date RAI Status

.17.9 10 12/5/97 Open. Comed Action Required N'tC Description of Issue

- (!)yron only) 3.7.910 DOC LA 30 (Dyron) DOC L 24 JFD P.21 JFD liases P.42 CTS 3.7.5 ACTION c 2 CTS 3.7.5 ACTION g 2 ITS 3.7.9 ACTION D and Associated Bases CTS 3.7.5 do:s not include specine ACTIONS for the case of two inoperabic SX makeup pumps except for inoperability due to river water level and cooling tower basin switches. Therefore, CTS LCO 3.0.3 would apply for all other SX makeup pump inoperabilitics. ITS .17.9 ACTION D trics to combec the modtfied CTS 3.7.5 ACTWS c.2 and g 2 for two SX makeup pumps inoperable. LA 30 changes the words in CTS 3.7.5 ACTION c.2 from " cooling tower level basin switches" to SX makeup pumps," While this may be an acceptable change for one switch /onc pump inoperabic, it may not be for two switches / wo pumps inoperable. With 2 cooling tower level basin switches inoperable, the licquired Actions of CTS 3.7.5 ACTION c.2 takes into account the manual start /stop capabilitics of the SX makeup pumps, and the alternate makeup source. This particular aspect of CTS 3.7.5 Action c.2 has not twen addressed in either LA.30 or L24. Sec item Numbers 3.7.913. Comment: Provide additional discussion and justification on this aspect of CTS 3.7.5 ACTIOtl c 2 and its effect on the conversion to ITS 3.7.9 ACTION D. Sec Item Number 3.7.913.

ComF.d Response to Innue Comed disagrecs 7As stated in DOC 3 LLA30 the level switch function is considered part of the SX makeup pumps 0" ERA 111LITY and discussed in the LCO Section of the 13ases for pump OPERABILITY with changes justified by Bases -

NDs P41 and P42 and LCO JFD P21. If one of the level switches were to become inoperable and unable to perform its O - intended function, then one SX makeup pump would he declared inoperable and Condition C cntered. With two level switches inoperable, two SX makeup pumps would be inoperable and Conditior D would be entered. With two cooling tower level basin switches inoperabic, Required Actions of Condulon D ofITS 3.7.9 take into uccount the manual start /stop capabilitics of the SX makeup pumps with the ucfinition of an associated makeup source discussed in the

- Actions Section of the 11ases for Required Action C. Comed continues to pursue this change. (See RAls 3.7.9-02,03,04, 05,06,11, and 13.)

O_

40

..__.__,..___.._.~-~_m,.

Response ta NRC RAI Dated 12/05/97 27.Jax 9x

! . NRC RAI Number NRC Inved Date RAI Status 3.7.9 11 12/5/97 Open . Comed Action Required NRC Description of Inoue (D3 ron only) 3.7.911 DOC LA 31 (Dyron) JFD P.21 JFD Bases P.41 JFD Bases P.42 CTS 3.7.5.f CTS 3.7.5 h C1S 315 ACTION f CTS 3.7.5 ACTION h ITS 3.7.9 ACTION D and Associated Bases CTS 3.7.5.f and 3.7.5.h specify that (111S OPERABILITY is dependent on the National Weather Service (NWS) forecasts of Rock Rher flood level and tornados respectively. CTS 3.7.5 ACTIONS f and h are the remedial actions that are taken uhen the NWS forecasts high river level (>702 fl.) and tornados respectively. While the staff agrecs in part that these anticipatory actions can bc relocated from the CTS to licensec controlled documents, the staff does believe that these anticipatory actions should be relocated to the plant emergency procedures or operating procedures due to the safety significance of the conditions. Ilowever, it is also the stafi's position that CTS 3.7.5 ACTIONS f and h be retained in some form in the ITS. The reason for this is even though both ACTIONS are anticipatory actions to be taken prior to the occurance of the conditions or event, both ACTIONS also apply aller the event ha i occurred and exiting the ACTIONS will depend on when the event ends. Even though both ACTIONS deal with two SX makeup pumps inoperable (CTS 3.7.5 ACTION f river water level > 702 ft and CTS 3.7.5 ACTION h river water level < 664.7 ft) the CTS ACTIONS are either More Restrictive or Less Restrictive than ITS ACTION D. Comment: Revise the CTS /ITS markup to include CTS

3.7.5 ACTIONS f and h in ITS 3.7.9 and provide the appropriate discussions andjustifications for the proposed changes.

Comed Responne to issue V Comed disagrees. As the staff has suggested, current Cyron Operating Abnormal procedures , OBOA ENV 1 Adverse Weather Conditions and OBOA ENV.2 Rock River Abnormal Water Level contain all of the Requircd Actions of CTS 3.7.5 Actions f and h. When contacted by the NWS of the issuance of a tornado watch or warning or of the Rock River exceeding the flood level requirements for SX makeup pumps OPERADlLITY, these procedures are entered and the appropriate actions taken Once the event is declared, the procedures and Actions are in clicct until the event has been terminated and the BOA exited. The NRC reviewer states that the Staff finds relocating these requirements to the TRM is acceptable but may be exited prior to the event ending; however, the original condition to enter the TRM Specification would not have been declared as over not allowing exiting of the requirement. Essentially all CTS SRs make a gencric introductory statement that a specific component or piccc of eqaipment shall be demonstrated OPERABLE by the successful performance of a specific SR. Almost all of the CTS SRs relocated to the TRM contain the exact same statement of demonstrating OPERABILITY through the performance of the SR. The difference between retaining specific requirements in the ITS or relocating them to a licensee controlled document (i c., TRM) is if the requirement meets the NRC criteria as stated in 10CFR50.36(c)(2)(ii). Comed continues to pursue this change. (Sec RAls 3.7.9-02,03,04,05, 06,10, and 13.)

=_ =.=.

V

~

41

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Resgumse to NRC RAI Dated 12/05/97- 27 Jr.3-9s

-... _ = .- -

__= _

NRC RAI Number - NRC leeued Date RAI Status O 1,7,9 12 12/5/97 Open NRC Action Required b NRC Ikacription of issue (13yron only) 3.7.912 DOC L $

(ll> ron) JFD P,30 JFD Ilases P 43 CTS 4.7.5 c.2 ITS SR 3.7.9.7 CTS 4.7.5 c.2 verines every 31 days the starting of the diesel from ambient conditions on a low basin level test signal. ITS SR 3.7.9.7 has changed this Frequency to be consistent with the IST Program The justincation for this change is unacceptable; consistency with the NUREO is not ajustincation for changing a Frcquency. Comment: Revisc the submittal to provide the additional discussion and technicaljustincation for this Less Restrictive change.

Comed Resp <mee to issue No change. The 31 day Frequency did not change. The Frequency statement in the NUREO of, "In accordance with the Inservice Inspection Testing Program" was used in ITS 3.7.9.7. The 31 days has been incorporated into the IST Program. Comed has not made any Frequency changes for this SR. Comed continues to pursue this change.

O O

4

~

lbsponse t: NRC RAI Dat-d 12/05/97 ~ 271:n 9H

. . = _ _ ,= _

NRC RAI Number NRC luued Date RAI Status (d' 3.7.9 l.1 N RC Description of luue 12/5/9/ Open Comed Action Required (Byron only) 3.7.913 DOC L24 (Dyron) ED P.30 l JFD Bases P.43 CTS 3.7.5 ACTON c.2 CTS 3.7.5 ACTION g 2 ITS 3.7.9 ACTION D and Associated 11ases CTS 3.7,5 ACTIONS e 2 and g 2 are modified byjustification L24 and combined into ITS 3.7.9 ACTION D. L 24 states that the modification places the plant in a condition where the safety function assumed in the design basis analysis can be satisfied and is consistent with CTS 3.7.5 ACTIONS c 2 and g 2. This is not true. See Item 3.7.910 for one aspect of this problem CTS 3 7.9 ACTION g 2 a requires that both deep wcli pumps be vertfied OPERABLE within I hour not one pump in, ne hour and the other in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months as proposed in ITS 3.7.9 Ar$ON D. CTS 1.7.5 ACTION g 2 b specifies the requirements with one deep well pump inoperabic. Implicit in this ACTION is that the cooling tower basin levels could be below H2% Thus 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months uould be allowed to not only restore the pump to OPERABLE status but also the basin water l level. ITS 3.7.5 ACT ON D does not allow this, ITS 3.7.5 ACTION E, immediate shutdown, woulo have to be entered.

In addition ITS 3.7.5 ACTION D has a Note which states that "LCO 3.0.4 is not applicable." This note applies to all of ACTION D. h, the CTS the provisions of CTS LCO 3 0.4 only apply if teth deep well pumps arc OPERABLE, the ITS would allow this to apply if one deep wcil pump is inoperable. Based on the above as wcll as other items, ITS 3.7.5 ACTION D needs major rcwork. Sec item Numhr 3.7.911. Comment: Revise CTS /ITS markup to correcity rcilect the design and current licensing basis for two SX makeup pumps inoperable and provide the appropriate additional discussions andjustifications to support the proposed changes Comed Response to luuc

( ) Comed agiecs that in order to conectly apply the Note for 3 0.4 not t . plicable another Condition (Condition E) should be L/ added This would allow Condition D io address the inoperability of two SX makeup pumps by verifying both SX basin levels at greater than 82% and the OPERABILITY of both makeup *ources within ore hour To be consistent with CTS 3.7.5 g 2 b), if one of the deep wcil pumps wcre inoperable, a Condition E would address both SX basin levels at greater than 82% and also would require verification of the OPERABILITY of at least I makeup sources, with the requirement to restore the inoperable makeup source to OPERABLE status uithin a 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months This change will be provided in our comprehr+c ITS Section 3.7 closcout submittal revision upon ?'rtC's concurrence with the Comed Responses to the ITS Section 3a NmEd disagrees: As stated in DOC 3.7 LA33 for CTS 3.7.5 g, the level and flow of the river is considered pan J ' 'X makeup pumps OPERABILITY and is discussed in !be LCO Section of the Bases for pump OPERABILITY. As directed by CTS 3.75g, if the level of the Rock River were to go to 664.7 feet MSL or less, both SX makeup pumps would be declared inoperable and Condition D entered With two inoperable SX makeup pumps, Condition D would require that both SX basin levels be veri!bd at greater than or equal to 82% and also would require venfication of the OPERABILITY of both makeup sources (i c., only deep well pumps Operabic). Consistent with CTS 3.7.5 g 2.b) the proposed Condition E would define if one of the deep well pumps were inoperable, a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is granted to restore both deep well pumps to the OPERABLE status (See RAls 3.7.9-02,03,04,05,06,10, and 11.)

