ML20203D053

Forwards Response to NRC RAI for Improved TSs Section 3.5 & 3.6.Responses to RAI Questions Contained in Encl

ML20203D053
Person / Time
Site:	Byron, Braidwood
Issue date:	12/08/1997
From:	Tulon T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1431 NUDOCS 9712160095
Download: ML20203D053 (33)

Text

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onnmonwrahh lam.n o mpany tirthlwmmi(ernoratmg Mahon Rome *1.thmH4 Ilrm rulle,11. m io7%19 1 rl HI0404 2801 Deccmber 8,1997 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

Subject:

13yron Nuclear Power Station, Units I and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos 50-454 and 50-455 4

13raidwood Nuclear Power Station, Units I and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Nos 50-456 and 50-457 Response to Request for Additional Information for ITS Sections 3.5 and 3.6.

References:

(1)

R. Assa (NRC) to 1. Johnson (Commonwealth Edison) letter dated August 5,1997.

(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 (RAl) for improved Technical Specifications (ITS) Sections 3 5 and 3.6.

The responses to the RAI questions are contained in.

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 I and 2. The amendments were requested in order to adopt the improved Technical Specifications of NUREG-1431, Revision 1. The questions and comments involve only Sections 3.5 and 3.6 of the Reference (2) submittal.

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-2 December 8,1997 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 Comed's Response to this NRC RAI is complete.

Pleas. address any comments or questions regarding this matter to oar Nuclear Licensing Department.

Sincerely.

4 Ti l iy J. Tulon Si dice President Braidwood Nuclear Generating Station : Response to NRC RAI Report cc:

Regional Administrator - Region 111, NRC Byron Project Manager - NRR Brairlwood Project Manager - NRR Senior Resident inspector - Braidwood Station Senior Resident inspector - Byron Station OITice of Nuclear Safety - IDNS otnrs'97132mt dw U

i Response to NRC RAI Report on the Comed ITS Submittal I

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j Respons to NRC RAI D:ted i1/05/97 09-Dec 97 NRC RAI Number NRC loued Date RAI Status j

3.5 411 11/5/97 Oper - NRC ^.ction Required NRC Description of Issue JFD C2 ITS 3,5.1 Applicability WOGHI WOG M1 proposes to modify the Applicability statements throughout the STS and is proposed for adoption in the ITS.

This generic change is not approved. Conunent: Revise all Applicability statements affected by WOG-81 to conform to l

the JTS. This is a global conunent.

Comed Respon.e to Inue l

WOG-81 was withdrawn in its entirety throughout the ITS submittal. The submntal was revised to -

adopt the STS presentation in the Applicabihty Section.

3 NRC RAI Number NRC Issued Date RAI Status 3.5 1-01 11/5/97 Open - Comed Action Required i

d NRC Dencription of Inue DOC A7 JFD B4 CTS 4.5.1.1.b ITS SR 3.5.1.5 CTS 4.5.1.1.b refers to an accumulator solution volume increase of 70 gallons. Corresponding ITS SR 3.5.1.5 proposes to utili/c 10% ofindicated level instead. No calculation is provided to demonstrate that 10% ofindicated level is

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equivalent to 70 gallons. Comment: Revisc DOC A7 to demonstrate that 10% indicated level is equivalent to 70 gallons.

Comed Response to issue I

Section 3.5 DOC A7 was wvised to read. " CTS SR 4.5.l.l.b requires the acemnulators be sampled after cach volume increase of greater th m or equal to 70 gallons. Currently, when filling the accumulators per the operating procedures, the accumulators are conservatively required to be sampled aller each fdl to ensure compliance with this SR. ITS SR 3.5.1.5 uill require verifying the boron concentration of the accumulator solutian once within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after cach solution volume increase of greater than or equal to 10% of indicated level which is equivalent to 70 gallons. The nominal water volume of the Si Accumulators is 7106 gallons based on the minimum and maximum volumes of 6995 gallons at 31% indicated level (Iow level alarm) and 7217 gallons at 63% indicated level (higli level alarm). This change in volume is equal to 222 gallons over a 32% level span or approximately 7 gallon per % level change. The 0% level equivalent is 6781 gallons and the 100% level indication is 7466 gallor.s equaling a total change of 685 gaFons over the 100% indicated level span or 6.85 gallons per % level change. This would equal a 10.2% indicated level increase for a 70 gallon volume increase in the Si accumulator. The expression for volume has been changed from gallons to an equivalent percent indicated level to be consistent with the indication available to the operator and the manner in w hich the increase in rohime is verified. This change is perceived as the intent of the CTS wording is considered editorial in nature and does not intoh e a technical change (either actual or interpretational) to the TS. This change is consistent with NUREG-1431.

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Respons? to NRC RAI Dated 11/05/97 09 pec-9 NRC RAI Number NRC isMate RAI Status 3.5.2 411 11/5/97 Open - NRC Action Required

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h RC Description of innue.

DOC LA6.

CTS 3.5.2 footnote

• j ITS LCO 3.5.2 Note 2 J

Hases discussion for ITS LCO 3.5.2. STS markup pge B 3.5 14 _

Bases insert B 3.5- '

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CTS 3.5.2 footnote

• requires the accumulatois to be Operable during Mode 3 with pressurizer pressure < 1000 psig uhenever isolation valves S18809A or S18809B are closed It has been proposed to move this requin: ment to the TRM and to replace it with a requirement to proviac an alternate means of cold leg injection for each isolated flow path. DOC LA6 states that establishing accumulator Operability during this condition is not important provided an alternate means of.

i csablishing cold leg injection is established. Comment: Revise the 11ases to state what the acceptable alternative means 4

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of cold water injection are, including Operable accumulators.

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! The LCO Section of the Bases for ITS LCO 3.5.2 has been modified to add the statement, "An alternate means may include: 1) OPERABLE accumulators with their isolation valves either closed, but energized, or open; 2) cold leg

- injection via the Safety injection pumps, and the Sl8821 A/B and the S18335 valves; or 3) cold leg injection via the Centrifugal Charging pumps and the Sl8801 A/B valves." In additioniSection 3.5 DOC LA6 has been revised to selocate the available alternate means of cold leg injection for cach isolated flow path to the Bases vice the TRM.

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e Response to NRC RAI Dated 11/05/97 os sec-97 NRC RAI Number NRC isnoed Date RAI Status 3.5.5-01 11/5/97 Open - NRC Action Required NRC Description ofissue DOC L8 CTS 3/4 4 6 2 Action b i

ITS 3.5.5 Action B in the event reactor coolant system leakage is above limits and is not restored to within limits in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, CTS 3/4.4.6.2 Action b requires being in Cold Shutdown (Mode 5) within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after reaching flot Standby (Mode 3). Corresponding Action 11 of ITS 3.5.5 requires being 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 Mode 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; it does not require entry into Mode 5.

The CTS markup shows this change is addressed by DOC L8, w hich by focusing on the deletion of Mode 4 from the 1

/ Applicability, covers the change to Mode 4. Ilowever, L8 does not address the Completion Time change to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, w hich is hard to characterite because the CTS do not stipulate w hen Mode 4 must be entered, only that Mode 5 must be entered within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after entering Mode 3.. Comment: Revisc DOC L8 to address the change 3

• Completion Time.

ComF.d Response to Issue Section 3.5 DOC LH has been revised to state, " CTS LCO 3.4.6.2 requires the Applicability of the seal injedion flow

- requirements in Modes 1,2,3, and 4. In addition, the LCO and SR references various conditions for exiting the Mode of Applicability and exceptions to Specification 4.0.4 for entry into Mode 3 and 4. ITS LCO 3.5.5 requires the Applicability of the seal injection flow requirements in Modes I,2, and 3. The CTS has been revised to climinate the Mode 4 seat injection flow requirements. This change is acceptable since high seal injection flow is less critical as a result of the louer initial RCS pressure and decay heat removal requirements in Mode 4. In Modes I,2, and 3, the scal injection flow limit is dictated by pr'CS flow requirements. Therefore, RCp seal injection flow is limited in Modes 1, ~ and 3 to ensure e

adequate ECCS performance and changing the Mode of Applicability is acceptable. Changing tne Applicability to 4

MODES 1,2, and 3 changed the Completion Time to exit the mode of applicability from 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to be in MODE $ to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to be in MODE 4. The Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to be in MODE 4 is consistent with both the CTS and the ITS Completion Times used throughout the specifications for placing the unit in MODE 4, including LCO 3.0.3. This change is consistent with NUREG 1431. See Discussion of Change M2 for discussion of the Mode 3,4.0.4 cxception." Comed continues to pursue this change.

NRC RAI Numher NRC issued Date RAI Status e

3.6-01 11/5/97 Open - NRC Action Required NRC Descriptlun of issue

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DOC Al CTS 3/4 6 4.1,il drogen Monitors 3

ITS 3 3.3 ITS 3.3.6 The CTS markup for CTS 3/4.6.41,11ydrogen Monitors, shows that this specification is retained as part ofITS 3.3.3; however, the CTS Split Report states this specification is retained as part ofITS 3.3.6, Radiation Monitoring. Comment:

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Correct this discrepancy.

Comed Response to Issue The Split Report was revised to state that the ll drogen Monitors are being retained as part of ITS LCO 3.3.3.

