ML20203C175

Responds to 971205 RAI Re Util Amend Requesting to Adopt Improved TS of NUREG-1431,Rev 1.Encl Does Not Include Any Replacement or Markup Pages

ML20203C175
Person / Time
Site:	Byron, Braidwood
Issue date:	02/13/1998
From:	Tulon T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1431 NUDOCS 9802250106
Download: ML20203C175 (11)

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February 13,1998 s

United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

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Subject:

Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket No. 50-454 and 50-455 Braidwood Nuclear Power Station, Units I and 2 i

Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Nos 50-456 and 50-457 P.esponse to Request for AdditionalInformation for ITS Beyond Scope Changes

References:

(1)

G. Stanley and K. Graesser (Commonwealth Edison) to NRC letter dated December 13,1996 (2)

R. Assa (NRC) to O. Kingsley (Con.monwealth Edison) ietter dated December 5,1997 The purpose of this letter is to transmit Commonwe?lth Edison's (Comed's) re conse to the NRC's request for additional information (RAI) for Improved Technical Specifications (ITS) Beyond Scope Changes The responses to the RAI questions are contained in.

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The RAI contains questions and comments stemming from the NRC's partial review of a

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Comed request (Reference 1) to amend the Current Technical Specifications (CTS) for Byron Units 1 and 2 and Braidwood Units I and 2. The amendments were requested in order to adopt the Improved Technical Specifications of NUREG-1431, Revision 1.

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9802250106 980213 PDR ADOCK 05000454 il

U.S. Nuclear Regulatory Commission February 13,1993 As discussed with NRC Staffin an August 12,1997 teleconference, this submittal does not include any replacement or CTS Markup pages. The required page changes and markups will be submitted at a later date when the NRC review and acceptance of Cons.d's Response to this NRC RAI is complete.

Please address any comments or questions regarding this matter to Dave Chrzanwoski, Nuclear Licensing Department.

Sincerely, othy J. Tulon u'ite Vice President l

Braidwood Nuclear Generating Station : Response to NRC RAI Report cc:

R gional Admiaistrator - Region III, NRC Byron Project Manager - NRR Braidwood Project Manager - NRR Senior Resident inspector - Brai.. wood Station Senior Resident inspector - Byron Station i

Office of Nuclear Facility Safety - IDNS ofture.. 91t010tjt.&w i

. _ _ __________ O

Attachment i Response to NRC RAI Repon on the Comed ITS Submittal m

Response to NI2C RAI Dzted 01/16/98 12 Feb-98 NRC RAI Number NRC Issued Date RAI Status BYS 3.0 1/16/98 Open Comed Action Required NRC Descripb ofIssue DOC L.7 JFD P.16 ITS LCO 3.3.2, Condition M CTS Table 3.3 3, Action 15a The proposed change involves the action completion time for restoring an inoperable instrumentation channel for the auxiliary feedwater pump (AFWP) suction transfer function on low pressure.

The proposed TS change would specify 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for restoration of an inoperable AFW actuation instrumentation channel plus an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> aller declaring an associated AFW pump inoperable before going to mode 3. The staff finds this unacceptable because the ITS permits only 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for an inoperable irtmment channel to be restored before going to mode 3. As a separate action, the ITS specifies 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for restoration dan inoperable AFW pump. The actions associated with an inoperable instrumentation channel and an inoperable AFW pump are not combined in the ITS or in the current Byron and Braidwood TS.

Asjustification for the above proposed TS changes, the licensee stated " Typically, it is inappropriate for one train of actuation instrumc1tation to require a shutdown in a shorter completion time than if the component is inoperable." The staff finds this justification to be inadequate in that instrumentation restoration action times are typically shorter than associated component action times and no basis for the proposed new action is provided. Comment: Provide additionaljustification for the propa ed change.