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NRC RAI Number NRC issued Da'e RAI Status l 3.7.9 14 12/5/97 Open NRC Action Required NRC Description of lanue (flyron only) 3.7.914 DOC L 24 <

(Dyron) CTS 3.7.5 ACTION g 2) c)

CTS 3.7.5 ACTION g 2) c) requires the plant to be placed "in at least ilOT STANDI3Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and at least ilOT SilVTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and at least COI D SliUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

The CTS markup deletes the words "and at least 110T SliUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ." The deletion is

- designated 1.24. Justification L.24 does not address this deletion. Comment: Provide a discussion and justification for this deletion.

Comed Respoate to km Comed uill revisc DOC L24 to include a discussion on dc!cting the requi cment for going to llOT SIIUTDOWN. This change will be prosided in our comprehensive ITS Sectio 13.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NRC RAI Number NRC lasued Date RAI Status 3.7,9 15 12/5/97 Open NRC Action Required NRC Description of Issue (13yron only) 3.7.915 JFD 13ases 13 20 (Dyron) CTS 3.7.5 d CTS 4.7.5 b ITS SR 3.7.9,3 and Associated Bases t CTS 3.7.5 d and 4.7.5.b specifics the UliS temperature limits uhich are to be taken at the discharge of the SX pump. ITS 3.7.9.3 and its Associnted 13ases specifies the temperature limits, but does not specify the location (SX pump discharge)

This should be reflected in the Bases discussion for ITS SR 3.7.9.3 since it is a plant specific detail. Comment: Revisc -

the CTS /ITS markup to show the relocation from the CTS and the inclusion in the ITS Dases of this detail and provide the appropriate discussions and iustifications for this Less Restrictive change.

Comed !!csponse to linue Comed will resisc Bases SR 3.7.9.3 to specify the UllS temperature (s) are to be taken at the discharge of the SX pump.

This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3,7 RAl.

J 4

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Response to NRC RAI Dated 12/05/97 2Na>98

====- . . = = = = - = = = - = = = = = = = = = = = = = = = = = = = = = = -

NRC RAI Number NRC Issued Date RAI Status 3.7.9 16 12/5/97 Open . NRC Action Required NRC Description of issue (Draidwood onl3 ) 3.7.916 DOC A.I (Braidwood) FD Bases P.19 CTS 3.7.5 ACTIONS ITS 3.7.9 ACTiuNS and Associated Bases The UllS is shared betaeen Units I and 2. There are no indications in the CTS that this system is shared between the units and no indication ofinter unit dependence in the CTS. For example, when the system is inoperable and regardless of uhich MODE cach unit may be in both units must simultaneously enter the appropriat; ACTIONS. The STS did not consider shased unit operation of a system. Therefore, the ITS needs an Actions Note to clarify that both units wi'l enter the approprint: ACTIONS. The new ACTIONS Note should state. "These ACTIONS shall apply to both units simultaneously? This Note will create the inter unit dependence of the design. Comment: Resisc the CTS /ITS markups and Bases to include this ACTIONS Nc e and provide the appropriate discussions andjustincations.

Comed Response to I.nue No change. Comed disagrees. There are several systems that are sharad between the two units uhich do not have any such note added. Operators are trained that if a common system betuwn the two units becomes inoperabic, a unit specific OPERABILITY determination is made. In this case, if the UllS becomes inoperable, both uruts will be made aware and appropriate unit specific action will be taken This is cc asistent with other commonly shared systems, structures, or components. ITS is consistent with the meaning and intent of CTS, and the licensed Operators are very well trained in, and familiar with, the application of technical specifications to shared system inoperabilitics. Comed continues to pursue this change. (Sec RAls 3.7.10-01,3

Il 01, and 3.7.12 01.) 1 NRC RAI Number NRC Issued Date RAI Status Q 3.7.9 17 12/5/97 Open 4 NRC Action Required NRC Description of issue (Bralduood only) 3.7.917 DOC LA.14 (Draidwood) CTS 4.7.5.2 ITS 3.7.9 CTS 4.7.5.2 requires the performance of a hydrographic surwy every 18 months to verify no degradationr o the UllS. ITS 3.7.9 does not contain this plant specific surveillance. The stated justification (LA.14) for relocating this requirement is based upon the STS does not contain a similar requirement or this level of detail. This is technically inadequate. While the staff agrecs that CTS 4.7.5.2.b (UllS slope degradation) can be relocated to the TRhi, it does not agree that CTS 4.7 5 2.a can be relocated While slope degradation is important to UllS OPERABILITY, it is a subjective verification and is less critical than maintaining the necessary depth to assure an adequate water supply for the UliS. The depth verincation (CTS 4.7.5.2.a) is analogous to maintaining a specific UllS water level (CTS 4.7.5.1 and ITS SR 3.7.9.1).

Therefore the staff requires this requirement to be retained. Comment: Revise the CTS /ITS markup to retain CTS 4.7.5.2 a and provide additional discussion and justifications to support the retention of CTS 4.7.5 2.a and the relocation of CTS 4.7.5.2 b.

Comed Response to issue No change. Comed disagrecs. ITS SR 3.7.9.1 only requires that the UllS water level be verified every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is in full compliance with NUREG 1431. The NRC resiewer is requesting Comed to desiate from the NUREG by incorporating the bottom level of the Ultimate lleat Sink (UllS) into the SR. The CTS currently contains the bottom level however, in accordance with the NRCs 10CFR50.36(c)(2)(ii) criteria, this information is Tiocated into the TRht.

Relocating this requirement into the TRh1 does not lessen the need or importance of monitoring the bottom level of the UllS or reduce its frequency. Once in the TRht, any changes to the requirement must be made in accordance with the

$0.59 process. Relocating this requirement to the TRh1 is consistent with other important parameters that need to be O retained in a licensce controlled document and not the ITS. Corned continues to pursue this change.

45

Response to NRC RAI Dated 12/05/97 27 Jan 9

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

NRC RAI Number NRC issued Date RAI Status 3.7.10 01 12/$/97 Open.NRC Action Acquited C NRC Description o'lanue 31101 DOC A.1 JFD 13ases P.21 CTS 3.7.6 ACTIONS

.TS 3.7.10 ACTIONS and Associated Bases The Control Room Ventilation System is two independent trains uhich serve one control room em'clope that is shared between Units I and 2. There are no indications in the CTS that this system is shared between the units and there is not indication ofinter unit dependence in the CTS. For example, wben one train is inoperable und regardless of which MODE cach unit may tw in, both units must simultaneously enter the appropriate ACTIONS. The STS did not considered shared unit operation of a system therefore, the ITS needs an ACTIONS Note to clarify that both units will enter the appropriate ACTIONS. The new ACTIONS Note should state: "These ACTIONS shall apply to both units simultaneously." This Note will create the inter unit dependence of the design Comment: Revise the CTS /ITS markups and Bases to include this ACTIONS Note and provide the appropriate discussions andjustifications Comed Responne to issue No change. Comed (syces There are several systems that are shared betueen the two units % hich do not have any such note added. Opert ; ors are trained that if a common system between the two units becomes inoperable, a unit specific OPERABILITY determination is made. In this case, if the control room ventilation becomes inoperabic, both tmits will be made aware and appropriate unit specific action will be taken. This is consistent with other commonly shared systems.

- structures, or components. ITS is consistent with the meaning and intent of CTS, and the licensed Operators are very well trained in, and familiar with, the application of technical specifications to shared system inoperabilitics. Comed continues <

to pursue this change.1Sec RAls 31916,3.7.1101, and 3.7.12 01.)

m=

NRC RAI Number NRC 16mued Date RAI Status 3.7.10 02 12/5/97 Open.NRC Action Required NRC Description of Issue 37,102 IsOC LA.17 ,

CTS 4 7.6.b ITS B3.7.10 Bases LA.17 specifics that the details of system OPERADILITY, design and methods of performing SRs are relocated to the ITS B3.7.10 Bases. CTS 4.7.6 b spvifics that the VC Filtration System be tested "at least once per 31 days on a STAGGERED TEST BASIS by initiating from the control room .. and verifying that the system operates for at least 10 continuous hours.. ." the "by initiating from the control room" is to be relocated by LA.17 to ITS B3110 Bases. This detail has not been relocated to ITS B 3.7.10 Bases. Comment: Revisc ITS B 3.7.10 Bases to include this detail.

Comed Response to issue Comed will revise the Surveillance Requirements Section of the Bases for ITS LCO 318 to include that flow shall be initiated from the control room for SR 3.7.10.1. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

l 46 i

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Response to NRC RAI Dated 12/05/97 2Ala9s NRC RAI Number NRC inoued Date RAI Status 3.7.10-03 12/5/97 Open.NRC Action Required NRC Description of issue 17.10 3 JFD C.9 STS 3.7.10 APPLICABILITY

- ITS 3.7.10 APPLICADILITY ITS 3.7.10 APPLICAlllLITY modifies STS 3.7.10 APPLICABILITY to place semicolons between MODES and specified conditions and to use "and's between APPLICABILITY specified conditions. This generic change is described in C 4 as WOG Hl.- It is the staff's understanding that WOG 81 has been rejected by the Owners Group. Comment: Delete this generic change.

Comed Responne to Innue WOG 81 will be withdraw n in its entirety throughout the ITS submittal. The submittal will be revised to adopt the STS presentation in the Applicability Section. T!Ps change will be provided in our comprehensive ITS Section 3 7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (Sce RAls 3.7.11-02, RAI 3.7.13 06,3.9.4_06, and 19.7 05.)