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- Response to NRC RAI IMted i1/05/97 09 nec-97 NRC RAI Number NRC inued D te RAI Status 3 M)2' I t/5/97 Open.NRC Action Required l

NRC Description of luue DOC L9 JFD P.6 Bases JFD B2 (Bases for !TS 3.63)

Bases JFD P6 STS 3 6.9, If>drogen Mixing System DOC 1A JFD P.6, Bases JFD B2 (Bases for ITS 3.6.8).' and Bases JFD P6 imply or state that the reactor containment fan coolers provide an altruate hydrogen control function similar to or the same as the STS hydrogen mixing system ITS l

- 3 6 6 and associacd Bases do not contain any infornation or discussions about the hydrogen mixing /h drogen control I

3 function vf fue reactor containment fan coolers. In addition, JFD B6 and Bases JFD P.6 do not discuss how the containment cooling system SRs ahJ Actions are more conservative than the Actions and SRs associated with STS 3.6.9.

Comment: Adopt STS 3.6.9 or a plant-specific equivalent in the ITS with appropriate discussions and justifications or provide additional discussion and justification for not adopting STS 3.6.9, See Comment 3.6M12.

Comed Rengumne to lanue The fact that the Containment Spray S stem and the Rt. actor Containment Fan Coolers (RCFCs) provide an alternate 3

hydrogen control function is discussed in the Byron /Braidwood UFSAR Section 6.2.5.2.3, "flydrogen Mixing System Design," and states, "The function of the mixing subsystem is to casure that local concentrations with greater than 4%

a hydrogen cannot occur within the primary containment following a LOCA. The mixing is achicted by natural convection processes, containment fan cooler operation, and the containment spray system. Natural convection occurs as a result of the temperature difference between the bulk gas space in the vessel and the containment wall. The natural convection action is ;naanced by the momentum of steam emitted from the point of the break. The operation of the containment spray system following the accident will result in the creation of an extremely turbulent atmosphere within the containment, as demonstrated in the Zion Station full flow containment spray system test. The containment spray system is discussed in Subsection 6.5.2. Mixing of the c atainment atmosphere to assure that there will be no " pocketing" of large hydrogen concentrations will be accomplis' cd by the scactor containment fan coolers (RCFC), an engineered safety feature described in Subsection 6.2.2 The omation of the recombiner system is not dependent on the operation of any engineered safety features other than the reactor containment fan coolers. Four coolers (two required for both normal and postaccident conditions) cach supplying 94,tKK) cfm (normal operation) or $9,000 cfm (postaccident operation) are provided for cach containment. The RCFC fans discharge this air through concrete ducts to the lower clevation." For 4

completeness, the Background Section of the Bases for ITS LCO 3.6.6, Containment Spray and Cooling Systems," was revised to add the sentence, "In addition, the Containment Spray System and Containment Cooling System provide an

[4 alternate hydrogen control function to da hydrogen recombiners during post LOCA conditions." The fact that the Post-LOCA Purgc S" stem provides an alternate hydrogen control function is discussed in the Byron /Braidwood UFSAR Section 9.4.9.3.1.a.1, *hst-LOCA Purge 5 stem Safety Design Bases," and states "The port-LOCA purge sy stem is a non-safety-3 related system (p'r Branch Technical Position CSB 6 2) which is provided as a backup to the hydrogen recombiners to purge the containuent of h drogen to maintain the hydrogen concentration below 4% by volume." Comed continues to 3

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Response to NRC RAI Dated 11/05/97 09-Dec-97 NRC RAI Number NRC lasued Date RAI Status 3.6.1-01 11/5/97 Open NRC Action Required -

NRC Description of lasue DOC AI -

CTS 3/4.6.1 CTS 3/4 6,1, the existing specification for primary containment, is the basis for ITS 3.6.1, Containment. In the upper right hand corner of the CTS markup, DOC Al shows CTS 3/4.6.1 also has requirements uhich apply to ITSs 3.7.3 and j

- 5.5.16; however, the CTS markup does not identify any specific requirements related to these specifications. DOC Al

' does not provide sufncient technicaljustification to explain this reference to ITSs 3.7.3 and 5.5.16. Comment: Revise the CTS markup to delete these ITS references or explain why they are appropriate.

Comed Response to Issue The CTS Markup pages wcre revised to delete the reference to ITS LCO 3.7.3. CTS DOC A5, as annotated on the CTS Markup, references Specification 5.5.16.

NRC RAI Number NRC Issued Date RAI Stat'un j

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3.6.1-02 11/5/97 Open NRC Action Required NRC Descriition of lasue l

DOC Al

- CTS 3.6.1.6 Actions ITS 3 6.1 Action A CTS 3/4.6.1.6 ACTION a allows 15 days to restore containment integrity for structural degradation and ACTION b allows 72 ht. its to restore containment integrity for an inoperable tendon group. Corresponding ITS 3.6.1 ACTION A rJlows one

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hour to restore the containment Operable status. ITS 3.6.1 now includes all Operability requirements and remedial actions for conta.nment. Thus CTS 3.6.1.6 ACTIONS a and b are replaced with ITS 3.6.1 Action A. Since Action A is More Restrictive than the action requirements it replaces, this change is more restrictive, not administrative. Comment: Revise the submitta' to show that CTS 3.6.1.6 Actions a and b are replaced by Action A ofITS 3.6.1, and providejustification for this more restrictive change. See Comment 3.6.103.

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

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Respons2 to NRC RAI Dated 11/05/97 09-pec-97 NRC RAI Number NRC Insued Date RAI Status

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3.6.1 11/5/97 Open-NRC Action Required j

NRC Description of luue j

DOC Al CTS 3.6.l.6 Actions ITSs 5.5.6 and 5.6.8 '

CTS 3.6.16 Actions require submitting Special Repo;ts to the Conunission in accordance with CTS 6.9.2. Since these CTS Actions are replaced by ITS 3.6.1 ACTION A, which does not require Special Reports, the CTS markup should indicate the disposition of the requirement for Special Reports - whether moved to another specification or deleted DOC Al indicates generally that portions of CTS 3.6.1.6 are moved to ITS 5.5.6 and 5.6.8; however, the CTS markup does not indicate which of these details are moved to these specifications. Comment: Revise the CTS markup to show which items remain in ITS 3.6.1 and uhich are incred to ITS 5 5.6 and 5.6.8. Provide additional discussions and justifications for these changes. See Comments 3.6.102 and 3.6.105.

l Comed Response to Inue.

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No change. As addressed in Section 5.0 DOC LA14, the reporting requirements of the containment structure are

- contained in ITS Specification 5.6.8, " Tendon Surveillance Report," which was adopted verbatim. This presentation conforms to the standard for ITS submittals. Corned continuca to pursue this change.

NRC RAI Number NRC Inued Date RAI Status 3.6.1-04 11/5/97 Open NRC Action Required NRC Description of Inue DOC A5.

CTS 4.6.1.1.c CTS 4.6. l.2.a. b, c, o, and g r

CTS 4.6.1.3.a. b, and d ITS SR 3.6.1.1 ITS SR 3.6.2.1 The above referenced CTS requirements are being changed to reflect the 10 CFR 50 Appendix J, Option B requirements as modified by TSTF 52. DOC A5 states this change applies only to CTS 4.6.1.1.c and 4.6.1.3; whereas, this change actually applies to all of the CTS requirements referenced. DOC A5 needs to be indicated on the CTS markup for every change to which it applies and should be revised to reference all affected CTS requirements. Comment: Revise the CTS markup and DOC A5 to address and justify all the administrative changes relative to adopting Option B.

. ComFd Response to louc No change, As addressed in Section 5.0 DOC LA24, CTS 4.6.1.2.a. b, c, d, and g and CTS 4.6.1.3.a. b, and d are placed in a program in the Administrative Controls Chapter (ITS Specification 5.5.16, " Containment Leakage Rate Testing Progrma"). Section 5.0 provides the markups andjustifications for these surveillances. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change.

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- RAI Status 3.6.l 05-11/5/97 Cpen-NRC Action Required v

NRC Description of lasue DOC A12 -

CTS 3 6.1.1 CTS 4.6.1.6.1 ITS SR 3.6.1.2 CTS 4.6.1.6.1 states " Containment vessel tendons' structural integrity shall be demonstrated.. " Corresponding ITS SR 3.6.1.2 states " Verify containment structural integrity in accordance with the Containment Tendon Surveillance Program " DOC A12 states the CTS requirement is technically equivalent to the ITS requirement; however, in the CTS markup, DOC A12 is associated with CTS 3.6.1.1 w hen it should be placed with CTS 4.6.1.6.1, w here the CTS requirement originates. Comment: Revise the submittal to address the administrative changes to CTS 4 6.1.6.1. See Comnient 3.6.l-03.

('amEd Response to issue 1 ~

DOC A12 designator was added to the top of the page for CTS LCO 3.6.1.6.

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NRC RAI Number NRC lssued Date RAI Status 3.6.1-06 II/5/97 Open - NRC Action Required NRC Description of Issue DOC A36 for ITS Section 5.0 CTS 1.7.d ITS SR 3.6.1.1 g

CTS 1.7.d (Containment Leakage Rates) is not accounted for in the CTS markup for ITS 3.6.1. DOC A36 for ITS Section 5.0 states that this is a cross reference to another CTS and therefore can be deleted, as an administrative change. Since the CTS referenced is CTS 3.61.2 which is addrused in the CTS markup ofITS SR 3.6.1.1, CTS 1.7.d is not deleted but retained as ITS SR 3.6.1.2. The change should not be addressed under ITS Section 5.0. but under ITS 3.6.1. Comment:

Revise the submittal to include a justification and discussion of this administrative change with the DOCS associated with ITS 3.6.1, Comed Response to Issue No change. CTS Specification 1.7.d states. " Containment Integrity shall exist when the containment leakage rates are within the limits of Specification 3.6.1.2.". In Section 3.6, the CTS markup for Specification 1.7.d illustrates that 1.7 d is addressed in Section 5.0. Similarly, CTS LCO 3.6.1.2 and CTS 4.6.1.1.c are both addressed in Section 5.0 for Specification 5.5.16, " Containment Leakage Rate Testing Program " as illustrated in the CTS atarkups for Section 3.6.

