ML20215M996
| ML20215M996 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/27/1986 |
| From: | Johnson I COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 2346K, NUDOCS 8611040145 | |
| Download: ML20215M996 (4) | |
Text
_ _ _ _ - _ _ _ _.
fm
) Commonwealth Edison c
One First National Plaza, Chica0o, Illinois Address Reply to: Post Omce Box 767 k
Chcago, Illinois 60690 - 0767 October 27, 1986 Mr. Harold R. Denton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC. 20555
Subject:
Byron Station Unit 2 Interim Technical Specification NRC Docket No. 50-455
Dear Mr. Denton:
The purpose of this letter is to provide you with the technical basis for our relief request from the provisions of Byron Station Technical Specification 3/4.9.4(a).
Granting it does not result in any negative impact upon the. health or ss.fety of either Commonwealth Edison personnel or the public. The technical specification currently requires Byron Station to maintain one door of the personnel hatch and the equipment hatch in place and held by minimum of four bolts or the equipment hatch removed pursuant to the Surveillance Requirement 4.9.4.2.
.The station requests to have the equipment and personnel hatch open during Unit 2 fuel load, prior to initial criticality.
During the fuel handling process, a " clean zone" (zone 2) " dirty zone" (zone 6) must be established.
Imposing this technical specification requirement would necessitate Byron Station to divide a four foot wide area and the stairways in half. Such an arrangement does not provide sufficient separation between the two zones and would result in a nonworkable situation during the initial fuel load.
In the event that an emergency should occur within the containment during the course of fuel load, having the hatch open would enhance our ability to respond and mitigate the potential for personnel injury or equipment damage. Additionally, the fuel handling foreman supervises activities in both the reactor cavity area and the fuel handling building.
If a situation arises, the foreman will have direct and ready access to both areas with the equipment hatch open.
A similar interim Technical Specification was issued for Byron Unit 1
-which allowed removal of the equipment hatch prior to initial criticality.
This change would allow Byron Unit 2 to have similar access conditions during fuel load as they had with Unit 1.
8611040145 861027 PDR ADOCK 05000455 A
\\
~.
6 Inspection and startup activities require large pieces of equipment (i.e. man basket and equipment for upperhead, internals and lif ting rig inspection and the reactor vessel stud tensioning device) to be employed.
Allowing the equipment hatch to remain open facilitates these activities.
In addition if any major equipment requires replacement, the equipment hatch would have to be opened.
It is very difficult to maneuver large and bulky equipment through the personnel hatch unless the personnel hatch is allowed to remain open during fuel load prior to initial criticality.
Lastly, the interlock in the personnel hatch is limited so no more than 30 people would be allowed in containment with the personnel hatch on.
This would seriously limit the startup activities, as well as inspections and walkdowns.
In order to maximize.the orderliness and efficiency of the fuel handling operation While minimizing the potential for errors, it will be necessary to allow the personnel and equipment hatches to remain open.
Commonwealth Edison has had experience in loading the core with the hatches closed and more recently, in the case of Byron Unit 1, with the hatches opened. We have found the fuel loading process to be a much a smoother evolution when the hatch is open.
Enclosed in Attachment I, is page 3/4 9-4 of the Byron Station Technical Specifications marked-up to reflect this relief request. Please issue this revised page for inclusion in the Byron Technical Specifications.
Should you have any questions about this matter, please contact this office.
One signed original and fifteen copies of this letter are provided for your review.
Very truly yours, I. M. Jo n
Nuclear Licensing Administrator
/klj cc:
.L. 01shan att.
2346K
s.
ATTACHMENT I Proposed Change to Containment Building Penetrations Tech Spec to Reflect Requested Relief Pg. 3/4 9-4 2346K i
i l
I l
t
[
- REFUELING OPERATIONS l
3/4.9.4 CONTAINMENT BUILDING PENETRATIONS I
LIMITING CONDITION FOR OPERATION 3.9.4 The. containment building penetrations shall be in the following status:
l The personnel hatch should have a minimum'of one door closed at any a.
one time and the equipment hatch shall_ be in place and held by a-minimum of four bolts or the equipment hatch removed pursuant to Surveillance Requirement 4.9.4.2, b.
A minimum of one door in the personnel emergency exit hatch is 1,.
closed, and c.
Each penetration providing direct access from the. containment atmosphere to the outside atmosphere shall be either:
[
1)
Closed by an isolation valve, blind flange, or manual valve, or i
2)
Capable of being closed by an OPERABLE automatic ~ containment purge isolation valve.
APPLICABILITY:
During CORE ALTERATIONS or movement of irradiated fuel within the containment.
ACTION:
With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or movement of irradiated fuel in the containment building.
i i
SURVEILLANCE REQUIREMENTS 4.9.4.1 Each of the above required containment building penetrations shall be determined to be either in its closed / isolated condition or capable of being.
closed by an OPERABLE automatic containment purge isolation valve withi~n 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of and at least once per_7 days-during CORE ALTERATIONS or movement of irradiated fuel in the containment building by:
j a.
Verifying the penetrations are in their closed / isolated condition, j
or b.
Testing the containment purge isofation valves per the applicable i
portions of Specification 4.6.3.2.
l l
BYRON - UNITS 1 & 2 3/4 9-4
- Idof 06W icablt-t Untt1 flor 30 inM0d Crdi(A 8
l 1
.