NRC RAI Number NRC lanued Date RAI Status 3.7.10-04 12/5/97 Open.NRC Action Required NRC Description of lanue '

3.7.10 4 JFD Ilases P.21 STS D3.7,10 Bases . BACKGROUND ITS B3.7.10 Bases . BACKGROUND STS 113,7.10 Bases . IIACKGROUND, the last sentence of the eighth paragraph states "The CREFS is designed in accordance with Scismic Category requirements." This scatence has not been adopted in the ITS, Bases P.21 does not explain this deletion. Comment: Provide additional dixr.aion and justification to explain why this STS text was not adopted.

Comed Responte to Innue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (Sec RAI 3.7.11 3.)

- _ = -m == ==

0 47

Response to NRC RAI Dated 12/05/97 27-Jan-98 NRC RAI Number NRC Inued Date RAI Status 3.7.11 01 12/5/97 Open - NRC Action Required NRC Description ofIssue 3?.Il 1 DOC A.I JFD Bases P.21 CTS 3.7.6 ACTIONS

] ITS 3.7.11 ACTIONS and Associated Bases Corument: See item Number 3.7.!01 Comed Response to issue No change. Comed disagrecs. There are several wvms that are shared betwccn the two units whic'i do not have any such note added. Operators are trained that if a common system between the two units becomes inoperabic, a imit-specific

, OPERABILITY determination is made in this case, if the ce'itrol room ventilation temperature control system becomes inoperable, both units will be made aware and aporna ~ mit-specific action will be taken. This is censistent with other commonly shared systems, stiuctures, or e .omstant with the meaning and intent of CTS, and the licensed Operators are very well trained ~ n "

.th, the application of tecnnical specifications to si.ared system inoperabilitics ComLd continues to p- /Sec RAls 3.7.9-16,3.7.10-01, and 3.7.12-01.)

NRC RAI Number hnC issued pate RAI Stati s 3.7.11-02 12/5/97 Open - NRC Action Required 3

NRC Description of Issue 3.7.11 2 ITD C.9 STS 3.7.11 APPLICABILITY ITS 3.711 APPLICABillTY ITS 3.7.11 APPLICABILITY modifics STS 3.7.11 APPLICABILITY .n accomance with WOG-81. See item Number 3.7.10 3. Comment: See item Number 3.7.10-3.

Comed Response to issue WOG 81 will be withdrawn in its entirety throughout the ITS submittal. The subtr,.r.al will be revised to adopt the STS presentation in the Applicability Section. This change will be provided in our comprehensive ITS Section 3.7 closcout submittat revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI. (See RAls 3.7.10-03, RAI 3.7.1"-%,3.9 LO6. and 3.9.7-u5.)

NRC RAI Number RC lssued Date RAI Status 3.7.11-03 12/'!97 Open - NRC Action Required Nhc Description of inst.c 1.7.11-3 JFD Bases P.21 STS B3.7.11 Bases - APPLICABLE SAFETY ANALYSES i

.TS B3.7.ll Bases APPLICABLE SAFETY ANALYSES The fo'erth sentence of the second paragraph in STS B3.7.11 Bases - APP' rA BLE SAFETY ANALYSES states "The Ckh ATCS is designed in accordance with Scismic Category I requiremenw. This s':n'ence has not been adopted in the ITS Bases P.2! does not explain this omission. Comment: Provide additional discussion to explain w hy this STS text was not adopted.

ComZu 'acsponse to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.7 closcoat submittal 9 revision upe.' NRC's concurrence with the Comed Responses to the ITS Section 3.7 RA r (Sec RAI 3110-4.)

48

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Response to NRC RAI Dated 12/05/97 27-Jan-98 NRC RAI Number NRC issued Date RAI Status 3.7.12-01 12/5/97 Open - NRC Action Reonired NRC Description cfIssue 3.7.1 L1 DOC A. I JFD Bases P.28 CTS 3.7.7 ACTIONS ITS 3.7.12 ACTIONS and Associated Bases

\ According to ITS 113.7.12 Bases DACKGROUND the description of the Nonaccessible Arca Exit ist Filter Plenum Ventilation System, states that this system is a subsystem of the common Auxiliary Duilding ?lcating Ventilation and Air Conditioning System, and is aln a shared system between the Units I and 2. There are no in,lications in the CTS that thi:;

system is sh red between the Units and is no indication ofinter-unit dependence in the CTS. ihe STS did not consider shared unit operation of a sptem and therefore, the ITS needs to be modified to take this into acount. InsulTicient information on system design and operational alignments has been provided to determine if a No e similar to thai i

proposed for ITS 3.7.10 ACTIONS :.nd ITS 3.7.11 ACTIONS (Sec Item Numbers 3.7.10-1 and 3.7.11 1) is sufficient to correct the concern or a total revision of the ACTION statements is nece:sary. Comment: Revise the submittal to acconat for the inter unit dependence of the shared V 7:ssible Arca Exhaust Filter Plenum Ventilation System r.nd provide additional discussion and justifications, as .qv.opriate Comed Response to issue No change. Comed disagrecs. There c several systems that are shared between the two units which do not have any

} Such note added Operators are trainct. that if a common system between the two units becomes inoperable, a unit specific OPERAbtLITY determination is made. In this case, if the nonessential area exhaust filter plenum ventilation system becomes inoperable, both units will be made aware and appropriate unit-specific action will be taken. This is consistent with other commonly shared systems, structures, or components. ITS is consistent with the meaning and intent of CT5, and the licensed Operators at: c ry wcli trained in, and familiar with, the application of technical specifications to shared sy stem inoperaoilitics. (See RAls 3.7.9-16,3.7.10-01, and 3.7.1101.)

NRC RAI Number NRC issued Date RAI Status

, 3.7.12-02 12/5/97 Open - NRC Action Required NRC Description of Issue 3.7.12 . DOC A.44 DOC A 45 DOC LA.38 JFD P.12

- JFD P.13 JFD Bases P.28 r CTS 3.7.7 ITS LCO 3.7.12 ITS B3.7. ? 2 Bases - LCO CTS 3.7.7 has b:en modified by a TS amendment request dated August 23,1996. This CTS change is under review by the staff, and is expected to be issued in Octo$cr,1997. This beyond scope of review item will be evaluated for inclusion in y

~

the conversion upon issuance of the amendment in October,1997. Comment: Review of this beyond scope of review item is pendin; resoluuon of the August 23,1996 TS amendment request Comed Response to issue No change. This amendment was submitted at the re;uest of NRR in an effort to further clarify th: reyirements for the standby plenum. This is an open issue until the NRC has reviewed and approved Comed amendment request dated August 23,1996.

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Response to NRC RAI Dated 12/05/97 - 27da79s NRC RAI Number NRC issued Date - RAI Status 3.7.13 01 2/5/97 Open NRC Action Required NRC Descriptit,n of Issue 3.7.13 1 DOC M.9 '

JFD P.16 JFD Bases P 38 CTS 4!).4.2 ITS SR 3.7.13.3 Note and Associated Bases A Note has been added to CTS 4.9.4.2 to state when this SR shall be performed it is acceptable to add this new Note; however, in ordct to limit its performance when the equipment hatch is not intact during refueling, then the ITS B3.7.13 Bases - SR 3.1.13.3 should state that the SR is only required during movement ofirradiateu fuct assemblics (w hether inside containment or inside the fuel handling building) or Core alternations with the equipmeni hatch not intact. This change will bring the Bases discussion into ccnformance with the interpretation of this Note as stated in M,9, P.16, and Bases P.38. Comment: Revise the submittal and CTS markup and provide additional discussian and technical justification for this change.

Comed Response to Issue The Surveillance Requirements Secticn of the Bases for LCO 3.7.13 has been revised for SR 3,7.13.3 from the original wording. "This SR is modified by a botc that requires this SR only during movement ofirradiated fuel assemblies or CORE ALTERATIONS when the equipment hatch is not intact," to read "This SR is modified by a Note that requires this SR only during movement ofirradiated fuct assemblics (in the fuel building or in the containment) or CORE ALTERATIONS vhen the equipment hatch is not intact." This change will be provided in our comprehensive ITS Section 3.7 clown submittal rcvision upon NRC's cccurrence with the Comed Responses to the ITS Section 3.7 RAI.

\

s 50 u .M.

Response to NRC RAI Dated 12/05/97 27 Jan-98 NRC RAI Number NRC Inned Date RAI Status __

3.7.13C 12/5/97 Open - Comed Action Required NRC Description of Inue 17.13 2 DOC M.9 JFD Bases P.38 CTS 3.9.4 CTS 4.9.4.2 ITS B3.7.13 Bases APPLICABILITY The CTS markup for CTS 4.9.4.2 changes the words "with the equipment hatch removed" to "with the equipment hatch not intact." While this change is considered acceptable, thejustification provided in M.9 and the description provided in j ITS BL7.13 Bases APPLICABILITY defining "not intact ' as including both personnel air lock doors opened is '

t unacceptabic. CT5 3.9.4 specifies containment OPERABILITY during CORE ALTERNATIONS and movem nt of irradiated fuci in containment. Under these conditions CTS 19.4 requires that the personnel hatch (air lock) and the

{

personnel emergency exit hatch (air lock) have at least onc door closed. CT' 19.4.2 which verifies t! at the FHB #

Ventilation System can maintain a negative pressure in the fuct building with the equipment hatch removed (not intact) would require this SR be performed under the conditions of the CTS 3.9.4, that is the air locks closed by a minimum of one door. The proposed definition of not intact (both air lock doors open) is not in accordance with current licencing basis as described in CTS 3/4.9.4, and would regire a NRC technical staff review of this change, This would constitute a beyond scope of resiew item for this conversion. Comment: Deletc from the definition of equipment hatch not intact the words describing both personnel air lock doors open from M.9 and ITS B3.7.13 Bases - APPLICABILITY.