Section 5 0 DOC A36 deletes CTS Specification 1.7.d because it simply provided a reference to another technical

. specification. The Frequency for ITS SR 3.6.1.1 states, "In accordance with the Containment Leakage Rate Testing Program." This change is appropriately contained in Section 3.6 DOC A5 for the CTS markup of CTS 4.61.1.c, w hich' references the Contaimnent to kage Rate Testing Program. Section 3.6 DOC Al2 addresses ITS SR 3.6.1.2. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change.

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. NRC Issued Date RAI Status 311-07 11/5/97 Open - NRC Action Required NRC Description of Issue -

IX)Chil CTS 3.6.1.1 Actions CTS 3 6.1.2 Actions ITS 3,6,1 Actions CTS 3 6.1.2 Actions restrict reactor coolant heatup beyond 200 F if the containment leakage rates are outside established '

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limits Ilowever, no Actions are provided in CTS 3Al.2 if the reace coolant temperature is >200 F (htode 4) and the

.j containment leakage rates are outside established limits. In this c CTS 3.0.3 or CTS 3.6.1.1 Actions are to be entered since they are equivalent. - Because ITS 3 A1 Actions are the s' both CTS 3 A1.1 Actions and CTS 3.03, the l

. replacement of these CTS Action requirements by the Actio-

. 6 3.6.1 !s actually an administrative change rather than l

a more restrictive change. Comment: Revisc the submittal to 3ress this change in presentation of CTS action requirements as an administrathe change.

4 Comed Responw to Issue f

Section 3.6 DOC hil was deleted and en administrative ('A') DOC was added uhich states, ":*.'.TS 341.2 Actions restrict reactor coolant heatup beyond 200 'F if the containment Icakage rates are outside established limits. If the reactor coolant

,h temperature were > 200 'F (htode 4) with the containment leakage rates outside established limits, the actions of CTS LCO 3.03 would apply? With ITS SR 311.1 not met for containment leakage rate testing, the Required Actions ofITS LCO 3 Al 'would apply. Since these actions are comparable to CTS LCO 3.0.3. this change is considered administrative in f

nature. This change is consistent with NUREG 1431." ~

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NRC RAI Number NRC Inued Date RAI Status O;

3.6. l-08 11/5/97 Open-NRC Action Required NRC Description of luuc DOC LAIN DOC LA19 for ITS Section 5.0 Bases JFD B5 CTS 1.7.e Bases Background discussion for ITS 3.6.1 As part of the definition of Containment integrity (or what is required for an Operable containment) CTS 1.7.c requires Operable penetration scaling mechanisms This requirement is not accounted for in the CTS markup for ITS 3.6.1 Bases-,

rather it is addressed by DOC LAl9 for ITS Section 5.0 as being moved outside the ITS to the Containment Leakage Rate Testing Program (ITS 5.5.16). In addition, this condition for an Operable containment, w hich is contained in the Bases Background discussion for STS 3.6.1, is not adopted in the Bases for ITS 3.6.1. Bases JFD B5 justifies this omission by stating this condition is not applicable to the plant design. Ilouever, DOC LA19 for ITS Section 5.0 states that CTS 1.7.c is a detail with respect to contaimnent Operability that has to been moved outside the ITS to the Containment Leakage Rate

• 5 sting Program. Because this detail is a condition for containment Operability, it should be stated in the Bases Background discu a for ITS 3.6.1, as was donc with the balance of CTS L7, consistent with the STS. Comment:

Revise the submittal foi l's ? Section 3.6.1 uith an LA-t3pc justification for moving the containment operability condition of CTS 1.7.c to the Baus for iJS 3.6.1 consistent with the STS. Make appropriate changes to the CTS and STS marknps and DOC LAl9 for IT 4 Section : 1 See Comment 3.6.1-06.

Comed Response to em Section 31 DOC LAlh h o been revised to read, " CTS Defimtion 1.7 includes details with respect to Containment Integrity. Consistent with NUREG-1431, Definition 1.7 items a, b, c, and e are relocated to the Background section ofITS LCO 3.6.1 Bases. Item d is discussed in ITS Section 5.0. These details (CTS Definition 1.7 items a, b, c, and c) are (9

attributes of containment Operability. ITS LCO 3.6.1 requires containment to be OPERABLE. ITS 3.6.1 and the V

definition of Operability suffice. As such, these relocated details are not required to be included in the TS to provide adequate protection of the pubhc health and safety. Any change to the details relocated to the Bases will be made in accordance with the Bases Control Program described in ITS Section 5.5." Section 5.0 DOC LA 19 was deleted. The Background Section of the Bases for ITS LCO 3 6.1 was revised to include item d and reads, "The pressuriecd scaling mechanism associated with a penetration is OPERABLE."

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Response to NRC RAI D:ted 11/05/97 09-Dec-97 NRC RAI Number NRC Inmed Date RAI Status 3 4.1-09 11/5/97 Open Comed Action Required NRC Description of Issuc Bases JFD Cl CTS 4.6. l.l.c CTS 4.6.1.2 STS SR 3.6.1.1 113 SR 3.6.1.1 and associated Bases discussion CTS 4.6.1.1.c and 4.6.1.2 equire leak rate testing in accordance with R.G.1.163 and 10 CFR 50 Appendix J. Option B.

STS SR 3 61.1 requires the visual examination and leakage rate testing be performed in accordance with 10 CFR 50 l

Appendix J as modified by approved exernptions. ITS SR 1A 1.1 modifies STS SR 3.6.1.1 to conforms to CTS 4 A1.1.c and 4 A1.2, as modified in the CTS markup. The STS is based on Appendix J Option A while the CTS and ITS are based on Appendix J, Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr.

- Christopher 1. Grimes to Mr. David J, Modcen, NEl, dated 11/2/95, and TSTF $2. While the ITS SR 3.6.1.1 difTerences from STS SR 3 A 1.1 are in conformance with the letter or TSTF 52 as modified by stafTeomments, the change to the ITS Dases are not in conformance. Comment: Comed should revise the submittal, to conform to the 11/2/95 letter and to the i updated TSTF $2 once the Owners Groups provides resision. Otherwise, additionaljustification is required for the desiations.

Comed Response to luuc i

Comed has conformed to TSTF-52, Revision 0, which was drafted based on the 11/2/95 letter. Frior to issuance of the ITS SER, Comed will evaluate any NRC/ industry approved revisions to TSTF 52, and will incorporate applicable changes into the ITS submittal as appropriate.-

NRC RAI Number NRC Inued Date RAI Status 3 A l.10 11/5/97 Open - NRC Action Required NRC Description of luuc Bases JFD P1 Bases for STS SR 3 61.1

- Bases for ITS SR 3 61.1 The Bases for STS SR 3.61.1 states the following: " Failure to meet air lock land purge valve with resilient scall leakage limits.. causes that to exceed limits." The Bases for ITS SR 3.6,1,1 adopts different wording at the end of this sentence and reads as follows: "..causes the limits to be exceeded." Bases JFD PI bases this difference from the STS as a general reformatting /cditorial rewording for plant specific nomenclatmc. Ilowever, this change is not for clarity or for plant specific nomenclature, but uould be considered a generic editorial change to the STS. Comment: Revise the submittal to conform to the STS wording.

Comed Response to issue No change. The Surveillance Requirements Section of the Bases for ITS LCO 3Al states, " Failure to meet air lock and purge valve leakage limits specified in LCO 3.6.2 and LCO 3 A3 does not invalidate the acceptability of these overall' leakage deictminations unless their contribution to overall Type A, B, and C leakage causes (THAT to exceed limits]."

Comed believes that the use of the word "that" is not clear. Therefore, the sentence has been modified to read " Failure to f

meet air lock and purge valve leakage limits specified in LCO 3 A2 and LCO 3.6.3 does not invalidate the acceptability of

' these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes [the limits to be exceeded]." As Bases JFD PI states, certain wording preferences were adopted in order to enhance the understanding by plant operators and other users. Comed continues to pursue this change.