Comed Response to issue No change. CTS Table 3.3 3 (Functional Unit 6g) Action 15a requires declaring the associated AF pump inoperable immediately whenever an ESFAS channel for "AF Pump Suction Transfer on Suction Pressure-Low" is inoperable. ITS LCO 3.3.2 (Functional Unit 6f) Condition M is proposed as the appropriate action requirements associated with this Function. ITS Condition M is proposed with a Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore a single inoperable channel of the "AF Pump Suction Transfer on Suction Pressure-Low" Function. If restoration of the instrument channel is not completed in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, Condition N is entered and the AF train is immediately declared inoperable, in acenrdance with ITS LCO 3.7.5," Auxiliary Feedwater System," a Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for restoring the AF train to operable status. This it consi tent with CTS 3.3.2, Table 3.3-3, Functional Unit 6g and Action if a. As stated in DOC 3.3-L7, it is inappropriate for one train of the actuation instrumentation to require a snutdown in a shorte "ompletion Time than if the component is inoperable. The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time for restoration of the instrumentation channel is considered appropriate due to: 1) tr.e capability of the channel on the operable ESFAS train to actuate a suction trmsfer on the unaffected AF train,2) the fact that the preferred source (l.c., the CST)is available and aligned, and monitored every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />,3) the capability of manually realigning the AF pump suction to the Essential Service Water System from the Main Control Room, and 4) the availability in the Main Control Room of a low suction pressure alarm from the operable channel, a CST low level alarm, CST level indication, and other instrumentation to alert the Operator during this inter al. Comed continues to pursue this change.

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Response to NRC RAI Doled 01/16/98 ta Feb-98 NRC RAI woihr -

NRC lisued Date RAI Statas BYS 5.0 1/16/98 Open Comed Action Required NRC Description ofissue DOC M,13 -

JFD F.3 ITS SR 3.4.1 A Note CTS SR 4.2.3.5 The Surveillance frequency Note not requiring ver'fication ni the measured RCS total flow (by performance of a precision c4.lorimetric heat balance) is increased to 7 days after reaching 90% RTP. Alihough the current plant TS do not specify a time limit for this calibratlan, they do require the RCS total flow rate to be determined by precision heat balance measurement prior to completion of physics tests. In addition, the STS specify a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time interval once 90% RTP is reached. Since the 7 day frequency has previously been approved for Vogtle,:t appears that this proposed change is generic and should be requested and justified through the WOG as a generic change to the WOG STS. Therefore, it is not appioved as a plant specific change at this time. Cominent: Revise the submittal to adapt the STS.

l Comed Response to issue No change. The NRC has previously approved the 7 day Frequency for SR 3.4.1.4 for Vogtle, Ginna, and Zion on a plant specific basis. In addition, several other utilities have also included this change in their ITS submittals. This change was o-Iginally submitted by Byron /Braidwood and appo ved by the Westinghouse Owner's Graup (WOG) as V'OG 99, and has been under TSTF review since November 19,1996. Comed continues to pursue this change.

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Response to NRC RAI D:,ted 01/16/98 12 Feb.98 NRC RAI Number NRC Issued Date RAI Status BYS 6.0 1/16/98 Open - Comed Action Required NRC Description of Issue DOC L.28 JFD P.44 ITS LCO 3.4.3 CTS LCO 3.4.9.1 The proposed change, P/r Limits Action for P/T limits, would require placing the smit in mode 5 rather than in mode 5 with RCS pressere < 500 psig. Keeping the RCS pressure < 500 psig at RCS temp of 200 F is essential to snaintaining P/r limits. The current Byron TS require this ccndition be achieved in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and the ITS allows 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This is already a relaxation in action time. To further delay the RCS pressure reduction will increase risk.

Also there is the possibility that Action C may not be entered if Action B.2 is completed, i.e., when the RCS temperature is 200 F but the RCS pressure is still 500 psig. Therefore, there is no requiiement to immediately go into Acticn C to restore the parameters to 500 psig. Therefore, this change is 'mac:eptable. Comment: Revise the submittal to retain the 500 psig RCS pres..!re requirement.