Comed Response to Issue DOC 3.7-M9 will be resised to include the followingjustification. "The proposed change is bounded by the CTS allowance which permits core alterations or movement ofirradiated fuel with the equipment hatch removed. This allowance is contingent upon the FHB Ventilation System's ability to maintain a negative pressurt in the fuct building.

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Because the airlock is contained within the equipment hatch, the reicase pathway to the FHB is much smaller and

' restoration to an intact condition is much easier and quicker to attam than reinstalling the equipment hatch. This change poses less of a relaxation than that w hich is curremly permitted. This change is not applicable to the emergency hatch since it provides a direct pathway to the environment without the charcoal filtration availabic via the FHB Ventilation l Sy stem. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC'e concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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51

Response b NRC RAI Dated 12/05/97 27-Jtn-9s NRC RAI Number NRC 'ssued Date RAI Status 3.7.13 03 12/5/97 Open Comed Action Required NRC Description of Issuc -

3.7.13 3 DOC M.12 JFD B.15 JFD P.16 i JFD Dases P.38 CTS 4.9.4.2 .

CTS 4.9.12.d 3)

ITS SR 3.7.13.3 and Associated Bases IU SR 3.7.13.5 and Associated Bases Justific:. tion M.12 states the following: "ITS SR 3.7.13.5 adds a flow rate requirement to CTS 4.9.12.d.3). This SR verifics the ability of the FHB Ventilation System to maintain the fuel building at a negative pressure. If the system were to run at a flow rate greater than design, the negative pressure may be met, but the Ic.rger flow rate could be indicative of system degradation." CTS 4.9 4.2 and ITS SR 3.7.13.3 pe: farm the same test, but the enclosnre now is the fuel building and containment. No flow raic requirement is included in ITS SR 3.7.13.3. Based on M.12 above, a flow rate requirement should also be provided for ITS SR 3.7.13.3. Comment: Revise ITS SR 3.7,13.3 to include a flow rate requirement or provide a discussion and justification based on system design or operational constraints to show that a flow rate requirement is not needed in this case.

Cr Ed Response to Issue

!- 1,, -

l ige. Inv. cased flow alone would not indicate system malfunction. The system is equipped with flow control dan.pers and flow through the plenum is verified by existing surveillances. The flow to/from containment is small in comparison to the FHB cxhaust flow. Design flow for the FHB exhaust is near 21,000 cfm while the Containment Mini-Purge Supply and Exhaust fans arc designed for 3,000 cfm. Considering that only a small portion of this flow sould bc

, available for "lcakage" to the FHB, the total flow from the FHB would remain essentially unchonged, and would remain

\ plus or minus 10% of design flow allowed by ANSI test methods. Comed continues to pursue this change.

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Resporise to NRC RAI Dated 12/05/97 27-Jan-9tl NRC RAI Number NRC issued Dste RAI Status 3.7.13 04 12/5/97 Open-Comed Action Required NRC Descriptinn of Issue .

3.7,13-4 DOC L.16 CTS 3.9.4 ACTIONS CTS 3.9.12 ACTIONS ITS 3.7.13 ACTIONS The CTS markup of CTS 3.9.4 ACTIONS adds ITS ACTIONS A, B, and C, and classifies this modification as a Less Restrictive change (L.16). Whilc the addition c. .TS ACTION A is considered to be a Less Restrictive change, the additions ofITS ACTIONS B and C are considered as an tdministrative change. Since the CTS requires casceding, the in j operability of the FilB Ventilatica System for CTS 3.9.4 would require entry into CTS 3.9.12 ACTIONS which are ITS '

ACTIONS B and C. Comment:. Resisc the markup for CTS 3.9.4 ACTIONS to show that ITS ACTIONS B and C are administrative changes rather than Less Restrictive changes. Provide additional discussion ar.djustifications for this -

Administrative change.

Comed Response to Issue Comed will resisc the DOC for Insert 3.9-4A which added Conditions B and C from 3.7 Ll6 to an 'A' designator, thereby identifying ITS Conditions B and C as administrative changes This change will be provided in our comprehensive ITS Secthm 3 7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

The inoperability of the FHB Ventilation System wouM tequire entry into CTS LCO 3.9.12, not CTS LCO 3.9.4. CTS LCO 3.9.4 provides an allowance which is contingent upon the proper functioning of the FHB Ventilation System.

Ilowever, with the FIIB Vertilation System inoperabic, the LCO statement of CTS LCO 3.9.4 can still be met by maintaining the equioment hatch in place. Therefore, multiple LCO entrics are inappropriate. Comed continues to pursue this change. tSec RAI 3.7.7-03 and RAI 3.7.8 05.)

NRC RAI Number NRC issued Date RAI Sta:us 3.7.13 05 12/5/97 Open - NRC ktion Required f

NRC Description of Issue 3.7.13 5 JFD C.2 JFD Bases C.3 CTS 3.9.12 ACTON c STS 3.7.13 ACTIONS ITS 3,7.13 ACTIONS Note and Associated Bases TSTF 36 Resision 2 modifies STS 3.7.13 ACTIONS by adding a Note which states that "LCO 3.0.3 is not applicable "

The staff has not yet reviewed and approved TSTF 36, but will recommend that this change be modified to locate the Note above STS 3.7.13 RA C.I and RA D.I to be consistent with the Standby Gas Tre.atment System STS in BWR/4 (NUREG 1433) and BWR/6 (NUREG 1434), and as being the more appropriate place for 'his Note. Comment: Revise the CTS /ITS markups to reflect this proposed change to TSTF 36 and provide additionaljustification and discussion for this change.

Comed Response to issue No change. Comed is currently pursuing this change as TSTF-36, Rev. 2 which is currently being resiewed by the NRC.

- If rejected by the NRC on a generic basis, Comed will continue to pursue the same change on a plant specific basis.

- ~ ~ -

Response to NRC RSIDatel(2/05/97 2Nra-98 NRC RAI Number NRC Issued Date RAI Status 3.7.13-06 12/5/97 Open NRC Action Required NRC Description of Issne 3.7.136 JFD C.9 STS 3.7.13 APPLICABILITY ITS 3,7.13 APPLICABILITY ITS 3.7."3 APPLICABILITY modifics STS 3.7.13 APPLICABILITY in accordance with WOG-81. Sec Item Number 3.7.10-3. Comment: See item Number 3.7.10-3.

Comed Response to Issue WOG-81 will be withdrawn in its entirety throughout the ITS submittal. The submittal will be resised to adopt the STS prescntation in the Applicability Section. This change will be prosided in our comprehensive ITS Section 3.7 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (Sec RAls 3,7.10-03, I RAl 3.7_l1-02,3.9.4-06, and 3.9.7-05.)

NRC RAI Mumher NRC lasued Date RAI Status 3.7.14 01 12/5/97 Open - NRC Action Required NRC Description of Issue 3.7,14-1 DOC A.26 JFD P.4 JFD Bases C.9 JFD Bases P.31 CTS 3/4.9.11 p)

'b ITS 3.7.14 By letter dated Nosember 5,1996, Comed Requested a change to CTS LCO 3.9.11, CTS 5.6.1.1 and CTS 6.9.1.10. CTS' 3/4.9,1 I was marked up to reflect this 11/5/96 request. This request has been approved by the staff. Dit is only a temporary change which expires in December,1997. The permanent TS changes have been submitted for staff review and approval in an amendment change package dated June 30,19M, Thus, the changes associated with this specification and their acceptance is a beyond scope of review item for this com-rsion, Comment: The resicw of the conversion of CTS

- 3/4.9.11 to ITS 3.7.14 is delayed pending staffs approval of the licensec's 6/30/9~ TS change request and resubmittal by the licensee of the CTS /ITS markups for ITS 3.7.14.

Comed Response to Issue By T. Tulon (Commonwcahh Edison) to United States Nuclear Regulatory Commission (Document Control Desk) letter dated October 10,1997, Comed supplemented the original ITS submittal with ITS Revision B. ITS Resision B contained the ITS versions of the CTS license amendment requests for 1) the Non Acce. ". ole Area Exhaust Filt:r Plenum and the Fuct llandling Building Ventilatio6. Systems, and 2) Boron Credit in the Spent Fuct Pool. NRC letter dated April 2,1997 issued Amend. ment 86 for Byron and Amendment 78 for Braidwood for soluble boron in the spent fuel pool (SFP). Since the license amendments were temporary in nature, Comed letter dated June 30,1997 proposed changes to permanently take credit for soluble boron in the SFP. Additionally, Comed responded to the NRC's request for additional information in Comed letter dated September 25 1997. Although not yet approved by the NRC, Comed has used the June 30,1997 and the September 25,1997 submittal revisions as th, CTS markup pages for ITS Resision B. If there arc any question after the Staff reviews the CTS license amendment request for Boron Credit in the Spent Fuel Pool and ITS Revision B, Comed will address them at that time. (See RAI 3.7.15-01 and RAI 3.7.16-01.)

(

Response to NRC RAI Dated 12/05/97 27-JnAs NRC RAI Number NRC Issued Date RAI Status

_C

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3.7.15-01 12/5/97 Open NRC Action Required NRC Description of Issue 3.7.15 1 DOC A.26 JFD P 4 JFD Bases C.9 JFD Bases P.31 CTS 3/4.9.11 ITS 3.7.15 See item Number 3.7.141. Comment: The review of the conversion of CTS 3/4.9.11 to ITS 3.7.15 is delayed pending staffs approval of the licensce's 6/30/97 TS change request and resubmittal by the licensee of the CTS /ITS markups for ITS 3.7.15.

Comed Respense to Issue Sec Comed Response to RAI 3.7.14-01, if there are any question after the m.aff resiews the CTS license amendtunt i request for Boron Credit in the Spent Fuct Pool and ITS Resision B, Comed ,ill address them at that time.

l NRC RAI Number NRC lssued Date RAI Status 3.7 16-01 12/5/97 Open NRC Action Required NRC Description of Issue 3.7.16-1 JFD P.4 JFD Bases C.9 JFD Bases P.31 ITS 3.7.16 V

The CTS markup does not show anything for ITS 3.7.16. Thejustifications provided in the ITS markup arc P 4 and Bases P.31. Resolution ofITS 3.7.16 will depend on the resolutions ofIten Numbers 3.7.141 and 3.7.15-1. Comment: The resicw of the ITS 3.7.16 is dclayed pending staft's approval of the licensec's 6/30/97 TS change request and resubmittal by the licensee of the ITS markup of ITS 3.7.16.