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Respons2 to NRC RAI Ihted i1/05/97 09 Dec-97

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NRC RAI Number NRC lasued Date RAI Status n

3.6.1 11-11/5/97

.Open-NRC Action Required NRC Dewription of Issue DOC /JFD - None CTS 4.6.1.2.c CTS 4.6.1.2.f ITS SR 3.6.2.1 ITS SR 3 6.3.6 and SR 3.6.3.7 CTS 3/4.6.l.2 has not been retained as a Lpalate LCO in the ITS. CTS 4.6.1.2.c states " Air locks shall be tested and i

demonstrated OPERABLE" This requirement is now ITS SR 3.6.2.1. CTS 4.6.2.1.f states that " Purge supply and exhaust isolation valves...shall be tested and demonstrated OPERABLE. " cr CTS requirements which are now ITS 3.6.3.6 and SR 3 6 3.7. Therefore, these CTS requirements are not relocated to ITS 5.5.16 as is shown on the CTS markup. Comment: Revise the submittal to show the CTS 4.6.1.2.c and 4.6.2.1.f are relocated to ITS 3.6.2 and 3.6.3 respectively and revise the CTS markeps for ITS 3.6.2 and 3.6.3 respectively to include these marked up pages. See item Numbers 3.6.2-4 and 3.6.3-4.

i Comed Response to issue No change. CTS 4.6.1.2 c states, " Air locks shall be tested and demonstrated OPERADLE by the requirements of_ -

Specincatine 4.6.1.3. CTS 4.6.1.3r b, and d delineate how the air lock shall be demonstrated OPER ABLE. The details of 9 hat con >otutes OPERABILITY are addressed in Specincation 5.5.16 as the CTS markup illustrates. Likewise, CTS 4.6.1.2.f(not 4.6.2.1.0 states, " Purge supply and exhaust isolation valves with resilient material seals shall be tested and demonstrated OPERABLE by the requirements of Specification 4.6.1.7.3 or 4.6.1.7.4." CTS 4.6.1.7.3 and CTS 4.6.1.7.4 delineate details of OPERAB:LITY. These details are relocated to the TRM as specified in LCO JFD LA16. Therefore, i

the CTS Markups for CTS 4.6.1.3 (ITS SR 3.6.2.1), CTS 4.6.1.7.3 (ITS SR 3.6.3.7), and CTS 4.6.1.7.4 (ITS SR 3.6.3.6) nre appropriate and correct. This presentation conforms to the standard for ITS submittal-Comed continues to pursue hs this change. -

NRC RAI Number NRC Issued Date RAI Status 3.6.2 01 11/5/97 Open - NRC Action Ricquired NRC Description of Inue DOC A5 CTS 4.6.1.3.a. b, and d ITS SR 3.6.2.1 Comment: See Comment 3.6.1-04 Comed Response to issue

._ No change. Co..Ed continues to pursue this change. (See Comed Response to RAI 3.6.104.)

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3.6.2 02 11/5/97 Open - NRC Action Required

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NRC Description of insac j

DOC A6 -

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FD P5 STS 3.6.2 Actions Note 3 4

ITS 3.6 2 Actions Note 3 STS 3.6.2 Actions Note 3 states: " Enter applicable Conditions and Required Actians of LCO 3.6.1<" Containment" when air lock leakage results in exceeding the overall containment leakage rate." ITS 3.6 2 ACTIONS Note 3 changes the word "w hen" to "if". JFD P5 bases this difference on achieving consistency with changes made to other sections. This justincation is inadequate and the staff considers this change to be a generic change to the STS. Comment: Revise t'.ic Note to adopt the STS wording.

Comed Response to Innue The Note was revised to adopt the STS wording.

NRC RAI Number NRC Issued Date RAI Status 3.6.2-03 11/5/97 Open - NRC Action Required NHL Description of lasue DOC All DOC L7 CTS 3 6.1.3 Action a 1 CTS 3.6.1.3 Action b q

ITS 3.6.2 Required Actions A.I and C.2 O

CTS 3 6.1.3. Actions a 1 and b require an air lock door to be maintained closed, with the time requirement in u hich to complete the action to be " maintain closed" is up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.6.2 Required Actions A.I and C.2 state that the air lock door is to be scrified closed within a one hour. The change to CTS 3.6.1.3 ACTION a.1 isjustified as L 7, Action b isjustilled as A.ll, Thejustificatic.n provided with A.II is "Not used." Also, these are more restrictive CTS changes (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to I hour), not administrative (A.ll) and less restrictive (L.7). Comment: Revise the submittal and provide additional discussion and justification for this more restrictive change.

Comed Response to issue Section 3.6 DOC AlI for CTS 3.6.1.3 Action b has been changed to DOC L7, consistent with CTS Action a.l. Comed maintains that this change is "less restrictive" in that the action to " maintain at least the OPERABLE /onc air lock door closed" can te interpreted to mean "immediately" take action, whereas in ITS 3.6.2 Required Action A.1 and C.2, this requirement is changed to " verify" and a I hout titue period is specified.

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Response to NRC RAI D:ted i1/05/97 09-Dec-97

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NRC RAI Number NRC issued Date RAI Status -

3.6.2-04 11/5/97 Open-NRC Actam Required NRC Description of Inue i

- DOC Ml ITS 3.6.2 Actions Note 3 CTS 3.6.1.2 Actions ITS 3.6.2 Actions CTS 4.6.1.2.c ITS SR 3 6.2.1 i

Because CTS 4.6.1.2 e corresponds to ITS SR 3.6.2.1 (See Conunent 3.6.1 11), CTS 3.6.1.2 Actions also apply to ITS 3 6.2. Conunent:. Revise the CTS markup for ITS 3.6.2 to include CTS 3.6.1.2 Actions. See Comments 3.6.1-7 and 3.6.1 11.

r Comed Response to Innue No change. CTS 4.6.l.2.c states, " Air locks shall be tested and demonstrated OPERABLE by the requirements of Specification l 6.l.3." CTS 4.6.1.3 (not CTS 3.6.1.2) states, "Each containment air lock shall be demonstrated OPERABLE.

CTS 4.6.1.3 corresponds to ITS SR 3.6.2,1 as illustrated in the CTS markup. This prescutation conforms to the standard for ITS submittals. Comed continues to pursue this change.

NRC RAI Number -

NRC lasued Date RAI Status 3.6.2-05 11/5/97 Open - NRC Action Required NRC Description of lasue DOC LA2 DOC Ll' g

DOC L2 CTS 3.6,1.3.a ITS 3.6.2 Actions Note i ITS 3.6.2 Action A Note 2 ITS 3.6.2 Action B Note 2 LTS 3.6.1.3.a states that the containment airlock doors are to be closed except when the air lock is being used for normal transit entry and exit, during which at least one door must remain closed This information according to DOC LA2 is relocated to the Bases. This is not entirely correct. The information with regards to using the air lock doors for normal entry and exit appears to be retained, with clarifications, in ITS 3.6.2 Actions Note 2, ITS 3.6.2 Action A Note 2 and ITS 3.6.2 Action B Note 2. Tims it should be considered as an extension of this requirement to the CTS 3.6.1.3 Actions.

Conunent: Revise CTS 3.6.1.3.a to relicct this Administrative change. Provide additional discussion andjustification for this ch:mge.

Comed Response to luue No change, There is a distinct difference between OPERABILITY requirements and Required Actions, including Notes in Required Actions. The statement in CTS 3.6.1.3.a which states, "Each centainment air lock.%ll be OPERABLE with both doors closed except when the air lock is being used for normal transit entry and exits through the containment, then at least one air lock door shall be closed," describes u hat constitutes containment air lock OPERABILITY. - As addressed in Section 3.6 DOC LA2, these details are being relocated to the Surveillance Requirements Section of the Bases for ITS LCO 3.6.2. Since Surveillance Requirements (SRs) are the mechanisms by which OPERABILITY, and therefore compliance with a specilication, is demonstrated, this change is appropriate. Correlating this information wita Actions would be inappropriate since Actions are only entered w hen an LCO/SR is not met. Comed continues to pursue this change.

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Response to NRC RAI Dated 11/05/97 09 pec 97 NRC RAI Number :

NRC Inued Date RAI Status 3.6.2-06 11/5/97 Open-NRC Action Required

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NRC Description of Inue j

DOC LAlH j

CTS 1.7.c ITS SR 3.6.2.1 ITS SR 3.6.2.2 I

CTS 1.7.c has been relocated to ITS B3.6.1 Bases-BACKGROUND perjustification LA.18. While it is acceptable to relocate CTS 1.7 to the Bases, CTS 1.7.c also refers to the requirements of CTS 3.6.l.3 which would translate to ITS SRs 3.6.2.1 and 3.6.2.2. Thus the markup of CTS 1.7 should also be included in the CTS markup for ITS 3.6.2. Comment:

Provide the appropriate markup of CTS 1.7 in the ITS 3.6.2 CTS markup. Provide additional discussion and justification for this administrative change.

Comed Response to Inue No change. CTS Specification 'l.7.c references CTS LCO 3.6.1.3, w hich by definition includes Surveillance Requirements. The CTS markup for 4.6.1.3 appropriately addresses ITS SR 3.6.2.1 as designated by Section 3.6 DOC A5 and DOC A6. This presentation conforms to the standard for ITS submittals. Comed continues to pursue this change.

1 NRC RAI Number NRC Inued Date RAI Status 3.6.2-07 11/5/97 Open NRC Action Required NRC Description of Inue DOC L2 CTS 3/4.6.l.3 Actions ITS 3.6.2 Action A Note 2 Dased on the discussion in Comment 3.6.2 5, the addition of a 7-day limit for entry and exit with one or more air locks having one air lock door inoperable could be considered as a more restrictive change. since the CTS would allow an indefinite period of time. Comment: Provide additiona' discussion andjustification for this more restrictive chan;,c. Sec Item Number 3.6.2-5.

Comed Response to Inue No changc. ' per CTS 3.6.1.3 Action a, with one air lock door inoperable, the operable air lock door must be maintained closed As addressed in Section 3.6 DOCS Li, L2, and L7, CTS 3.6.l.3 actions do not contain provisions for opening a door that is required to be closed to comply with the required actions. Comed continues to pursue this change.

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Respon:e to NRC RAI Dated 11/05/97 09 Dec-97 NRC RAI Number NRC Issued Date RAI Status

- 3.6.2 fat i1/5/97 Open - Comed Actica Requi cd NRC Description of Issue JFD Bases C.1 CTS 4.6.1.2.c CTS 4.6.1.3.a CTS 4 6.1.3.b CTS 4.6.1.3.d i

ITS SR 3.611 and associated Bases Comment: See Comment 3.6.1-09.

