Text

Forwards Util Response to RAI Re Partial Review of Current TS for Byron & Braidwood
	ML20216C020
Person / Time
Site:	Byron, Braidwood
Issue date:	09/02/1997
From:	Stanley G; COMMONWEALTH EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	NUDOCS 9709080210
	Download: ML20216C020 (31)
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!elNikiw 2Hol September 2,1997 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington. D. C. 20555 ( -

Subject:

Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Response to Request for Additional Information

References:

(1) R. Assa (NRC) to I. 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 the Commonwealth Edison (Comed) response to the NRC's request for additional information (RAl). The response to the RAI questions are contained in Attachment 1. A list of Reference (2) pages affected by this RAI response is provided in Attachment 2.

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

The questions and comments involve only Sections 1.0,2.0,3.1, and 3.2 of the Reference (2) submittal.

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, a U,S. Nuclear Regulatory Commission September 2,1997 As discussed with NRC Staffin an August 12,1997 teleconference, this submittal does act include any replacement or marked-up CTS pages. The required page changes and mark-ups will be submitted at a later date when the NRC review of the amendment request is near completion. As stated above, a list ofITS submittal pages afTected by this response is provided in Attachment 2 Please address any comments or questions regarding this matter to our Nuclear Licensing Department.

Sincerely,

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i ene Stanley Site Vice President Braidwood Nuclear Generating Station Attachment 1: Response to NRC RAI Report Attachment 2: Comed Response to August 5,1997 NRC RAI , ITS Submittal Affected Page List i cc: Regional Administrator-Rill Byron Project Manager-NRR Braidwood Project Manager-NRR Senior Resident inspector-Braidwood Senior Resident Inspector-Byron Office of Nuclear Safety-IDNS owididadmasst nrr57115mt doe l

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I Attachment 1 Response to NRC RAI Report on the Comed ITS Submittal i

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R:sponse to NRC RAI Report 02 Sep-97 NRC RAI Number NRC lasued Date RAI Status

'l.0 01 84/97 Open - NRC Action Required NRC Description ofissue 1.0-01 DOC Al9 CTS 1.0 Definition for Shutdown Margin The definition in the CTS has been revised to confbrm to the definition in the STS. Ilowever, there are two markup errors in the CTS. The CTS markup does not contain "With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and" which is contained in the ITS. Also, the definition markup does not reference DOC A19, whichjustifies this change. The only reference to DOC A19 appears on CTS pages 3/41 1 and 3/413. These pages follow the CTS 1.0 markup pages. Comment: Revise the submittal to correct these markup errors.

Comed Response to issue Revised the ITS submittal to sorttet the markup errors: "the CTS markups were revised to add the missing text "With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and." In addition, CTS DOC 1.0-A19 was added to the CTS markups for the definition of Shutdown Margin.

NRC RAI Number NRC issued Date RAI Status 1.0-02 8/5/97 Open NRC Action Required NRC Description ofIssue 1.0-02 JFD-P2 ITS 1.2 Logical Connectors, Examples 1.21 and 1.2 2 ITS 1.3 Completion Times, Examples 1.31 through 1.3 7 ITS 1.4 Frequency, Examples 1.41 through 1.4 3 Titles have been added to these examples. The examples in the STS do not contain titles. These changes have been categorized as plant specific changes. Comment: These changes base been categorized incorrectly. These changes are generic. These are notjustifiable plant specific or editorial differences.

Comed Response to issue Revised the ITS submittal to omit the titles: ITS and NUREG were revised to delete the titles from the examples in Sections l.2,1.3, and 1.4.

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Response to NRC RAI Report c2.sep.97 l

~fdtVIIAiTEmber NRC issued Dale ~ 51 R Status 1.0-03 s/5/97 Open . NRC Action Required NRC Ibeription oflosue i

1.0 03 DOC M2 and DOC Al2 JI D C9 13TF 88 CTS Table 1.2 Note "

IFS lable 1.1 1 Notes (b)and (c)

STS Table 1.1 1 Notes (b) and(c)

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The CTS note ,iroposed to be changed by specifying that the " required" bolts be tensioned instead of "all" the bolts as implied by the CTS and specified in the STS. This change and difference is based on TSTF 88 whlch has not been approved by the NRC, Comment: Revise the submittal to adopt the STS wording of Notes (b) and (c) which is consistent with CTS requirements.