Comed Response to issue No change. Comed agr:es with the NkC statement,". there is the possibility that Action C may not be entered if Actioa B.2 is completed, i.e., when the RCS temperature is less than or equal to 200*F but the RCS pressure is still greater than or equal to 500 psig." The ByrorvBraidwood P/T limits curves in the PTLR may r.st necessarily require RCS pressure to be less thaa or equal to 500 psig to be within acceptable limits, as is cunently Se case for the Byron /Braidwood P/r limits curves at 200'F. Therefore, Condition C may not be applicable. Entry into Condition C is MODE dependent. Whenever the Unit L less than or equal to 200'F (i.e., MODE 5) and the pressure and temperature (P/r) limits are not restored, ITS l

Condition C must be entered. Upon c'itry into MODE 5 with the P/T limits still not resured (i.e., regardless of whether RCS pressure is above or below 500 psig), Condition C is applicable and must be entered to restore RCS pressure and temperature to within the P/r limits. In addition, the entry conditions for Condition A (unit in MODE 1,2,3, or 4), and therefore, Condition B (Required Action and associated Completion Time of A not met), are no longer applicable based on entry into MODE 5 (provided Required Action A.2 has been completed), and Conditions A and B are exited. Specifyi.g any MODE 5 actions in Conditions A or B is technically incorrect and against the ITS rules of usage since once the Unit reaches MODE 5, these Conditions are exited. With the changes proposed by Comed, it is clear that when the Unit is in MODES 1,2,3, or 4, only Conditions A and B apply. When the Unit is in any MODES other than MODES 1,2,3, or 4, Conditica C applies. Under the requirements of the NUREG, given the situation with RCS pressure greater than or equal to 500 psig in MODE 5 and the P/T limits not restored, Conditions B and C would both apply This would lead to confusion for the Operator since ^ e Required Actians are different. Furthermore, the Operator is te follow Required Actions for a Condition for which the entry Conditions no longer are applicable. Comed believes this to be a " broke" in the NUREG,

reated in the conversion from CTS to ITS. Comed disagrees with the staft's statement, "The current Byron TS require this condition be achieved in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and the ITS allows 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This is already a relaxation in action time." Both the Byron and Braidwood CTS contain actions to restore the RC3 pressure and temperatuu to within limits in 30 minu*es, or be in hot standby (MODE 3) in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce RCS temperature to less than 200'F (MODE 5) within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. These same requirements are contained in l'IS cs Required Actions (RA) A.1 (Restore to within limits in 30 minutes), B.1 (Be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />), and B.2 (Be in MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />). Comed continues to pursw. 'his change.

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Response to NRC RAI Dated 01/16/98 12-reb,

NRC RAI Number NRC issued Date RAI Status BYS 8.0 1/16/98 Opea-Comed Action Required NRC Description of issue DOC L.I4 JFD P.4 ITS SR 3.4.18.2 CTS SR 4.4.1.5.2.2 The Surveillance Frequency is praposed to be changed from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for verifying boron concentration prior to opening an isolation valve in an isolated loca. Thejustin:ation given for this proposed change cites the amount of time to sampic and confirm the concentration results, llowever, the Surveillance Frequency does not define the amount of time for sampling but everely the time tne Surveillance should be completed prior to opening either the hot or cold leg isolation valve. Operating experience has shown that completing this Surveillance within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ofopening an isolation valve 4

provides reasonable assutan:e that the bcron concentration difference will remain within acceptable li' nits until the loop is unisolated. This has not bean justified for the longer time period and, therefore, we do not find the proposed change --

l acceptable. Comment: Revise the submittal to retain the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance frequently.

Comed Response to issue Comed will tevise ITS SR 3.4.18.2 to retain the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Surveillance Frequency. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Beyon' Scope RA!,

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Respons to NRC RAI Dated 01/16/98 12-Feb-9s NRC RAI Number SRC issued Date RAI Status i

BYS 3.0 1/16'98 Open Comed Action Required v

NRC liescription of issue DOC L.7 JFD P.16 ITS I CO 3.3.2, Condition M CTS Table 3.3-3, Action 15a The proposed change involves the acticn completion time for restoring an inoperable instrumentation channel for the auxiliary feedwater pump (AFWP) suction transfer function on low pressure.

The proposed TS change u ould specify 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for restoration of an inoperable AFW actuat:on instrumentation channel plus an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after declaring an associated AFW pump inoperable before going to mode 3. The staff Hnds this unacceptable because the ITS permits only 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for an inoperable instrument channel to be restored before going to mode 3. As a separate action, the ITS specifies 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for restoration of an inoperable AFW pump. The actions associated with an inoperable instrumentation channel ar.d an ir. operable AFW pump are not combined in the ITS or in the current Byron and Braidwood TS.