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Comed Response to issue Comed has conformed to TSTF 52, Revision 0, which was drafted based on the 11/2/95 letter. Prior to issuance of the ITS SER, Comed will evahmte any NRC/ industry approved revisions to TSTF-52. and will incorporate applicable changes

- into the ITS submittal as appsopriate,

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NRC RAI Number NRC lasued Date RAI Status 3.6.2-09 11/5/97 Open - NRC Action Required

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NRC Description of Issue Bases JFD C2 STS SR 3.6.2.2 and associated Bases ITS SR 3.6,2.2 and associated Bases STS SR 3.6.2.2 requires terifying only one door in the air lock will open at a time at six month inten als. The interval is

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modified in ITS SR 3.6.2.2 from 6 months to 24 months. This modification is in accordance with TS1F-17; however, the Bases changes are not in accordance with TSTF 17. Comment: Revise the ITS Bases to be in accordance with TSTF 17 orjustify the deviations.

Comed Response to issue Insert B 3.6-27C in the Suncillance Requirements Sxtion of the Bases for ITS LCO 3.6.2 has been modified to conform to TSTF 17, Revision I, and reads. ". used for entry and exit (procedures require strict adherence to single dooi openini;),

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

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Response to NRC RAI D:ted 11/05/97 09-Dec 97

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NRC RAI Number NRC lssued Date RAI Status

[)

3.6.2 10 11/5/97 Open - NRC Action Required a ~

NRC Description of Issue JFD Pl$

Bases discussion ofITS 3.6.2 Required Actions A.1, A.2 and A.3, B.1, D 2, and B.3, and C.1, C.2 and C.3 The listed Bases discussions difTer from the STS to clarify the actions to be taken for two inoperable air lock doors in the same air lock. The staff has reviewed the changes and finds that it reiterates information already included in the Bases and other sections of the ITS. In addition, the staff considers this change to be generic. This is not a justifiable plant-specific or editorial difference trom the STS. Comment: Revise the in Bases to delete the proposed clarification.

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

NRC RAI Number NRC issued Date RAI Status 3 6.3-01 11/5/97 Open. NRC Action Required NRC Description at issue DOC Al7 CTS 3.6.3 DOCIAl CTS 3 6.3 Table 3 611 JFD B6 ITS LCO 3.6.3 Note p

JFD C3 Q

STS LCO 3.6.3 Bases JFD C3 Bases discussion of LCO for ITS 3.6.3 Bases JFD PS ITS LCO 3.6.3 contains a note not contained in CTS 3.6.3 or STS LCO 3.6.3. This note exempts the feedwater isolation valves (FWlVs), the FWlV b pass valves, the feedwater preheater bypass valves and the feedwater tempering valves from 3

this specification. The justifications (DOC A3, JFD B6, and Bases JFD PS) state that the containment isolation function for these vahes is covered by ITS LCO 3.7.3 and JFD C3 and Bases JFD C3 state that this difference change is in accordance with TSTF-44 Rev.1. The staff has rejected TSTF 44 Rev. O and TSTF 44 Rev. I has not been submitted to the staff for review. The staff considers this change to ir a generic change that is beyond the scope of review for this conversion. Comments: Delete this generic change.

Comed Response tr, Issue i

F-44 has been withdraw n from the ITS submittal. Comed is deleting LCO 3.7.3, "FW lsolation Valves," from the ITS submittal and retaining the requirauents for feedwater valves in ITS LCO 3.6.3, " Containment Isolation Valves,"

consistent with Byron /Braidwood Current Licensing Basis.

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Response to NRC RAI D:ted 11/05/97 09-Dec-97 NRC RAI Number NRC Issued Date RAI Status O-3.6.3 02 11/5/97 Open - NRC Action Required s

NRC Description of issue DOC A18 ITS SR 3.6.3.3 DOC Li1 ITS SR 3.6.3.4 CTS 4.6.1.1.c ITS SR 3.6.3.8 CTS 4.6.3.2 CTS 4 6.1.1.a. CTS 4.6.3.2. and various other ITS 3.6.3 SRs, state the requirements to verify that valves are demonstrated Operable. The CTS requirements have been revised to only require these surveillances for valves that are not locked, scaled, or othenvise secured in position. This change reduces the number of valves subjected to these surveillance requirements In some cases this change is designated Administrative (DOC A18) and in others less restrictive (DOC L1i). The staficonsiders this change Less Restrictive in every case because this exempts previously tested valves from the surveillance. Comment Revise the submittal to treat all instances of this change as less restrictive and add additional justification and discussion as appropriate.

Comed Response to Ins.ne CTS SR 4.6.2.1.c.1, SR 4,6.2.2.c, and SR 4.6.3.2 have been revised to add the phrase, "that is not locked, scaled, or othenvise secured in position." The CTS markups for these SRs have been revised to designate them as 'iess restrictis c'.

Therefore, all 'A18' designators.. ave been replaced by 'LIl' designators, and Sectica 3.6 DOC Al8 was deleted. Section 3.6 DOC L1 I was resised to state, " CTS SR 4.6.1.1.a, SR 4.6.2.1.c.1), SR 4.6.2.2.c and SR 4.6.3.2 require periodic verification that the valves are in their correct position. ITS requires the same verification, but excludes valves that are locked, scaled, or othenvise secured in their correct position. This allows these valves, which are secured in their required C

position under administrative controls, to be exempted from the surveillance. These valves are secured in their accident

'A position and are not required to actuate to perform their safety function. Proper positioning of valves is administruively controlled by the Out of Senice Program in conjunction with the Locked Equipment and Caution Card Program. These programs ensure valves are maintained in their proper position by requiring independent verification of safety-related or other important equipment, documentation of the position oflocked equipment in a suacillance program, and periodic revicus of equipmcut normally required to be locked. Exempting these valves that are secured in their required position is perceived as the intent of the CTS wording, and therefore, the addition of the phrase more accurately reflects this intent."

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NRC RAI Number NRC Issued II.ite RAI Status 3.6.3-(0 11/5/97 Open - NRC Action Required NRC Description of Issue DOC A29 JFD P5 CTS 3.6.3 Acticas STS 3 6.3 Actions Notes and associated Bases ITS 3.6.3 Actions Notes and associated Bases.

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

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Response to NRC RAI Dated 11/05/97 09-nec-97 l

NRC RAI Nupiber NRC Issued Date RAI Status 3.6.3 04 11/5/97 Open - NRC Action Required NRC Description of lisue DOC MI ITS 3.6.3 Actions Note 4 CTS 3.6.1.2 Actions ITS SR 3.6.3.7 LTS4.6.1.2.f ITS SR 3.6.3.8 ITS 3.6.3 Actions Because CTS 4 6.1.2,f applies to ITS SR 3.6.3.7 and SR 3.6.3.8 (See Comment 3.6.1 11), CTS 3.6.1.2 Actions also apph to ITS 3.6.3. See Comment 3.6.17. Comments: Revise the CTS markup for ITS 3.6.3 to include CTS 3.6.1.2 Actions.

See Conunent 3 6.1-7 and 3.6.1 11.

Comed Response to issue No change, Comed continues to pursue this change. (See Comed Response to RAI 3.6.1 11.)

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l Response to NRC RAI Dated i1/05/97 09-occ-97 NRC RAI Number NRC Issued Date RAI Status O) -

3.6.3 05 11/5/97 Open NRC Action Required L

NRC Description of Issue DOC LA4 CTS 4.6.1.7.1 Bases JFD P7 STS SR 3.6 3.1 and associated Bases.

CTS 3.6.1.7.a ITS SR 3.1.3.1 and associated Bases CTS 3.6.1.7 and CTS 4.6.1.7.1 are specific in how the 48 inch purge valves are to be assured of not inadvertently opening; each purge vatte is required to have the power removed. STS/ITS SR 3.6.3.1 requucs thtt these valves be scaled closci The Bases for STS SR 3.6.3.1 states that a purge valve that is scaled closed must have motive power to the valve operator removed This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. The Bases for ITS SR 3.6.3.1 deletes the phrase " removing the air supply to the valve operator" and replaces it with " installing a mechanical block." Bases JFD P7 justitics this change on plant specific design, analysis, and terminology details. Since the CTS only talks about power mmoval, not installation of mechanical block, this justification is insullicient. Finally, the justifications given by DOC LA4 and Bases JFD P7 do not specify whether the staff has

- approved using mechanical blocks as an alternative to power removal. Comment: Delete the ITS Bases change and 4

conform to the CTS or STS, or provide additional discussion and justification to show that using mechanical blocks has been appioved by the sta" Comed Restu ase tu luue No ch:mge. The option ofinstalhng a mechanical block as a means of removing motive power to the valve operator of a containment purge valve that is scaled closed is discussed in the Byron /Braidwood UFSAR Section 6.2.4, " Containment

,O Isolation System," and states, "The normal containment purge valves are locked closed by the admimstrative procedure of V

interrupting power to the valve at the circuit breaker (i c., the circuit breaker is racked out) and tagging the breaker "out of service" (OOS). Inadvertent operation of the purge valves requires violation of procedures prohibiting both the operation of tagged-out equipment and the containment purge system. Tagging out at the breaker is considered equivalent to a mechanical lock because in both instances positive action is used to present the valve from receiving power and an administrative procedure is required to return the breaker to service. At Braidwood, valves VQ001 A/B and VQ002 A/B may have exterior mechanical stops mounted to the valve. These valve stops may be used as an additional method of locking the valves closed." In addition, the Bases for CTS Specification 3/4.6.1.7 states, "To provide assurance that the 48-inch containment valves canact be inadvertently opened, the vaives are scaled closed in accordance with Standard Review Plan 6.2.4 w hich includes mechanical devices to seat or lock the valve closed, or prevents power from being supphed to the valve operator." This page of the Bases is an original page of CTS approved by the Staff w hen issuing the Byron and Braidwood operating licenses. Comed continues to pursue this change.