Cor.Ed Response to lisue No change. The NRC, Owner's Group Chairpersons, and utility management are scheduling a meeting to discuss generic issues (l.c., TSTFs) that involve changes to the Imptoved Technical Specifications (ITS). The main focus of this meeting is to discuss a schedule for reviewing the TSTFs, w ho is reviewing the TSTFs, and what direction is to be provided to utilities which have submitted ITS and have taken credit for the TSTFs that have not yet been approved. Therefore, the status of this RAI la pending resolution of these issues.

NHC RAI F er NRC losued Date RAI Status 1.0-Os 8/5/97 Open NRC Action Required NHC therlpth 2f Isst e 1.0-04 A13 JFDs C3 and P5 Section 5 0 JFD C9 STS Markup insert 1,15A ITS 5.6.6 PTLR ITS Definition of PTLR TSTF 4, Revision i TSTF 4 proposed placing the PORY lift settings in the PTLR, modifying the PTLR def;nition to indicate this, and removing the reference to specifications 3.4.3 and 3.4.12 from the PTLR definition. TSTF 4 rejected by NRC on IW28/96, in addition, JFD P5 states that the LTOP enable temperature, which was added to the PTLR definition by TSTF 4, is not included in the ITS definition of PTLR Comment: Revise the submittal to adopt the STS definition of PTLR; delete JFDs C3 and P5. Note, DOC A13's statement that the proposed PTLR definition is consistent with the STS is incorrect because the defimition is based on 'ISTF 4 Finally, Sect %n 5.0 JFD C9 should be deleted and ITS 5.6.6 revised to match the STS.

Comed Response to Issue By letter dated May 21,1997, a revision to the flyron and Braidwood CTS was requested to relocate the Pressure and Temperature Limits in accordance with Generic Letter 96 03. At the time of the ITS Revision A submittal, the proposed change to CTS had not yet been submitted. Therefore, the proposed CTS License Amendment Request w as incorporated into ITS.

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Itsponse to NRC RAI Report o? Sep.97

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NRC RAI Number NRC lssued Date R AI Status 1.0 05 8'$/97 Open . NRC Action Required NRC Description of lisue 1.0 0$ Channel Calibration dennition DOC A3 Ji'D C8 (1S10-64)

DOC A4 Ji D C2 (1S11 19)

Channel Operational Test (COT) definition DOC A3 JiD CS(TS1T 64)

DOC L3 JI D C7 (TSTI 39, Rev.1)

Trip Actuating Device Operational Test (T ADOT) dennition DOC A3 Ji D C8 (1STF 64)

DOC L3 JI D C7 (TSTT 39, Rev.1) 1he listed dennitions in the CTS are proposed to be revised as described by the DOCS an/.11 Ds listed. The following snarkup of these C1S definitions shows the propewd changes; the justi0 cation for each change is noted in bold typeface in brackets following the change. Language common to the corresponding STS definition is underlined.

A Cil ANNEL CAllllRATION shall be the adjustment, as necessary, of the channel such that it responds within the required range and accuracy to known values of[Al] inputs. [ Al and Pl] 'the CilANNI1 CAllllRAllON shall encompass the entire channel including the required sensors and alarm, interlock, display and'or trip functions and l A3 and C8] 1hc CilANNEL CAI IllRATION shall encompass those components, such as sensors, alanns, displays, and trip functions, required to perform the sperined safety function (s). [ A3 and C8] Calibration of instrument channels with Resistance Temperature Detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and nonnal calibration of the remaining adjustable devices in the channel. [ A4] Whenever a sensing element is replaced, the next required CilANNEL CAllllRATION sahlt include an inplace cross calibration that compares the opther sensing elements with the recently installed sensing element. [C2] 1he CllANNEL CAllilRATlON [A4] may be perfonned by means of [ Al] any series of sequential, m erlapping calibrations [ Al], or total channel steps such that the entire channel is calibrated.