Comed Response to Issue See Comed Response to RAI 3.7.14-01. If there are any question after the Staff resiews the CTS license amendment request for Boron Credit in the Spent Fuct Pool and ITS Revision B, Comed will address them at that time.

NRC RAI Number NRC Issued Date RAI Status 3.7.17-01 12/5/97 Open - NRC Action Required NRC Description of issue -

3.7.17-1 JFD Bases P.20 ITS B3.7.17 Bases - BACKGROUND The third paragraph, first sentence, references the primary ccolant specific activity limits of LCO 3.4.16. The stating of the I microcurie per gram limit has been omitted because the limit is different between Braidwood and Byron. This ;s a legitimate difference and its should be stated clearly rather than disguised by this alternative editorial wording.

Comment: Reise the Bases to include the specific activity valves for cach facility.

Comed Response to Issue Comed will resise the Bases to reflect the specific activity values for Braidwood and Byron. The submittal will be revised to adopt the STS presentation in the Applicability Section. This charge will be pruided in our esmprehensive ITS

'3 Section 3.7 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

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55

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Response to NRC RAI Dated 12/05/97 27-Jin-9f.

.._._._.7 :

. . _c

- NRC RAI Number NRC Issued Date RAI Status

[] 3/4.7.8 01 12/5/97 Open - NRC Action Required NMC Description of Issue 3/4.7.8-1 DOC LA.39 CTS 3/4.7.8 CTS 3/4.7.8 is being totally relocated out cf the TS to the TRM. Thejustification used for this is LA.39. The LA -

justifications are to be used to relocate speciS requirements and detailed information from individual specifications. The relocation of entire specifications such as 3/4.7.8 are to be justified using the Relocated (R.x) designation. Comment:

. Reuse the CTS markup to show that this change is a relocated item and provide the appropslate discussion and justification for this relocated CTS.

Comed Respamse to Issue The Braidwood/ Byron ITS Summary Disposition 11 atrix of the Split Report for CTS LCO 3.7.8, " Snubbers" will be revised to show CTS LCO 3.7.8 as being " relocated" ani Note 22 will be deleted. In addition, DOC 3.7 LA39 will be changed to an 'R' designator. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal tension upon NRC's concurr:nce with the Comed Rcsinnses to the ITS Section 3.7 RAI.

NRC RAI Number NRC lssued Date RAI Status 3.9-01 12/5/97 Open-NRC Action Required NRC Description of issue 3.9-01 DOC LA6 CTS 3/4.9.3, Decay Time Byron /Braidwood characterized this change as less restrictive generic, LA. This specification is relocated based on

.i application of the 10 CFR 50.36. Comment: Revise the LA.6 DOC to a Relocated DOC, A

Comed Response to Issue No change. 'LA' designators are used for relocating details of specifications or specifications that are not addressed by the generic WOG Split Report. LA6 states, "This requirement is to be relocated to the TRM." Although CTS LCO 3.9.3, --

" Decay Time," satistics Criterion 2 of the Technical Specification Selection Criteria in 10 CFR 50.36(c)(2)(ii), it is not classified as an 'R' designator because it is not identified in the Generic WOG Eplit Report as being relocated. This presentation is standard throughout the Byron /Braidwood submittal Comed continues to pursue this change.

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a R:sponse to NRC RAI Dated 12/05/97 - 27 J:n-97 NRC RAI Number - NRC lasued Date RAI Status 3.9-02. 12/5/97 .Open NRC Action Required NRC Description of issue 3.9-02 See table below Proposed changes based on STS generic changes that are still pending or that have been rejected, as indicated in the tabic, should be withdrawn. Either adopt the STS or maintain the CTS requirements.

Byron /Braidwood Units I and 2 "Beyond Contractor Resiew Scope (BCRS)" Table

. Section 3.9, Refueling Operations Updated: November 25,1997 ITS Section or ITS LCO DOC-JFD Reasons for Exemption of Resiew i

j Comment (if required)

-1 2 3 4 5 6 7 3.9.7 C3

-BCl - X __- - -- - TSTF 20 0 11/24/97 sta . pending 3.9.6 . ' . C1 P4 BC2 BP24 - X - - - =-- -

- TSTF-21 proposed RI 11/24/97 status: TSTF 21 approved on 5/19/97, but Rev 1 is not to staff for review 3.9.5 3.9.6 -LA10 C2 - X - - - - -

TSTF 22 11/~; d97 status: Reject [] if CTS contains flow rates B3.9.3 BC5 BP4 - X - - - - - TSTF 23 R1 11/24/97 status: rejected i1/19/97 by TSTF, Rev3 is pending issuance for staff review, Rev2 is being reviewed by the staff.

3.9.3 C5 BC4 -- X - - - - -

TSTF 96 11.24.97 status: approved 10/28/97_ --

3.9 - C4 - X - -- - - WOG-81 11/24/97 status: WOG # not under resiew.

B3.9 BC3 - X

. Editorial 1 (

lI/24/97 status: Approved 10/18/95 3.9.4 M8 P3 - - -

X - - -

3.9.1 Pl - - - - -

X -

Editorial-ll 11/24/97 status: Approved 4/11/97 L - P= plant specific; C= based on TSTF er WOG item. B= Bases 5

Reasons for exempting change from review:

1. Cover letter 12-13 96, Attachment #3 Existing and Future Licensing Amendments to be incorporated into ITS.

c Response to NRC RAI Dated 12/05/97 27-J:s-9s

' 2. Cover letter IU3d Attachment #4 Pending and Proposed ISTS Change Travelers

3. Comed letter 2 24 97, Attachment #1, Generic Changes versus CTS DOCS

4. Cover letter 1213 96, Attachment #5 Beyond Scopc Change (changes that are different than both CTS and ITS).

- 5 Cover letter 1213 96, Attachment #6 Beyond Scope 53 racketed Changes 6 Comed letter 2 24 97i Attachment #2, Plant Specific Change Justifications Which arc Now in the Generic STS Change Process 7.Other Reason as identiDcd in comments to this table and with the written prior approval of the NRC Technical Monitor as referenced.

Comed Response to issue Regarding TSTF-20 TSTF 96, Editorial 1, and Editorial.1!! No change based on NRC approval of these changes.

Regarding WOG-81: Withdrawn. See RAls 3.7.10-03, RAI 3.7.11-02,3.7.13 06,3.9.4 06, and 3.9.7 05. Regarding TSTF 22: Withdrawn. See RAls 3.9.5-05 and 3.9 6-04. Regarding TSTF-23: See RAI 3.9.3 01. Regarding TSTF 21:

No change. LCO 3.9.6 requires two RilR loops to bc OPERABLE and one RHR loop to be in operation. The LCO Section of the Bases for ITS LCO 3.9.6 states that the flow Irh starts in one of the RCS hot legs and is returned to the RCS cold legs. With the RilR System aligned to, or during transitioning to or from, the Refueling Water Storage Tank !

l (RWST) to support filling or draining the refueling cavity, or to support required testing, the LCO would be considered not i met. in order to acknowledge these operational conditions, TSTF-21 Revision 1 (NRC approved), made a change to the l Bases for LCO 3.9.6 to allow both RIIR pumps to be aligned to the RWST to support filling or draining the refueling j cavity or to support required testing. Comed disagrecs with this change which allows an exception to the LCO to be included in the Bases with no corresponding LCO change. Ins'ead, Comed added a Note to the LCO that permits the required RilR loop to be removed from operation and considered OPERABLE when eligned to, or during transitioning to or from, the RWST to support filling or drainir.g the refueling cavity, or to support required testing, if capabic of being -

reatigned to the RCS. Comed contends that without this change, the LCO would be considered not met when the RilR System is aligned to the RWST, and Condition A would have to be entered. Th: Required Action rec,2 ires immediately in;tiating action to restore the RIIR loops to OPERABLE status, thereby prohibiting the use of the RilR System to fill or drain the cavity or perform required testing. Comed continues to pursue the enange as addressed by LCO JFDs 3.9-Cl and 3,9 P4 and Bases JFDs 3.9 C2 and 3.9-P24.

, _%.-b):

NRC RAI Number NRC Issued Date RAI Status .

-3.9.1 01- 12/5/97 Open - NRC Action Required NRC Description of Issuc 3.9.1-01 Bases discussion for ITS 3.9.1 Applicable Safety Analyses, page B 3.9-2 in the second paragraph of the Applicable Safety Analyses, it has been proposed to delete the term " margin of safety" and replace it with the dermed term " Shutdown Margin"f The Shutdown Margin definition audresses stuck tod worth w hich is not relevant during refueling operations. Comment: This is not ajustifiable plant specific or editorial difference. Revisc the submittal to conform to the STS.

Comed Response to Inue Comed will confonn to the STl This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI 1 2

Response to NRC RAI Dated 12/05/97 27-Jan-98 NRC RAI Number NRC lasued Date RAI Status 3.9.1-02 12/5/97 Open NRC Action Required NRC Descrip6n of issue 3.9.1 02 Bases discussion for ITS 3.9. I Actions, page B 3.9-3 The first sentence of the Orst paragraph of the Actions section of the STS has not been adopted in the ITS. This sentence states, " Continuation of Core Alterations or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO." Ccmment: This is not ajustifiable plant ,pecific or editorial difference. Revise the submittal to conform to the STS.

Comed Response to issue The sentence in the Actions Sc.oon of the Bases for NUREG LCO 3.9.1, " Continuation of CORE ALTERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in -

compliance wi!h the LCO" will be retained. This change will be provided in our comprehensive ITS Section 3.9 closcou:

submittal revision upon NRC's concurrence with the Comed Respouses to the ITS Section 3,9 RAI.