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Response to NRC RAI Dsted 11/05/97 09-Dec-97 NRC RAI Number NRC issued Date RAI Status 3.6.3-06 11/5/97 Open - NRC Action Required v

NRC Description of issue DOC LA18 ITS SR 3.6.3.1 CTS 1.7.a ITS SR 3.6.3.2 CTS 3.6.1.1.a ITS SR 3.6.3.3 CTS 3.6.1.7

TS SR 3 6.3.4 CTS 4.6.1.7.1 CTS 4.6.1.7.2 CTS 1.7.a has been moved to Bases Background discussion ofITS 3.6.1 according to DOC LA18. While it is acceptab!c to reloca.tc CTS 1.7 to the Bases, CTS 1.7.a also refers to the requirements of CTS 3.6.1.1.a. CTS 3.6.1.7, CTS 4.6.1.7.1 and CTS 4.6.1.7.2 which translates to ITS SR 3.6.3.1, SR 3.6.3.2, SR 3.6.3.3, and SR 3.6.3.4. Thus the markup of CTS 1.7 should also be included in the CTS markup of ITS 3.6.3. Comment

Provide the appropriate markup of CTS 1.7 in the ITS 3.6.3 CTS markup. Provide additional discussion and justification for this administrative change.

Comed Response to issue No change. This presentation conforms to the standard for ITS submittals. (Sec Comed Response to RAls 3.6.1-06 and 3 6.2-06 )

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Response to NRC RAI D:ted 11/05/97 09-Dec-97 NRC RAI Number

' NRC lssued Date RAI Status

-3.6.3-07 11/5/97 Opc i NRC Action Required V

NRC Description of issue DOC L12 STS SR 313,5 and associated Bases JFD C6 ITS SR 3.6.3.5 and associated Bases Bases JFD C6 Bases discussion of LCO for ITS 3.6.3 CTS 4 6.3.3 CTS 413.3 requires the isolation time of each power operated or automatic containment isolation valve be determined to be within limits. STS SR 313.5 states basically the same thing but the "or" is changed to "and" STS SR 313.5 has been modified by TSTF 46 Rev. I which clarifics that the SR only applies to automatic power operated valves. ITS SR 343.5 and the Bases discussions of LCO for ITS 3.6.3 and ITS SR 343.5 have been modified to reficct TSTF 46 Rey,0, as justified by DOC L12. Since TSTF 45 Rev, O was modified by the staff and resut mitted and approved as TSTF 46 Rev.

I, the changes proposed in the ITS differ from the STS, as revised. Comment: Change the CTS markup, ITS SR markup and ITS Bases markup to conform to the approved TSTF 46 Rey, I or provide additional discussion and justification for the devicious.

Comed Respimse to Issue TSTF-46, Revision 0, has been withdrawn from the ITS submittal. Comed, however, continues to pursue this change on a plant specific basis for the following reasons. The references to " manual," " remote-manual," " power-operated,"

" check," aad " automatic" is not consistent within the STS. Byron /Braidwood plant specific terminology distinguishes between the classification of valves dssignated as " power operated" and " automatic." Automatic valves refer to those vahes that require a motive force to actuate, such as air or electric, and receive an automatic actuation signal. Automatic

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air operated valves and automatic clectric operated valves fall into this category. Power operated valves, on the other

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hand, require a motive force to actuate, such as air or cicctric, but do not reccise an automatic actuation signal. Air power operated valves and electric power operated valves fall into this category. Adopting the change to SR 3.6.3.5 in TSTF-46, Revision I, which states " Verify the isolation time of each automatic power operated containment isolation valve is within limits" would inappropriately include powcr operated containment isolation valves (i.e., valves that do not receive a containment isolation signal), which is not the intent. Therefore, deleting reference to power operated isolation valve time testing reduces the potential for misinterpreting the requirements of this SR while maintaining the assumptions of the accident analysis, and is consistent with plant specific terminology.

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Response to NRC RAI dated i1/05/97 -

09-Dec-97 4

NRC RAI Number NRC Issued Date RAI Status 23.63 11/5/97 Open - NRC Action Required 1 NRC Description of luue JFD B3 Bases JFD B3 Bases JFD P13 ~

. STS 3.6.3 Action E STS SR 3.6 3.1 and associated Bases discussions ITS 3 6 3 Action D ITS SR 3 63.1 and associated Bases discussions STS 3.63 RA E 1, E.2 and E3 have been revised in ITS 3.63 ACTION D to delete the option ofisolating a penetration flow path with a purge valve not within the leakage limits and associated ras. The only option is the current licensing -

basis of restoring the valve to OPERABLE status in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or begin an orderly plant shutdown.' Also, the STS SR-J3.63 i exception for opening one purge valves while in Condition F is deleted. Justincation BJ, Bases BJ and Bases P.13 state this exception is already accommodated in Condition A Lcquired Actions. This is not understood because if a

. purge valve is leaking, then Condition A cannot be entered. Thejustification must be further explained. Comment:

Provide additional discussion smd justification for this CTS change.

Comed Response to luue

" Condition A" has been changed to " Condition D"in Section 3.6 LCO JFD B3 and Bases JFD B3. The JFDs have been revised to state, "This exception is adequately addressed by Cor.dition D Required Actions, without the necessity for the complexity introduced by this exception." The exception in SR 3.63.1 is unnecessary since SRs do not have to bc

- perfont.ed on inoperable equipment or components, i.e., when Condition D is entered.

NRC RAI Number NRC issued Date RAI Status

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.- 3.6.3-09 11/5/97 Open - NRC Action Required NRC Description of Issue JFD-Pil l-Bases JFD P20 Bases P22 Bases P24 STS 3.6.3 Required Action A.2 Completion Time STS bR 3.63.4 and associated Bases iTS 3.63 Required ' Action A.2 Completion Time ITS SR 3.63 4 and associated Bases STS 3.63 Required Action A.2 Completion Time and STS SR 3.6 3.4 Frequency state the following: " Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days " ITS 3.63 Required Action A.2 Completion Time l

and ITS SR 3.63.4 Frequency, add the word "once" to the Completion Time and Frequency to change the STS wording -

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

Comed Response to issue Per Comed response to RAI 3.191, Comed submitted a traveler at the November 1997 Westinghouse Owner's Group'-

(WOG) ITS meeting. The StaP'. comment in RAI 3.1-01 for SR 3.1.6.1 was that this change was a legitimate use of the word "once" in an SR Frequency. A Tmal. disposition of the traveler is to be determined at the February 1998 WOG ITS meeting.

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l Response to NRC RAI D$ted 11/05/97 c9-Dec-97 NRC RAI Number NRC issued Date RAI Status 3.6.3 10 11/5/97 Open NRC Action Required NRC Description of issue Bases JFD C4 Bases for STS 3.6.3 Bases for ITS 3.6.3 STS 3.6.3 Required Action C.1 Completion Time has been modified by TSTF-30 Rev. 2 While ITS 3.6.3 Required Action C.1 Completion Time incorporate = TSTF 30 Rev. 2 changes, the Bases for ITS 3.6.3 does not fully incorporate all of the STS Bases changes associated with TSTF-30 Rev. 2. Comment: Revise the Bases for ITS 3.63 ? % corporate the Bases changes associated with TSTF-30 Rev. 2 or provide additional discussion a..d justification for the acviations.

Comed Response to Issue Baws JFD C4 designator was added to ITS SR 3.6.3.6 for "(Ref. 5)" in the Surveillance Requirements Section of the Bases for ITS LCO 3.6 3. In addnion, Bases JFD C4 was revised to read "This change is consistent with NUREG-i431, as modified by TSTF-30, Revision 2."

NRC RAI Number NhC Issued Date RAI Status 3.6.3 11 11/5/97 Open NRC Action Rcquired NRC Description of issue Bases CD C5 Bases for STS SR 3.6.3.3 and SR 3.6.3.4 Bases for ITS SR 3.6.3.3 and SR 3.6.3.4 STS SR 3.6.3.3 and SR 3.63.4 have been modified by TSTF 45 Rev.1. While ITS SR 3.6.3.3 and SR 3.6.3.4 have incorporated the changes associated with 'ISTF 45 Rev. I, tbc Bases for STS SR 3.6.3.3 and SR 3.6.3.4 do not fully d

incorporate all of the Bases changes associated with TSTF 45 Rev.1. Comment: Revise the Bases for STS SR 3.6.3.3 and SR 3.6.3.4 to incorporate the Bases changes associated with TSTF 45 Rev. I or provide additional discussion and justification for the desiations Comed Response to Inue TSTF-45, Resision 1, added an Insert in the Surveillance Requirements Section of the Bases for ITS LCO 3.6.3 sta'ing, "This SR does not apply to valves that are locked, scaled, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, scaling, or securing " TSTF-45, Revision i, was incorporated by adding the insert to the Bases for ER 3,0.3.3 and SR 3.6.3.4.

