ML20213D636

Provides Bases for Belief That Facility Substantially Designed,Constructed & Preoperationally Tested Consistent W/ Fsar,Ser,Addl Licensing Documents & Commission Regulations. Listing of Status of Tech Spec Changes as of 861028 Encl

ML20213D636
Person / Time
Site:	Byron
Issue date:	11/05/1986
From:	Reed C COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
2319K, NUDOCS 8611120167
Download: ML20213D636 (5)

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- one Fwst Nabonal Plaza, Checa00, Illinois

, Address Reply to: Post Omco Box 767 s Chica0o, Illinois 60600 - 0767 November 5, 1986 Mr. Harold R. Denton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC. 20555

Subject:

Byron Station Unit 2 Satisfaction of Licensing Requirements and certification of Technical Specifications NRC Docket No. 50-455

References:

(a) May 11, 1983 letter from C. Reed to H.R. Denton (b) April 8, 1982 letter from T. Tramm to H.P.. Denton  ;

(c) August 27, 1985 letter from B. Youngblood to D. Farrar (d) October 23, 1984 letter from C. Reed to H.R. Denton (e) February 12, 1985 letter from C. Reed to H.R. Denton

Dear Mr. Denton:

This letter provides the bases for Conunonwealth Edison Company's

(" Edison") belief that Byron Station Unit 2 (" Byron") has been substantially designed, constructed and pre-operationally tested in conformity with the Final Safety Analysis Report ("FSAR"), other licensing-related documents, the

, Safety Evaluation Report ("SER"), and the rules and regulations of the ,

Connaission. Inherent in this statement is the acknowledgment of the normal update process which translates current documents for design, construction and other activities into submittals to the NRC, e.g. FSAR descriptions. The FSAR will be updated to reflect any changes to the plant as required by Reference (c) and 10 CFR 50.71(e).

Edison has considerable experience in nuclear power plant design, construction and operation. Similarly, Byron's architect-engineer Sargent &

Lundy, and Byron's nuclear steam supplier, Westinghouse, have considerable experience in nuclear power plant design and construction. These three entities employ extensive design control procedures and practices, many of which have been previously described in detail for Byron. (See Reference (a)). Also documented in detail in Reference (a) are the contributory roles of quality assurance audits and independent engineering reviews in the verification of the design, construction and installation activities. This combination of experience and design control practices and reviews supports Edison's belief that Byron Unit 2 has met the requirements to receive a license.

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Byron Unit 2 is now substantially completed. As with all new plants, certain activities which can be deferred in accordance with the Commission's regulations, including a small number of the pre-operational tests, have been identified to the NRC staff. All uncompleted items, including the deferrable construction deficiencies which have been identified to you by Region III and which have been detenmined not to need schedular relief, are being tracked by the station. Where appropriate, items are evaluated for their impacts on operation. This evaluation includes a review by a Senior Reactor Operator who determines the mode of operation by which each item must be completed.

Edison's analysis of the remaining uncompleted activities shows that the issuance of an operating license, the loading of fuel and the testing of the facility can proceed consistent with the reasonable assurance of no undue risk to public health and safety.

Compliance with the NRC's regulations has previously been detailed in Reference (b). To the extent that those regulations are still in force, Edison continues to believe that it is in essential compliance with them.

Similarly, Edison believes that it is in essential compliance with all regulations promulgated subsequently.

Furthermore, the Technical Specifications which have been prepared for Byron Unit 2 are in conformance with the as-built plant and the FSAR.

The Byron Unit 2 Technical Specifications were developed during the approval of the Byron Unit 1 Technical Specifications. The accuracy of the Byron Technical Specifications has been demonstrated by the two years of direct experience with them since Byron Unit 1 was licensed in late 1984. The only differences between the Technical Specifications for Byron Unit 1 and Unit 2 are unit-specific in nature. As there are only a limited number of differences, the reviews documented in references (d) and (e) support the certification of the Byron Unit 2 Technical Specifications. These circumstances, and the reviews described below for the Byron Unit 2 Technical Specifications, provide a high degree of confidence in the appropriateness of the Byron Technical Specifications.

The development of the Byron Technical Specifications involved an extensive, multidisciplinary review of the entire volume to further assure their accuracy. Byron Station personnel conducted: (1) a 100% on-site review of proposed Technical Specifications for Byron Unit 2 identified during the preparation of the Byron Unit 1 Full Power Technical Specifications and, (2) a 100% on-site review of all station-initiated technical changes since Edison's initial submittal of Unit 2 Technical Specifications. Additionally, input and review were obtained from several other organizations when deemed appropriate by the Byron Station. The corporate and station departments involved in the verification included: Project Engineering, Technical Services-Nuclear, Station Electrical Engineering, Nuclear Fuel Services, Nuclear Licensing, Byron Technical Staff. Byron Operating, Byron Training, Byron Maintenance, Byron Radiation Chemistry and Nuclear Safety. Appropriate credit has also been taken for the reviews of the Byron Unit 1 Technical Specifications conducted by Westinghouse (NSSS vendor) and Sargent & Lundy (Architect-Engineer).