_xx l NRC RAI Number NRC Issued Date RAI Status 3.9.1-03 12/5/97 Open NRC Action Required NRC Description of lasue 3,9.1 03 Bases discussion for ITS 3.9.1 Actions. page B 3.9 3 in the middle of the first paragraph of the Actions section of the STS the term "all opcrations involving" has not been adoped in the ITS. Inst:ad, an insert has been proposed that states, "an inadvertent criticality may occur due to ar.

incorrect fuel loading. To minimize the potential of an inadvertent criticality resulting from a loading error." This O appears to overlook the possibility of an inadvertent criticality as a result of a reduced boron concentration. Comment:

This is not a justifiable plant specific or editorial difference. Revisc the submittal a conform to the STS.

Comed Response to Issue <

No change. Comed disagrees. The possibility of an inadvertent criticality as a result of a reduced boron concentration is still addressed in that same sentence by " . and positive reactivGy additions must be suspended immediatc*y." Replacing "all operations involving CORE ALTERATIONS" with " CORE ALTERATIONS" does not address a reduction in boron concer.tration in either case. Comed continues to pursue this change.

NRC RAI Number NRC issued Dre RAI Status 3.9.1-04 12/5/97 Open - NRC Action Required NRC Descriptior, of Issue 3.9.1-04 Bases discussion for ITS 3.9.1 Actions, page B 3.9-3 An insert has been acided to the end of the second paragraph of the Actions section. The intention of the insert is to exclude " normal heatup/cooldown of the coolant volume for the purpose of system temperature control" from Required Action A.2 to suspend positive reactivity additions. Comment: This is not a justifiable plant specific or editorid difference. Revisc the submittal to confctm to the STS This issue should be brought to the Te.h Spec Task Force for future action.

Comed Response to issue The change associated with Bases JFD 3.9-P14 has been presented to the WOG for generic change consideration and a traveler is being created for the other Owner's Groups' review and approval. Comed cantinues to pursue this change plant specifically until generic rcralution has been achieved.

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59

. R sponse to NRC RAI Dated 12/05/97 27-J:n 98 NRC RAI Number NRC lssued Date RAI Statua b

b 3.9.1 05 12/5/97 Open NRC Action Required NRC Description of Issue 3.9505 Bases discussion for ITS SR 3.9.1.1, page B 3.9-4 In the STS, the last sentence of the first paragraph states, " The boron concentration of the coo'. ant in cach volume is determined periodically by chemical analysis." The ITS has not adopted the term "in cach volmne" Comment: This is not a justifiable plant specific or editorial difference. Revise the submittal to conform to the STS.

Comed Pasponse to Issue No change. Since the LCO is applicable only to the filled portions of the RCS, the refueling canal, and the refueling cavity that are hydraulically coupled to the reactor corc, the boron concentration limit is applicable only for the reactor core or those areas in direct communication with the reactor core (see Bases JFD 3.9 P7). The.nfere, in the Serveillance Requirements Section of the Bases for NUREG LCO 3.9.1, the phrase, "in cach solume" is techrically incorrect if the RCS, the refueling canal, and the refueling cavity were not hydraulically coupled. Comed belic /cs this change is necessary for properly representing the requirements of the LCO and SR 3.9.1.1, and continues to pursue this change NRC RAI Number NRC Issued Date RAI Status 3.9.1-06 12/5/97 Open NRC Action Required NRC Description of Issue 3.9.1-06 DOC A9 CTS 3.9.1 The ITS adds the refueling cavity to the list of specified volumes that require the boron concemration limits of TS to bc i p)

(

niet. Comment: Based on the discussion provided in A9 the change is not justifiable as an administrative c:rmge.

Provide additionaljustification to support the administrative change category.

Comed Response to issue DOC 3.9-A9 will be revised to state, " CTS LCO 3.9.1 requires maintaining boron concentration of all filled portions of the RCS and refueling canal. Clearly, it is the intent of CTS to include the refueling cavity when referencing the RCS in the ;

LCO and Surveillance Requirements Sections. Therefore, ITS LCO 3.9.1 clarifies the " filled portions of the RCS" region by specifically denoting the " refueling cavity" area. This change is perceived as the intent of the CTS wording, is ce nsidered editorial in nature and does not involve a tc6nical change (either actual or interpretational) to the TS. This enange is consistent with NUREG-1431." This change will be provided in our comprenensive ITS Section 3.9 closcout submittal revtsion upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAL NRC RAI Number- NRC Issued Di.tc RAI Status 3.9.1-07 12/5/97 Open - NRC Ac* ion Required NRC Description of Issue

- 3.9.1 DOC LA1 CTS 3.9.1 The CTS marki p shows the application of the LAl DOC to LCO 3.9.1.b(2) which is note " that is deleted by DOC A3.

Comment: Revise the CTS markup to correct the applications of LAl and A3.

Comtd Response 19 Issue Comed disagrees. In the CTS Markups, the 'LAl' designator pertains to CTS LCO 3.9.1.b.2, excluding the footnote symbol ("). The 'A3' designator addresses the footnote symbo! in the LCO and footnote *t Comed continu:s to pursue this changc.

60

Response to NRC RAI Dated 12/05/97 27-Jan-98 NP.C RAI Number --.- NRC lssued Date RAI Status 3.9.1 08 12/5/97 Open - NRC Actian Required NRC Description of Issue 3.9.1 08 JFD Pl CTS LCO 3.9.1 The P1 DOC adds the i.rticle "the" to SR 3.9.1.1. Comment: Revise ITS SR 3.9.1.1 to adopt the STS. (This and other sentence structure changes could be made throughout the STS and the industry declined to adopt and "English" language format in favor of specifications that contained the required information with a " human factored" format.

Comed Response to issue No change. This change has been approved on 4/11/97 as Editorial-11. (See RAI 3.9-02.)

NRC RAI Number NRC Issued Date RAI Status h 3.9.2-01 12/5/97 Open - NRC Action Required NRC Description of Issue a 3.9 2-01 ITS 3.9.2 Actions Note ITS 3.9.2 contains an Actions Note w hich states, " Separate Condition entry is allowed for cach unborated water source isolation valve." Comment: The submittal has neither discussed norjustified using this note. Revise the submittal to provide thejustifiction for this note.

7 Comed P.csponse to hsue No change. Comed disagrees. The CTS Markup for CTS SR 4.9.1.3 addresses the addition of the ITS LCO 3.9.2 Actions O

v Note with 'Alo' and 'Ml' designators (page 3/4 9-1). Comed continues to pursue this change.

NRC RAI Num!n r NRC lssued Date RAI Status 3.9.2-02 12/5/97 Open - NRC Action Required FRC Description of Issue 3.9 2-02 Bases discussion for 1I S 3.9.2 LCO, page B 3.9-5 The proposed insert for this section reads,"This LCO includes valves from the RWST w henever concentration of the RWST falls below specified limits. Acceptable isolation in the closed position of unborated water source isolation valves is provided by mechanical stops, removal of air, or removal of electrical power." The revision that follows is a proposed alternate. "This LCO includes valves associated with the RWST whenever the boron concentration of the RWST falls below specified limits. The unborated water source isolation valves are acceptably secured in the closed position by utilinng mechanical stops, removing air, or removing clectrical power as appropriite." Comment: Revise the submittal to incorporate the recommended insert material.

Comed Response to issue No change, in comparing Comed's proposed Bases statement and the reviewer's proposcd stateracnt the only changes are wording preferences which are strictly editorial. Sincc there is no technical or operational benefits gained in using the k

proposed wording, Comed clects to maintain our current wording, and continues to pursue this change.

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<- Response to NRC RAI D:ted 12/05/97 27-J$n-98

~5RC RAI Number NRC Issued Date RAI Status 3.9.2 03 12/5/97 Open - NRC Action Required NRC Description of Issue 3.9.2-03 Bases discussion for ITS SR 3.9.2.1, page B 3.9 7 in the STS the first three sentences of the Bases discussion for SR 3.9.2.1 provide gen:ral background about the surveillance. This material has not been adopted in the Bases discussion for corresponding ITS 3.9.2. Comment: This s not a justifiable plant specific or edi:orial difference. Revisc the submittal to conform to the STS.

Comed Response to issue Comed will resisc the submittal to adopt the first three sentences in the Surveillance Requirements Section of the Bases for SR 3.9.2.1. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Resporses to the ITS Section 3.9 RAl.

NRC RAI Number NRC Issued Date RAI Status 3.9,3-01 12/5/97 Open NRC Action Required NRC Description of issue 3.9.3-01 DOC L10 CTS 3/4.9.2 CTS 3/4.9.2 establishes the requirements for the nuclear instrumentation in Mode b. The LCO requires in part audible indication in the containment and the control room. It has been pr: posed to delete this requirement because there is no design requiremer.t for the audible alarm and the ITS requirement to isolate all unborated water sources in Mode 6 (ITS 3.9.2) provides adequate assurancc that a reactivity event will not occur. Comment: InsutTicient justification has been q prosided ta support this proposed change. Resisc the submittal to move this requirement to the ITS Bases, consistent with NUREG 1431.

Comed Response to issue No change. Deleting the audible alarm requirement from the Background Section of the Bases for LCO 3.9.3 is consistent with TSTF-23, Resision 1 and Resision 2 (both under NRC consideration). For plants such as Byron and Braidwood, which isc! ate all boron dilution paths per LCO 3.9.2, the source range OPERABILITY requirements include only the visual monitoring function. Braidwood and Byron UFSAR Section 15.4 provides the following discussion for boron dilution during MODE 6: "An uncontrolled boron dilution transient cannot occur during this mode of operation.

Inadvertent dilution is prevented by administrative controls which isolate the RCS from the potential source of unbora.cd water. CVCS valves, specified in CTS 3.9.1 (ITS 3.9.2.1) will be verified closed and secured in position by mechanical stops or by removal of air or electrical power. These valves block all flow paths that could allow unborated makeup water to reach the RCS. Any mrAcup which is required durmg refueling will be borated water supplied from the RWST by the low head injection pumps." This method of valve isolation is acceptable by the NRC as presented in other ITSs involving isolation of valves Based on the above justificatien, audible alarms are not required. Comed continues to pursue this change.