An AN ALOG CllANNCL OPERATIONAL TEST COT [ A.1) shall be the injection of a simulated or actual [A2] signal into the channel as close to the sensor as practicable to s crify the [ A3 and C8] OPERAlllLITY cf required alarm, interlock, display, and'or trip functions [ A3 and C8] , including all components in the channel, such as alarms, interlocks, displays, and trip functions, required to perfonn the specined safety function (s). [ A3 and C8] ThKOT may be performed by means of any series of sequential, m criapping, or total channel steps so that the entire chunel is tested. [L3 and C7] The ANALOG CilANNEL OPERATIONAL TEST [ A 1] COT shall include :djustments, as necessary, of the required l A3]

alarm, interlock and'or [ A Il Trip Setpoints such that the Setpoints are within the required range and accuracy.

A TRIP ACTUATING DEVICE OPERATIONAL TEST TADOT [ Al) shall consist of operating the trip actuating device and verifying the OPERAlllLITY of required alann, interlock, display, and'or trip functions, including all components in the channel, suc h as alanns, interlocks, displays, and trip functions, required to perfonn the specined safety function (s), [ A3 and C8] lhe TADOT may be perfonned by means of any series of sequential, overlapping, or total channel steps so that the entire trip actuating device is tested. [L3 and C7] The TRIP ACTUATING DEVICE OPER ATIONAL TEST TADOT [ All shsilinclude adjustment, as necessary, of the trip actuating desice such that it actuates at the required setpoint within the required accuracy.

a. DOC L3 and Ji D C7 are based on 'lSTF 39, Revision 1, which adds to the CTS and STS dennitions of COT and TADOT the sentence, "1he COT (TADOT) may be performed by means of any series of sequential, a erlapping, or total channel steps so that the entire channel (trip actuating device) is tested." TSTF 39, Res. I, has not yet been approved by the j NRC. Comment: Resisc the submittal to withdraw this proposed allowance from the definitions for COT and TADOT if TSTF 39, Rev.1, is rejected by the NRC.

b. DOC A3 and Ji D C8 are based on TSTF-64 which attempts to clarify the C'lS and STS deOnitions of Channel j 3

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-1_ Response to NRC RAI Report _ -

02 ser 97 C brbo COT, md TADOT, TSTF 64 replaces the C'lS and STS wording describing the components that inust be tested in each channel. TSTF 64 has not yet been approved by the NRC. Comment: Revise the submittal to adopt the STS w ording for this part the dennitions for Channel Calibration, COT, and TADOT if TSTF-64 is rejected by the NRC.

DOC A4 and JFD C2 are based on 1STF 19 which revises the STS defmition of Channel Calibration. TSTF 19 proposes to remove language describing how to perform a Channel Calibration for RTDs and thermocouples following replacement of a sensing element.1he NRC approved TSTF.19 with modi 0 cations; NRC received 1STF 19, Revision 1. on April 7 I 1997, but have not yet approved it. Comment: Revise the submittal to adopt the STS wording for this part the definition for Channc' Calibration if TSTF 19, Rev. I,is rejected by the NRC. Note: Adopting the language added by DOC A4 would be acceptable because the CTS dennition currently does not specincally address calibration of RTDs and themocouples.

Comed Hesponse to lisue !

No change. In a rnecting between the NRC and the NEl Technica! Specincations Task Force (TSTF) on April 17.1997, the NRC described problems that had been found with the ISTS definitions of Channel Calibration, Channel Operational Test ;

(COT), Trip Acturating Device Operational Test (TADOT), and related dennitions. Ilased on the NRC's suggestions, the ;

ilWROO developed revised dennitions of these terms (BWROO 38). The NEl TSTF has reviewed this 1raveler and agreed !

to the proposed changes.1he traveler is currently under review by the individual Owner's Groups. Therefore, the status of

- this RAI is pending resolution of the traveler and review by the NRC.