U 23

I Response to NRC RAI D:teb1/05/97 09-Dec-97 NRC RAI Number NRC Issued Date RAI Status O

3.6.3 12 11/5/97 Open-NRC Action Required V

NRC Description of issue Bases JFD P8 Bases discussion of LCO for STS 3.6.3 Bases discussion of LCO for ITS 3.6.3 The third paragraph of the Bases discussion of LCO for STS 3.6.3 states "The normally closed isolation valves... are those listed in Reference 1." This paragraph deals with those containment isolatior, valves that are required to be closed during an accident and are ii. the closed position during normal operation.. This paragraph is omitted from the Bases discussion of LCO for ITS 3.6.3 and the STS Bases markup indicates this omission isjustified by Bases JFD P8 which does not address this subject. Bases JFD P8 also states there is no requirement for an isolation valve's Operability to be tied to the integrity of a closed system. This is incorrect.10 CFR 50 Appendix A GDC 55 through 57, and the definiti<m of Containment Integrity (CTS 1.7.a) tic the Operability ofisolation valves to the integrity of i closed system. Therefore, the STS wording is correct and should be retained. In addition, the staff finds this change to be generic and beyond the scope of review for this conversion. Comment: Delete this gencric change.

Comed Response to issue No change. The LCO Section of the Bases for STS LCO 3.6.3 states, "The normally closed isolation valves are considered OPERABLE w hen manual s alves are closed, automatic valves are de-activated and sec';ted in their closed position, blind flanges arc in place, and closed sy stems are intact. These passive isolation valves / devices are those listed in Reference 1."

This paragraph was deleted by Bases JFD P8 since there is no requirement in ITS for a normahy closed automatic valve to be de-activated and secured in its closed position. Implementing this requirement, would in fact, rend;r the Emergency Core Cooling System inoperabic. Additionally,10 CFR 50 Appendix A GDC 55-57 require that cach line that.. shall be provided with containment isolation valvc(s).

The convere is not truc - There is no requirement tying an isolation valve's operability to the integrity of a closed system. Furthermore, CTS Defm' ition 1.7.a specifics operability O

requirements for containment INTEGRITY, not containment isolation valves (CIVs). ITS LCO 3.6.3 which addresses the d

operabihty of CIVs does not specify any requirements for the integrity of closed systems. Comed continues to pursue this change.

NRC RAI Number NRC Inued Date RAI Status 3.6.3 13 11/5/97 Open - NRC Action Required NRC Description of issue Bases JFD Pl2 Bases discussion of Applicable Safety Analyses for STS 3.6.3 Bases discussion of Applicable Safety Analyses for n S 3.6.3 The Bases for ITS 3.6.3 does nca adopt the last sentence of the first paragraph of the Bases discussion of Applicable Safety Analyses for STS 3 6.3. This sentence statt ;"Therefore, the safety analyses of any event requiring isolation of containment is applicable to this LCO." Bases JFD P12 bases this omission on the the fact that ITS 3.6.3 Applicability is limited to Modes I,2,3, and 4, and that ITS 3.9.4 addresses containment isolation requirements outside these modes.

(Note, this is cicarly stated in the Bases discussion of Applicabihty.) The omitted sentence appears to assume that the analyses referenced are only apnlicable during Modes I,2, 3, or 4 in the ITS which may not be true. The staff considers this omission to be a generic difference from the STS and outside the scope of an ITS conversion. Comment: Revise the submittal to adopt the omitted sentence.

Comed Response to inne The omitted sentence was adopted in the Background Section of the Bases for ITS LCO 3.6.3, and Bases JFD P12 was deleted

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Response to NRC RAI Dated 11/05/97 09-Dec-97 NRC RAI Nt.mber NRC issued Date RAI Status 3.6.3 14 11/5/97 Open - Comed Action Required NRC Description of Inue Bases JFD P20 Bases JFD P24 Bases for STS 3.6.3 Required Action B.1 Bases for ITS 3.6.3 Required Action B.i The Bases for ITS 3.6.3 Required Action B.1 differs from the STS as discussed in Bases JFDs P20 and P24. These modifications incorporate portions of TSTF-145, as well as other changes The staff has accepted TSTF-145 Rev. I as modified by staff conunents. Comment: Revise the Bases to adopt STS Bases changes of TSTF 145 Rev. I as supplemented by staff comments or provide additional discussion and justification for deviations.

Comed Response to Issue Subsequent to the NRC Staff approving TSTF-145, Revision I, the industry withdrew the traveler at the 10/1/97 NRC/TSTF meeting. NUREG LCO 343 Condition A, for one containment isolation valve inoperable, requires s crification that the affected penetration flow path is isolated once per 31 days for isolation devices outside containment and prior to entering MODE 4 from MODE 5 if not performed witilin the previous 92 days for isolation devices inside containment. The traveler proposed adding this requirement to Condition B for two containment isolation valves inoperabic. This is an inappropriate change since whenever Condition B is entered for two valves inoperable, Condition A will always be entered for one valve inoperable. Duplicating requirements in Conditions is not consistent with NUREG philosophy. Comed did not adopt TSTF-145, Revision 1, and continues to pursue the Bases changes plant specifically.

NRC RAI Number NRC lssued Date RAI Status 3 6.6-01 11/5/97 Open - NRC Action Required NRC Description of issue DOC A18 DOC Lil CTS 4 6.2.1.c. I ITS SR 16 6.5 Comment: See Comment 3 6.3-02 Comed Response to issue CTS SR 4 6.2.1.c 1, SR 4.6 2.2.c, and SR 4.6 3.2 have been revised to add the phrase, "that is not locked, scaled, or otherwise secured in position " The CTS markups for these SRs have been revised to designate them as 'lcss restrictive'.

Therefore, all' AIM' designators have been replaced by 'L1l' designators. end Section 3.6 DOC AIM was deleted.

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j Response to NRC RAI Dated 11/05/97 09-Dec-97 NRC RAI Number NRC lssued Date RAI Status O

3.6 6-02 11/5/97 Open - NRC Action Required V

NRC Description of Issue

- DOC LA7 CTS 4.6.2.1.b Bases for ITS SR 3.6.6.4 The markup of CTS 4.6.21.3 shows that the system alignmcut ("that on recirculation flow") for the containmet spray pump test has been removed from CTS. DOC LA7 states tha' this system alignment detail is relocated to the TRM.

Ilowever, the Bases for ITS SR 3.6.6.4 describes the system alignment as "They (punipsl are tested on recirculation flow."

Comment: Revisc DOC LA7 to show that the test flow path has also bece relocated to the Bases for ITS SR 3.6.6.4.

Comed Response to issue Section 3.6 DOC LA7 has been revised to read, " CTS SR 4.6.2.1.b details the required developed bead for the containment spray pump and test flow path during performance of the Surveillance. These details are to be relocated to the Bases.

These details are not necessary to ensure the Operability of the containment spray pumps The requirements ofITS LCO 3 6 6, " Containment Spray and Coohng Systems," and assochted SRs are adequate to enst.-e the containment spray pumps are Operable. As such, these details are not required to be in the TS to provide adequate protection of the public health and safety. Relocating these details to the Bases maintains the consistency with NUREG-1431. Any change to these details will be made in accordance with the Bases Control Prog.am described in ITS Section 5.5.

NRC RAI Number NRC Issued Date RAI Status 3 6.6-03 11/5/97 Open NRC Action Required N RC Description of issue DOC LM o

CTS 3.6.2.3 Actions JFD P3 STS 16 6 Actions A and C and associated Bases Bases JFD P3 ITS 3 6.6 Actions A and C and associated Bases CTS 3.6.2.1 Action Consistent with CTS, ITS 3.6.6 Required Actions A.1 and C.1 specify a 7-day Completion Time, instead of the 72-hour Compiction Time of the STS, in the event of one inoperable containment spray train or onc or more inoperabic containment cooling trains, respectively. The ITS also speedies a 14-day Completion Time measured from discovery of failure to meet the LCO. instead of the 14-day Completion Time of the STS. While the Completion Time change from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days is acceptable based on current licensing basis, the change from 10 to 14 days is unacceptabic. The justifications provided (L.8, P.3 and Bases P.3) are inadequate, and are not based on current licensing basis Thus, the staff considers the change to be a generic change that is beyond the scope of review for this comersion. Comment-Delete this generic change.

Comed Response in lasue No change. ITS LCO 3.6.6 requires that with one containment spray (CS) train inoperable or with one or more containment cooling trains inoperable, restore CS train to operable status in 7 days AND 14 days from discovery os railure to meet the LCO. ITS LCO 3 K.1 requires that with one or more buses with one required qualified circuit inoperable, restore required qualified circuit (s) to operable status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AND 6 days from discovery of failure to meet the LCO.

The purpose of the second Completion Time (i.e.,. days from discovery...) is to prevent alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. In the case of CS and Containment Cooling, Comed has conformed to the NUREG philosophy of allowing alternating only once betwccn a CS train inoperability (7 day Required Action) and one or more Containment Cooling train inopc abilitics (7 day Required Action) This results in a 14 day Comp 1ction Time, rather than the STS 10 day Completion Time. Comed Q

beheves that this change isjustifiable based on NUREG philosophy and continues to pursue this change.

26

Response to NRC RAI Dated 11/05/97 09-occ-97 r--

NRC RAI Number NRC Issued Date RAI Status O

3 6.7-01 11/5/97 Open NRC Action Required NRC Description of issue DOC A18 DOC L11 CTS 4.6.2.2,c ITS SR 3.6.7.4 Comment: See Comment 3.6.3-02 Comed Response to issue CTS SR 4.6.2.1.c.!, SR 4.6.2.2.c, and SR 4.6.3.2 have been revised to add the phrase, "that is not locked, scaled, or otherwise secured in position." The CTS markups for these SRs have been revised to designate them as '1 css restrictive'.