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Response to NRC RAI Dateil 12/05/97 27-Jr.e 98

~ NRC RAI Number NRC Inued Date RAI Status 3.9.3-02 12/5/97 Open NRC Action Required NRC Iwcription of Issue 3.9.3-02 Bases discussion for ITS SR 3.9.3.2, page B 3.910 The STS Bases states that the reason that tne Channel Calibration is performt.d with an 18 month frequency is that this surveillance needs to be performed under the conditions that apply during a plant outage. This information has not been adopted in the ITS. Comment: This is not a justifiable plant specific or editorial difference. Resisc the submittal to conform to the STS.

Comed Response to Issuc Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal resision upon NkC's concurrence with the Comed Responses to the ITS Section 3.9 RAl.

NRC RAI Number NRC issued Date P \l Status 3.9.4-01 12/5/97 Open NRC Action Required NRC Description of Issue 3.9.4-01 DOC A6 JFD P2

, CTS 3.9.4.a I- ITS LCO 3.9.4 Note l CTS LCO 3.9,4.a allows removal of the equipment hatch pursuant to the successful pe formance of the Surveillance l

Requirement to verify the Operability of the fuel handling building exhaust plenutas. This has been reformatted in the form of an LCO note for corresponding ITS 3.9.4. This note states that Iter i a of the LCO is only required when the Fuct s llandling Duilding Exhaust Filter Plenum Ventilation System is not in compliance with ITS LCO 3513. However, the Applicability for ITS 3.9.4 and ITS 3.7.13 are not the same. The note should be revised to state that Item a of the LCO is only required when the Fuct llandling Building Exhaust Filter Plenum Ventilation System is not Operable. Comment:

Resise the submittal to specify system Operability status rather than compliance with LCO 3.7.13.

Comed Responsa to lune No change. The proposed wording for the LCO 3.9,4 Note stating, " . System is not Operable" merely represents a wordmg preference over Comed's proposed wording stating, " . System is not in compliance with LCO 3.7.13 "

Comed continues to pursue this change.

r-NRC RAI Number NRC Issued Date RAI Status 3.9.4-02 12/5/97 Open - NRC Action Required NRC Description of issue 3.9.4-02 JFD Pl7 Bases discussion for ITS SR 3.9.4.2, page B 3.9-15 In the STS the last part of the paragraph describes other Surveillance Requirements in other LCOs that demoastrate the Operability of the containment purge valves and their associated actuation instrumentation. This information has not been adopted in the ITS. Comment: This is not ajustifiable plant specific or editorial difference. Resise the submittal to conform to the STS.

Con Ed Response to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 31 TAI.

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.- Resporm 13 NRC RAI Dated 12/05/97 27-Jr.i 98 NRC RAI Number NRCIss cd Date RAI Status O 3.9.4-03 12/5/97 Open NRC Action Required V NRC Description ofIssue '

3.9.4-03 DOC L2 CTS 4.9.4.1 CTS 4.9.9 DOC L2 states the CTS has been revised to relax the surveillance frequency from 7 days to 18 months. Comment: DOC L.2 justifies the proposed changes to CTS 4.9.9 test frequencies; howescr, DOC L.2 does not provide appropriate discussion for CTS 4.9.4.1 changes identified as L2 and the CTS 4.9.4.1 markup does not reficct the proposed ITS. Revise the CTS markup and provide DOC discussion to address cach proposed CTS change.

Comed It sponse to Issue CTS DOC 3.9-L2 will be resised as follows, " CTS SR 4.9.4.1 and SR 4.9.9 require the containment ourge isolation valves to be demonstrated OPERAI3LE cvery 7 days by verifying tnat containment isolation occurs on an actuation signal ITS SR 3.9.4.2 requires the containment purge isolation valves to be demonstrata.d OPERAHLE cvery 18 months by verifying that containmcu isolation occurs on an actuation signal. CTS SR 4.9.41 b has been resised to relax the Surveillance Frequency from 7 days to 18 months. This is acceptable since the contaimnent purge isolation system requires the performance of ulditional SRs to ensure operability of'hc system and the containment isolation function. The 13 month Frequency maintains consistency with other si. star ESFAS instrumentation and valve testing requirements. The SRs for the actuating instrumentation are contained in LCO 3.3.6. These requirements inchde a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Channel Check, a 92 day Channel Operational Test, and an 18 month Channel Calibratica and TADOT (for the Manual Initiation function only). In addition to the instrumentnon requirements of LCO 3.34 cach containment purge isolation valve requires the verification of the isolation time in accordance wi'h the IST program (SR 3.9.4.3). In addition, CTS SR 4.9.4.1.a requires verifying that the penetrations arc in their closed / isolated condition, w hile ITS SR 3.9.4.1 demonstrates that the open

. purge valves are not blocked from closing and cach valve operator has motive power by verifying cach required h

\_.

penetration is in the required state.- These changes are consistent with NUREG 1431." This change will be prosided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS bection 3.9 RAl.

NRC RAI Number NRC Issued Date 'RAI Status 3.9.4-04 12/5/97 Open - NRC Action Required NRC Description of Issue 3.9.4-04 DOC M8 JFD P3 ITS SR 4.9.4.3 DOC M8 justifics adding purge valve isolation time testing in accordance with IST frequencies. Comment: The proposed SR represents a generic change to the STS. Typically, valve isolation testing is performed as part of the system operability requirements. Explain why this proposed SR does not duplicate the testing requirements of ITS SR 3.6.3.5.

Comed Response to Issue No change. ITS SR is applicable in MODES 1-4. ITS SR 3.9.4.3 is applicable during CORE ALTERATIONS and during movement of i radiated fuct assemblics within containment. Therefore, they are not duplicate testing requirements.

Comed continues to pursue this change.

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Response to NRC RAI Dated 12/05/97 27 J=-98 NRC RAI Number NRC Issued Date RAI Status

O 3.94415 12/5/97 Open NRC Action Required L.) NRC Description of Issue 3.9.4-05 DOC A11 ITS LCO 3.9.4 DOC All states that the requirements of CTS 3.9.9, " Containment Purge Isolation System" are retained in the presentation ofITS LCO 3.9.4.c which requires an operable Containment Purge Isolatior. System. Comment: The proposed ITS LCO 3.9.4.c requires the " Containment Ventilation (emphasis added) System to be operable. Provide a DOC for the deletion of Containment Purge Isolation System operability requirements during core alterations or movement '

ofirradiated fuel in containment.

Comed Response tu Issue No change. Containment " Purge isolation" System and Containment " Ventilation" System are one and the same. They arc /can be used interchangeably. Comed continues to pursue this change.

NRC RAI Number N:tC Issued Date RAI Status

't.9.4-06 12/5/97 @n-NRC Action Required NRC Description of Issue 3.9.4-06 JFD C4 ITS 3.9.4 Applicability JFD C4 proposes to revise the STS format for constructing applicable conditions. Comment: This is a deneric -hange that requires a staff approved TSTF change. Revise the submittal to aoopt the STS.

-- Comed Response to Issue

k. WOG-81 will be withdrawn fro... .e iTS submittal ITS and bUREG will be revised to adopt the ISTS presentation in the Applicability section cfITS LCOs 3.9.4 and 3.9.7. As a result, LCO JFD 3.9-C4 will be deleted. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAl. (See RAls 3.7.10-03,3.7.1102,3.7.13-06, and 3.9.7-05.)

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Response to NRC RAI Dated 12/05/97 27 Ja-9s

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NRC RAI Number NRC nssued Date RAI Status 3.9.541 12/5/97 Open - NRC / 4-Sn Required NRC Description of Inue 3.9.50! DOC L4 CTS 3/4.9.8.1 footnote

The footnote modifies the LCO by allowing the RilR loop to be removed from operation during the performance of Core Alterations in the vicinity of the reactor vessel hot legs. It has been proposed to delete Inc term "during the performance of Core Aherations in the vicmity of the reactor vessel ho' legs" from the footnote. Comment; InsufTicient justification hns been prosided for this proposed change. Resisc the submittal and proside additionaljustification.

Comed Response to issue No change Comed has conformed to the STS LCO 3.9.5 Note which allows the required RHR loop to be removed from operation for I hout per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period preided no operations are permitted that would cause reduction of the RCS boron et ncentration. This Note allows other refueling operation activities such as core mapping, valve testing, installation and removat of temporary lighting, temporary submadnes or any other activity not invohing any operations that would cause a boron reduction in the RCS or a reactivity chang '. The CTS also prosides a footne'c stating that the RHR loop may be removed fro:a operation for up to I hour per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months priod during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs In converting to ITS, and in compliance with the STS, the words, "during the performance of CORE ALTERATIONS in the vicinity of the vessel hot legs" were removed hc ITS definition of CORE ALTERATION states, " CORE ALTERATION shall be the mowment of any fuel sc.urces, or reactivity control components, within the reactor vessel with the v 21 head removed and fuel in the vessel." The ITS definition differs t

from the CTS definition in that equipment in the vicinity of the hot leg (such as lighting, temporary submarines, etc.) is no longer required to be classified as CORE ALTERATIONS in ITS. Without the revised Note, certain operations widch j[

were allowed under the CTS Note would no ionger be allowed in ITS. The footnote in ITS LCO 3.9.5 is consistent with the ITS definition and the deletion of the words, "during the performance of CORE ALTERATIONS in the vicinity of the O vessel hot leg" is appropriate. Comed continues to pursue this change. (Sce RAI 3.9.5-04.)

NRC RAI Number NRC Issued Date RAI Status 3.9.5-02 12/5/97 Open - NRC Action Required NRC Description of issue 3.9.5-02 Bases discussion for ITS 3.9.5 LCO, page B 3.918 The LCO sectior describes uhy one RHR loop must be Operable and in aperation. The STS identifies removal of decay heat, mixing of the borated coolant to minimize the possibility of criticality, and indication of reactor coolant temperature.

The ITS has omitted mention of the indication of reactor coolant temperature. Comment: This is not ajustifiable plant specific oi editori! change. Resise the submittal to conform to the STS.