As justification for the above proposed TS changes, the licensee stated " Typically, it is inappropriate for one train of actuation instrumentation to require a s' utdown in a shorter completion time than if the component is inoperable." The staff finds this justification to be inadequate in that instrumentation : e,toration action times are typically shorter than associated component action times and no basis foc the proposed new action is provided. Comment: Provide additionaljustihcation l

for the proposed change.

Comed Response to issue No change. CTS Table 3.3 3 (Functional Unit 6g) Action 15a requires declaring the associated AF pump inoperable (nV) immediately whenever an ESFAS channci for "AF Pump Suction Transfer on Suction Pressure-Low" is inoperable. ITS LCO 3.3.2 (Functional Unit 6f) Condition M is proposed as the appropriate action requirements associated with this Function. ITS Condition M is proposed with a Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore a single inoperable channel of the "AF Pump Suction Transfer on Suction Pressure-Low" Function. If restoration of the instrument cilannel is not completed in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, Condition N is entered and the AF train is immediately declared inoperable. In accordance with ITS LCO 3.7.5, " Auxiliary Feedwater System," a Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> i. JMwed for restoring the AF train to operable status. This is consistent with CTS 3.3.2, Table 3.3-3, Functional Unit og and Action 15a. As stated in DOC 3.3-L7, it is inappropriate for one train of the octuation instrumentation to require a shutdown in a shorter Completion Time than if the component is inoperable. The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time for restoration of the instrumentatica channel is considered appropriate due to: 1) the capability of the chanael on the operable ESFAS train to actuate a suction transfer on the unaffected AF train,2) the fact that the preferred source (i.e., the CST) is available and aligned, and monitored every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />,3) the capability of manually realigning the AF pump suction to the Essential Service Water System from the Main Control Roam, and 4) the availability in the Main Conmol Room of a low suction pressure alarm from the operable channel, a CST low level alarm, CST level indication, and other instrumentation to alert the Operator during this interval. Comed continues to pursue this change.

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Rcsponse to NRC RAI Dated 01/16/98 12-reb-98 NRC RAI Number NRC issued Date RAI Status

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I1Y S 5.0 1/16/98 Open - Comed Action Required

%J NRC Description of issue IX)C M.15 JFD P3 ITS SR 3.4.1.4 Note CTS SR 4.23.5 The Surveillaace Frequency Note not requiring verit. cation of the measured RCS total flow (by performance of a precision calorimetric heat balance) is increased to 7 days after reaching 90?6 RTP. Although the current plant TS do not specify a time limit for this calibration, they do require the RCS total flow rate to be determined by precision heat balance measurement prior to completion of physics tests. In addition, the STS specify a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time interval once 9096 RTP is reached. Since the 7 day frequency has previously been approved for Vogtle, it appears that this propoed change is generic and should be requested andjustified through the WOG as a generic change to the WOG STS. Therefore, it is not appros eu as a plant-specific change at this time. Comment: Revise the submittal to adapt the STS.

Comed Response to issue No change. The NRC has previously approved the 7 day Frequency for SR 3.4.1.4 for Vogtle, Ginna, and Zion on a plant specific basis. In addition, several other utilities have also included this change in their ITS submittals. This change wms originally submitted by Byron'Braidw ood and approved by the Westinghouse Owner's Group (WOG) as WOG-99, and has been under TSTF review since November 19,1996. Comed continues to pursue this change.

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Response to NRC RAI D ted 01/16/98 12-Feta 8 NbtI bmt

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BYS 6.0 1/16/98 Open Comed Action Required V

NRC Deseription of hsue DOC L.28 JFD P.44 ITS LCO 3.4.3 CTS LCO 3.4.9.1 The proposed change, P/T Limits Action for pet limits, would require placing the unit in mode 5 rather than in mode 5 with RCS pressure < 500 psig. Keeping the RCS pressure < 500 psig at RCS temp of 200 F is essential to maintaining P/T hmits. TLe current Byron TS require this condition be achieved in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and the ITS allows 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This is already a relaxation in action time. To further delay the RCS pressure reduction willincrease risk.