Therefore, all 'A18' designators have been replaced by 'L1l' designators, and Section 3.6 DOC AIS was deleted.

(Correction Note: This RAI was labeled 3.7.7-01 instead of 3.6.7-01.)

NRC RAI Number NRC Issued Date RAI Status 3.6.7-02 11/5/97 Open - NRC Action Required NRC Description of Issue Bases JFD P7 Bases Background discussion for STS 3.6.7 Bases Background discussion for ITS 3.6.7 Bases for ITS SR 3.6.7.5 The last sentence of the third paragraph in the Bases Background discussion for STS 3.6.7 states "The eductors are designed to ensure that the ph of the spray mixture is between 8.5 and i1.0." The Bases Background discussion for ITS

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3.6.7 omits this sentence. Bases JFD P7 provides no technical basis for this change. Note that the Bases for ITS SR 3.6 7.5 basically makes the same statement, but without the limits. The omitted Background statement is neces ary to describe the design characteristics of the spray additive system and thus is required. Comment: Revise the submittal to adopt the STS wording with the STS pH limits of 8.5 and i1.0 or specify the plant specific limits. Provide additional discussion andjusti0 cation as necessary.

Comed Response to issue The omitted sentence in the Background Section of the Bases for ITS 1.CO 3.6.7 was adopted with plant specine pH values and reads. "The eductors are designed to ensure that the pH of the spray mixture is between 8.5 and 12.8." (Correction Note: This RAI was labeled 3.7.7-02 instead of 3.6.7-02.)

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i Respons: to NRC RAI D terl 11/05/97 09-Dec-97 NRC RAI Numhcr NRC issued Date RAI Status

[]

3.6.8-01 11/5/97 Open - NRC Action Required NRC Description of luue DO A14 ITS SR 3.6.8.1 and associated Bases CTS 4.6.4.2.a ITS SR 3.6.8.2 and associated Bases CTS 4.6 4.2.b ITS SR 3.6.8.3 and associated Basa s CTS 4 6 4.2.a and b specifies surveillance requirements for hydrogen recombiner testing pertaining to (1) rate of heater sheath temperature increase and power consumption; (2) channel calibration ofinstrumentation and controls; (3) attributes of a visual examination; and (4) required heater phase resistance. According to DOC LA14. details of these four sum:illanc requirements have been moved to either the Bases or the TRM. Items 1, 3, and 4 have been relocated to the Bases. In addition, procedural details for determining power consumption (item 1) are moved to the TRM. DOC LAl4 does not justify placing this requirement in the TRM, as opposed to the Bases. In addition, the channel calibration requ;.cment, item 2, cannot be found in the Bases for ITS 3.6.8, as specified in DOC LA14. Comment: Revise the Bases for ITS 3.6.8 to inchide the channel calibration details, as specified in the CTS 4.6.4.2.b.I and DOC LA14. Provide additional discussion and justification for moving the channel calibration power consumption procedural details.

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

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the TRM These details are not necessary to ensure the Operability of the Hydrogen Recombiner Systems. The

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requirements of ITS LCO 3.6.8, liydrogen Recombiners," and associated SRs are adequate to ensure the Hydrogta Recombinct Systems are Operable. As such, these details are not required to be in the TS to provide adequate protection of the public health and safety. The relocation of these details maintains the consistency with NUREG-1431. Any change to these details in the Bases will be made in accordance with the Bases Control Program described in ITS Section 5.5.

Any change to these details in the TRM will be made in accordance with 10 CFR 50.59."

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Response to NRC RAI D ted 11/05/97 09-Dec-97 NRC RAI Number NRC Issued Date RAI Status

[)

3.6.8-02 11/5/97 Open - NRC Action Required x

NRC Description of Issue DOC L9 JFD D1 Bases JFD Bl Bases JFD B2 Bases JFD P7 CTS 3 6.4.2 Action ITS 3.6.8 Action B Bases for ITS 3.6.8 Required Actiona B.1, B.2, and C.1 CTS 3.6.4.2 Actions do not address the condition in which both hydrogen recombiners are inoperable. Thus, CTS would require a plant shutdown in accordance with CTS 3.0.3. ITS 3.6.8 Action B allows 7 days of operation in this condition, provided the hydrogen control function is maintained. The justification given in DOC L9 for this relaxation is unacceptable because there is no evidence that tac four alternate hydrogen cont.ol functions, listed in the proposed Bases for ITS 3.6.8 Actions, have been previously accepted by the staff. In addition, how does one perform a surveillance on natural convectica to verify that it is Operable as au r.! ternate hydrogen control function. Also, containment spray does not reduce or facilitate hydrogen gas concentration. If Comed cannot reference documentation showing that the NRC staft' accepted these alternate hydrogen control functions, then ITS 3.6.8 Action B cannot be used. Therefore, the CTS requirement for an LCO 3.0.3 shutdown should be retained. Comment: Provide additional discussion and justification for this less restrictive change. See Comment 3.6-02.

Comed Response to issue The fact that the Contaimnent Spray System and the Reactor Containment Fan Coolers (RCFCs) provide an alternate hydrogen control function is discussed in the B3 ron/Braidwood UFSAR Section 6.2.5.2.3, " Hydrogen Mixing Sy stem D'esign," and states, "The function of the mixing subsystem is to ensure that local concentrations with greater than 4%

hydrogen cannot occur within the primary containment following a LOCA. The mixing is achieved by natural comcction v

processes, containment fan cooler operation, and the containment spray system. Natural convection occurs as a result of the temperature dtIference between the bulk gas space in the vessel and the containment wall. The natural convection action is enhanced by the momentum of steam emitted from the point of the break. The operation of the containment spray system following the accident will result in the creation of an extremely turbulent atmosphere within the contaimnent, as demonstrated in the Zion Station ull-flow containment spray system test. The containment spray system r

is discussed in Subsection 6.5.2. Mixing of the containment atmosphere to assure that there will be no " pocketing" of large hydrogen concentrations will be accomplished by the reactor containment fan coolers (RCFC), an engineered safety feature described in Subsection 6.2.2. The operation of the recombiner system is not dependent on the operation of any engineered safety features other than the reactor containment fan coolers. Four coolers (two required for both normal and postaccident conditions) each supphing 94.000 cfm (normal operation) or 59,000 cfm (postaccident operation) are provided for each containment. The RCFC fans discharge this air thmugh concrete ducts to the lower elevation " For completeness, the Background Section of the Bases for ITS LCO 3.6.6, Containment Spray and Cooling Systems," was revised to add the sentence, "In addition. the Containment Spray System and Containment Cooling System provide an alternate hydrogen control function to the hydrogen recombiners during post-LOCA conditions." The fact that the Post-LOCA Purge System provides an alternate hydrogen control function is discussed in the Byron /Braidwood UFSAR Section 9.4.9.3.1.a 1, " Post-LOCA Purge System Safety Design Bases," and states "The post-LOCA purge system is a non-saf,ty-related system (per Branch Technical Position CSB 6-2) w hich is prosided as a backup to the bydrogen recombiners to purge the containment of h drogen to maintain the hydrogen concentration below 4% by volume." Comed continues to 3

pursue this change.

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Response to NRC RAI D:ted 11/05/97 09-nec-97 NRC RAI Number NRC lssued Date RAI Status

[7,}

3.6.8-03 11/5/97 Open - NRC Action Required

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NRC Description of Inue Bases JFD P7 Bases Backgound discussion ofITS 3.6.8 in the Baws Background discussion of ITS 3 6.8, the third paragraph states timt two 100% capacity independent hydrogen recombiners are shared between the units; however, Bases JFD P7 does not explain how ITS LCO 3.6.8 affects cach unit's operation. If these hydrogen recombiners are in use for one Unit or inoperable, what is the operational status of the second Unit? Is it shutdown? The ITS APPLICABILITY, ACTIONS and/or Bases should explain this restriction. If not, an explanation of how ITS 3.6.8 OPERABILITY requirements for the unaffected Unit are met when the recombiners are dedicated to the affected unit or are inoperabic. Comment: Revise the submittal and provide the additional discussion and Justification for this plant specific design.

CumEd Response to luue For Byron and Braidwood, the design basis does nq postulate accidents on both units concurrently, but rather an accident on one unit and safe :;hutdown of the other umt. Therefore, the need for the hydrogen recombmers on the non-accident unit is not postulated in the design basis. However, if a recombiner ucre in use oa one unit, it would still be capable of being manually realigned to the other unit. The Bases for the Byron and Braidwood Current Technical Specifications (CTS) 3/4.6.4, " Combustible Gas Control," states, "The OPERABILITY of the equipment and systems required for the detection and control of hydrogen gas ensures that this eqmpment will be available to maintain the hydrogen concentration within containment below its Gammable limit during post-LOCA conditions. EITHER RECOMBINER UNIT (or the Purge Syacm) is capable of controlling the espected hydrogen pencration associated with: (1) zirconium-water reactions, (2) radiolytic daomposition of water, and (3) corrosion of metals within containment. These 11 d., gen Control Systems 3

are consistent with the recommendations of Regulatory Guide 1.7, " Control of Combustible Gas Concentrations in Containment Following a LOCA," March 1971. The Hydrogen Mixing Systems are provided to ensure adequate mixing h) of the containment atmosphere following a LOCA. Tnis mixing action will prevent locali/ed accumulations of hydrogen kJ fmm exceeding the Hammable limit." Comed believes that this change isjustifiable and continues to pursue this change.

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