Comed Response to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI. (See RAI 3.9.6-02.)

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66 i j

Response to NRC RAI Dated 12/05/97 27-ns-98 NRC RAI Number NRC Issued Date RAI Status g) '

3.9.5-03 NRC Description of Issue 12/5/97 Open NRC Action Required 3.9.5 33 DOC M3 CTS 3/4.9.8.1 Action The CTS Amon is modified in the ITS to require "immediate" action to pc _orm required remedial measures. Comment:

The DOC does not : ddress that time limits are imposed by adoption of the STS content. Provide a resised DOC.

Comed Response to Issue No change. Comed disagrecs. The addidon of"immediately" is addressed in DOC 3.9-M3 The only time limit associated with ITS LCO 3.9.5 is the 4 heur Completion Time of Required Action A.4, which is consistent with CTS and therefore is not changea Comed continues to pursue this change. (Sec RAI 3.9.6-03.)

NRC RAI Number NRC lasued Date RAI Status k 3.9.5-04 12/5/97 Open-NRC Action Required NRC Description of Issue 3.9.5 04 DOC M9 CTS 3/4.9.8.1 Note

The ITS provides allowances for remosing a loop from operation. The CTS change ensurt;s boron dilution does not occur l with no loops in operation for the one-out-cight hour period permitted by the TS. Comment: Insufficicmjustification has been provided to state the safety basis for this provision. Resise the submittal and proside additionaljustification.

Comed Response to Issue h

d See Comed Response to RAI 3.9.5-0 L NRC RAI Number NRC lssued Date RAI Status 3.9.5 05 12/5/97 Open - NRC Action Required NRC Description of issue 3.9.5-05 DOC LA10 CTS 4.9.8.1 The proposed C TS change relocates details regarding flow and temperature requirements during testing to licensee controlled documcats. This is geneic change TSW-22. TSTF-22 was rejected by the staff. Comment: Withdraw the CTS change and resubmit resised ITS.

Comed Response to issue Comed will revise the ITS submittal to include the flow rate value in ITS SR 3.9.5.1 and ITS SR 3.9.6.1. (Note:

Approved TSTF-21, Revision 1, allows deleting the flow rate requirement in NUREG SR 3.9.6.1.) However, the CTS requirement for the RCS temperature to be less than or equal to 140 oF

vill be relocated to a Licensec Controlled Document. The temperature requirement does not meet the 10CFR50.36(c)(2Xii) eriteria and is . Tot included in NUREG-1431. Relocating the temperature requir: ment (DOC 3.9-LA10) to a Licensec Controlled Documt nt provides assurance that the requirement is maintained and any potential changes to the specific temperature requirem<.nt will require a 50.59 cvaluation. DOC 3.9-LA10 will be revised to relocate only the RCS temperature requirement 9 the TRM. This change will be prmided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the

. Comed Responses to the ITS Section 3.9 RAl. (See RAI 3.9.6-04.)

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Response to NRC RAI Dated 12/05/97 27 Jat-98 NRC RAI Number NRC Issued Date RAI Status 3.9.6 01 12/5/97 Open - NRC Action Required NRC Description ofIssue 3.9.6 01 JFD P5

- ITS 3.9.6 Condition A and Required Action A.1 Bases discussion for ITS 3.9.6 Required Action A.1, page B 3.9-22 Condition A for STS 3.9.6 states, "Less than the required number of RHR loops Operable." Corresponding Condition A for ITS 3,9.6 states, "One or more RIIR loops inoperable." STS Required Action A.1 refers to restoring the required RIIR loops. ITS Required Action A.I would omit the word "rcquired". Comment: These are not justifiable plant specific or editorial differences. Revise the submittal to conform to the STS. These are generic changes. These changes should be brought to the Tuch Spec Task Force for future action.

Comed Response to Issue No change. Comed distgrecs. The NUREG rules of usage reserves the word required for wben the LCO allows " options" to fulfill inc TS requirement (c g. NUREG LCO 3.4.12, LTOP), or when the LCO requires less than the total number to bc OPERABLE, in this case, the LCO requires that two RHR l oops be OPERABLE, and since there are only two RHR loops in the Byron /Braidwood design, addmg the word "rcquired" would be inappropriate. Comed continues to pursue this change.

NRC RAI Number NRC issued Date RAI Status 3.9.6-02 12/5/97 Open - NRC Action Required NRC Description of Issue 3.9.6 02 Bases discussion for iTS 3.9.6 LCO, page B 3,9 22 The LCO section describes why one RHR loop must be in operation. The STS states that mixing minimizes the possibility of criticality and that RHR must be in operation in order to provide indication of reactor coolant temperature. This material has not been adopted u. the ITS. Comment: This is not a justifiable plant specific or editorial difference. Revise the submittal to conform to the STS.

Comed Response to Issuc Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI. (See RAI 3.9.5-02.)

NRC RAI Number NRC Issued Date RAI Status 3.9.6-03 12/5/97 0 1".. - NRC Action Required NRC Description of Issue 3.9.6-03 DOC M3 CTS 3/4.9.8.2 Action DOC M7 The CTS Action is modified in the ITS to require "immediate" adion to perform required remedial measures. Comment:

The DOC does not address that time limits are imposed by adoption of the STS content. Provide a revised DOC.

Comed Response to Issue No change. Comed disagrees. The addition of"immediately" is addressed in DOC 3.9-M3. The only time lima associated with ITS LCO 3.9.5 is the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time of Required Action A.4, which is consistent with CTS and therefore is not changed. Comed continues to pursue this change. (Sec RAI 3.9.5-03.)

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.. Response to NRC RAI Dated 12/05/97 27-un-98 NRC RAI Number NRC lssued Date RAI Status 3.9.6 04 12/5/97 Open - NRC Action Required NRC Ducription of Issue 3 9.6-04 DOC LA10 CTS SR 4.9 8.2 Tbc proposed CTS change relocates details regarding flow and temperature requirements during testing to licensee controlled documents. This is generic change TSTF 22. TSTF 22 was rejected by the staff. Comment. Withdraw the CTS change and resubmit revi.:d ITS.

Comed Response to Issue Sec Comed Response to RAI 3.9.5-05.

NRC RAI Number NRC issued Date RAI Status 3.9.7-01 12/5/97 Open NRC Action Required NRC Description of Issuc l ~3.9.7 01 CTS 4.9.10 l STS SR 3.9.7.1 The CTS markup for this Surveillance Requirement refers to determining the water level during the movement of irradiated fuel assemblics. Correspondmg STS SR 3.9.7.1 does not contain this applicability reference. Comment: The CTS markup is in error. Revise the CTS markup to conform to the STS.

Comed Response to issue No change. Comed disagrees. The CTS markup for CTS SR 4.9.10 is merely clarifying that this surveillance is only 3 required to be performed consistent with the revised CTS Applicability, (i.e., During movement of" irradiated" fuel-t

..[d assemblics . . ) asjustined in DOC 3.9 LAl1. Comed is not proposing that this Applicability reference be included in the ITS SR. This change is consistent with the Applicability of NUREG LCO 3.9.7, Comed continues to pursue this change.

NRC RAI Number NRC lssued Date RAI Status 3.9.7-02 12/5/97 Open - NRC L. on Required NRC Description of Issue 3.9.7-02 Bases discussion for ITS 3.9.7 Applicable Safety Analysis, page B 3.9-25 The discussion in the STS refers to Regulatory Positions C.1 e and C.I.g of Regulatory Guide 1.25 w hich adopts a 23 foot minimum level requirement for refueling. Comment: This is not ajustifiable editorial difference. Revise the submittal to cither conform to the STS or provide plant specific Bases for the LCO limit of 23 feet of water above the reactor vessel flange.

Comed Response to issue Comed will revise the Applicable Safety Analysis Section of the Bases for ITS LCO 3.9.7 to include reference to Regulatory Guide 1.25, C. I.c and C. I.g. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal icvision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAl.

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. Response t2 NRC RAI Dsted 12/05/97 27 J:2-9s NRC RAI Number NRC Issued Date RAI Status 3.9.7-03 12/5/97 Open NRC Action Required NRC Description of Issue 3.9.7-03 DOC L5 ITS LCO 3.9.7 The CTS changes identified as L5 include administrative changes because CTS limits on movement of control rods is included in the ITS definition of CORE ALTERATIONS. Comment: Provide a separate identification and discussion of cach administrative change.

Comed Response to Issue No change. Comed believes that DOC 3.7-L5 adequatelyjustifics the less restrictive change, and does not cor.'ain any administrative changes. Comed continues to pursue this change.

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NRC RAI Number NRC lisued Date RAI Status 3,9.7 04 12/5/97 Open - NRC Action Required NRC Description ofissue 3.9.7-04 DOCL5 ITS LCO .'.9.7 The CTS changes identified as L5 include less restrictive changes not d4 cussed because CTS establish water level limits when fuel assemblics or control rods are moved with Jradiated fuel scatd in the reactor vessel. Comment: Provide a l separate identification and discur,sion of each less restrictive change.

Comed Response to Issue

No change. Comed disagrecs. The whole purpose of DOC L5 and the relocation of" irradiated" fuel assemblics is t N discussed in LAl1. Comed continues to pursue this change.

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NRC RAI Number NRC lssued Date RAI Status 3.9.7-05 12/5/97 Open-NRC Action Required NRC Dexription of Issue 3.9.7 05 JFD C4 ITS 3.9.7 Applicability IFD C4 proposes to revise the STS format foi constructing applicable conditions. Comment: This is a generic change tbt requires a staff-approved TSTF change. Revise the submittal to adopt the STS.

Comed Response to Issue WOG-81 will be withdrawn from the ITS submittal. ITS and NUREG will be revised to adopt the ISTS presentation in the Applicability section ofITS LCOs 3.9.4 and 3.9.7. As a result, LCO JFD i 4 C4 will be deleted. This change will be provided in our comprehensive ITS Section 3.9 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI. (See RAls 3.7.1043,3.7.Il-02, 3.7.13-06, and 3.9.4-06.)

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