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'l All substantive differences between the Byron Unit 2 Technical Specifications and the approved Byron Unit 1 Technical Specifications are I unit-specific in nature. We understand that substantial agreement on the appropriateness of these differences has been achieved through discussions with the NRC Staff. Several change requests applicable to Byron Unit 2 technical specification certification are currently pending on the Byron I

docket. These changes are provided in Attachment I, along with brief descriptions of their status and acceptable deadlines for their resolution.

Based on the previously described extensive, in-depth reviews and the proposed resolutions of the above listed docketed change requests, Edison believes that the Byron Unit 2 Technical Specifications are in conformance with the as-built facility and the Byron /Braidwood FSAR.

There are certain Technical Specification requirements, such as surveillance times, Which are patterned after the Westinghouse Standardized Technical Specifications and are not directly linked to specific FSAR analyses. To the extent that we can demonstrate such requirements to be unnecessarily conservative, we intend to propose Technical Specification changes in the future. The current acceptability of the Technical Specifications does not preclude Edison from seeking to modify those which new information shows to be overly conservative.

All of the safety limits, LCO's and setpoints specified in the Technical Specifications are based upon conservative analyses. To the extent that those analyses are unnecessarily conservative, we may be proposing specific changes to redefine those limits. Changes to correct overly conservative technical specifications may also be proposed as experience is gained through the performance of those surveillances and as the Technical Specifications are implemented during the startup program.

We have also reviewed the Technical Specifications against our understanding of the NRC Staff's SER. We are not aware of any changes required to the Technical Specifications based on this review.

For all these reasons, Edison believes that Byron Unit 2 has been designed, constructed and pre-operationally tested in a way that will assure it meets the requirements of the FSAR, other licensing-related documents, the SER and the NRC's rules and regulations. Therefore, Byron satisfies the Commission's requirements for a license.

Very truly yours, Cordell Reed Vice President

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ATTACHMENT I Byron 2 Certification Technical Specification changes Pending as of October 28, 1986 ISSUE TIMEFRAME FOR RESOLUTION Heatup and Cooldown curves - Prior to initial issuance Westinghouse has issued revised of license curves. Submitted 8/22/86, supplemented 10/3/86 (Johnson to Denton).

~ Fire Protection tables - revises the Prior to initial issuance number of fuel handling building of license detectors. Submitted 9/10/86, supplemented 10/27/86 (Johnson to Denton)

Maximum uranium weight per fuel Prior to initial issuance rod. Submitted 7/30/86 (Johnson to of license Denton)

Grid plane locations - Revision Prior to initial issuance of to include differences between license Unit 1 and Unit 2 grid plane locations. Submitted 7/30/86 (Johnson to Denton).

Target Axial Flux difference value- Prior to initial issuance Changes "0%" to the " predicted of license value" for the end of cycle life. Request submitted 7/30/86 (Johnson to Denton).

Auxiliary Feedwater Pump Diesel Oil Prior to initial issuance i

Day Tank Level - deletes the unit of license specific percentage values while retaining the 420 gallon requirement.

Submitted 8/5/86 (Johnson to Denton).

Interim Technical Specifications Prior to initial for VA deferrals. Submitted 10/1/86 issuance of license (Farrar to Denton)

Section 6 changes to reflect Station Staff's convenience 4

Manager concept - no technical impact. Submitted 9/10/86, Supplemented 10/7/86 (Johnson to Denton).

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ISSUE TIMEFRAME FOR RESOLUTION Byron Unit.2 L7 Value- Prior to initial issuance of license maximum allowable containment leakage rate needs to be included in Unit 2 Tech Specs. Submitted 8/22/86, supplemented 10/23/86 (Johnson to Denton)

Interim. Technical Specification Prior to initial issuance of for removing the equipment and license personnel hatch prior to Unit 2 initial criticality.

Submitted 10/27/86 (Johnson to Denton)

Ultimate Heat Sink (UHS) Staff's convenience ,

cooling towers-revise the instrument indication for 873.75 feet mean sea level to 50% instead of 86%.

Submitted 8/13/86, supplemented 9/16/86 (Johnson to Denton) 2319K I

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