Also there is the possibility that Action C may not be entered if Action B.2 is complete J, i.e., when the RCS temperature is 200 F but the RCS pressure is still 500 psig. Therefore, there is no requirement to immediately go into Action C to restore the paran.cters to 500 psig. Derefore, this change is unacceptab'e. Comment: Revise the submittal to retain the 500 psig RCS pressure requirement.

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CoraEd Response to issue No.hange. Comed agrees with the NRC atatement,". there is the possibility tha' Action C may not be entered if Action B.2 is completed, i.e., w hen the RCS temperature is less than or equal to 200'F but the RCS pressure is still greater than or equal to 500 psig " The Byron'Braidwood Pfr limits cur es in the PTLR may not necessarily require RCS pressure to be less than or equal to 500 psig to be within acceptable limits, as is currently the case for the Byron /Braidwood P/T limits curves at 200'F. Therefore, Condition C may not be applicable. Entry into Condition C is MODF dependent. Whenever the Unit is less than or equal to 200'F (i.e., MODE 5) and the pressure and temperature (P/T) limits are not restored, ITS Condition C must be entered. Upon entry into MODE 5 with the PfI limits still not restored (i.e., regardless of whether hd RCS pressure is above or below 500 psig), Condition C is applicable aQ must be entered to restore RCS pressure and terrperature to within the P/T limits. In addition, the entry conditions for Condition A (unit in MODE 1,2,3, or 4), and therefore, Condition B (Required Action and associated Completion Time of A not met), are no longer applicable based on entcy into MODE 5 (provided Required Action A.2 has been completed), ard Conditions A and B are exited. Specifying any MODE 5 actions in Conditions A or B is technically incorrect and against the ITS rules of usage since once the Unit reaches MODE 5, these Conditions are exited. With the changes proposed by Comed, it is clear that when the Unit is in MODES 1. 2,3, or 4, only Conditions A and B apply. When the Unit is in any MODES other than MODES 1,2,3, or 4, Condition C applies. Under the requirements of the NilREG, given the situation with RCS pressure greater than or equal to 500 psig in MODE 5 and the Pfr limits not restored, Conditions B and C would both apply. His would lead to confusion for the Operator since the Required Actions are dilTerent. Furthermore, the Operator is to follow Required Actions for a Condition for which the entry Conditions no longer are applicable. Comed believes this to be a " broke" in the NUREG, created in the conversion from CTS to ITS. Comed disagrees with the staffs statement, "The current By ron TS require this condition be achieved in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and the ITS allows 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This is already a relaxation in action time." Both the Byron and Braidwood CTS contain actions to restore the RCS pressure and temperature to within limits in 30 minutes, or be in hot standby (MODE 3)in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce RCS temperature to less than 200'F (MODE 5) within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. These same requirements are contained in ITS as Required Actions (RA) A.] (Restore to within limits in 30

--minutes), B.1 (Be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />), and B.2 (Be in MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />). Comed continues to pursue this change

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Response to NRC RAI D:tcd 01/16/98 12-reb as NRC RAI Number NRC Issued Date RAI Status BYS 8.0 1/16'98 Open Comed Action Keqt.. ed NRC Description of issue

'OC Ll4 Jhi P.4 ITS SR 3.4.18.2 CTS SR 4.4,1.5.2.2 The Surveillance Frequet :y is proposed to be changed from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for verifying boron concentration prior to opening an isolation valve ic an isolated loop. The justification given for this proposed change cites the amount of time to sample and confirm the concentration results. Ilowever, the Surveillance Frequency does not define the amount of time for sampling but merely the time the Surveillance should be completed prior to opening either the not or cold leg isolation valve. Operating experience has shown that completing this Surveillance within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of opening an isolation valve provides reasonable assurance that the boron concentration difference will remain within acceptable limits until the loop is unisolated. This has not been justified for the longer time period and, therefore, w e do not find the proposed change acceptable. Comment: Revise the submittal to retain the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance frequently.

Comed Response to issue Comed will revise ITS SR 3.4.18.2 to retain the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Surveillance Frequency. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Beyond Scope RAI.

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