NHC RAI Number NRC lasued Date RAI Status 1.0-06 8'$/97 Open.NRC Action Required NHC i escription of issue I l.0-06 ITS 1.4 Frequency examples 1.4 3 and 1.4-4 WOG 74 ,

! JFD C10

a. WOG 74 changes "were" of the STS to "was" in example 1.4 3; the use of"were" in the STS is an intentional use of the subjunctive mood. Comment: Adopt the STS verb form. ;

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b. WOO 74 adds a fourth example to illustrate the use of a surveillance note that says, "Only required to be performed in !

Mode 1." This is in contrast to the note that says, "Only required to be met in Mode 1," w hich is addressed in example 1.4

3. Comment: List all occurrences of this note in the ITS, and explain u hy the Bases explanation in each case is inadequate for understanding how the note modines the Frequency. In addition, the proposed examp!c fails to state the time limit for -

performing (and meeting) the surveillance following entry into Mode 1 (this would be the Completion Time of the applicable Required Action). NRC acceptance of this example would require prior owners group and TSTF approval of a corresponding generic change to all Ove STS NUREGs. Recommend withdrawal of example 1.4 4.

ComFd Resp <mse to issue

- Item a: 11S and NUREO wcre revised to adopt the word "were"in Section 1.4, Frequency Examples 1,4 3 and 1.4-4. Item [

b: No change. WOG 74 adds a fourth example (Example 1.4-4) to illustrate the use of a Surveillance Requirement (SR)

Note that states "Only required to be performed in MODE 1," As the example states, the assumed Applicability of the associated LCO is MODE 1,2, or 3. As the example also states "Should the 7 day interval be exceeded while operation is ,

not in MODE 1. this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance." Therefore, the -

i time limit for performing the SR is prior to (not following) entry into MODB 1. In Example 1.4 3, if the SR were not performed within the _"specined Frequency"(plus the extension allow ed by SR 3.0.2), the use of"Not required to be -

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performed..." permits entry into the speci0ed condition in the Note for a specined time stated in the Note to perform the i

SR In contrast,in Example 1.4 4,if the SR were not performed within the "specified Frequency"(plus the extension i

allow ed by SR 3.0.2), the use of"Only required to be performed.. " prohibits entry into the specified condition in the Note until the SR were performed.1his kind of Note appears in the following ITS SRs: 3.1.2.2,3.3.1.3,3.4.3.1,3.4.11.1 Note 2, i

3.4.Il.2,3.4.14.1,3.4.I6,2,3.5.l.5,3.5.4.I,3.5.4.2,3.7.1.1, and 3.7.2.1. Example 1.4 4 was added to avoid Operator

confusion and a potential SR 3.0,4 or SR 103 violation. Comed continues to pursue this change.

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a f Respo:se to NRC RAI Report 02 Sep-97 NRC NAEiiumber~~-NRC lasued Date EA'lStatus 1.0-07 3!.*/97 Open NRC Action Required NRC Description of Ia.M 1.0 07 JrD Cll ITS 5.$.16 Containment Leakage Rate Testing Program STS definition of La TSTf$2 1he dennition of La is proposed to be omitted from the ITS and its value specined in lis $.$.16. JFDll states this is consistent with the STS changes proposed by TSTT $2, which TSil modified on 10/24/96 for 1STF consideration. No revisions to TSTT $2 have been tubmitted to date, llowever, denning La in the administrative controls program may be acceptable it was accepwu in the Vogtle Units 1 and 2 conversion to the ITS. Comment: The purpose of this comment is solely to track resolution of TSTT 52 as it relates to the adoption of Appendix J Option il for Ilyron and tiraldwood. It may be repeated (with different emphasis) in comments for ITS Section 3.6.

Comed Response to issue The purpose of this comment is solely to track resolutiot n'TSTF 52 as it relates to the adoption of App?adix J Option 11 for !!yron and liraldwood. No response required.

NRC RAI Number NRC Issued Date RAI Status 2.0-01 8/$/97 Open NRC Action Required NRC Description oflosue 2.0-01 JFD PI ITS Figure 2.1.1 1,(page I of !) Reactor Core Safety Limits CTS Figure 2.1 1, Reactor Core Safety Limit Tour Loops in Operation CTS Figure 2.1 1, x axis is titled

Pow er (fraction of Nominal)". ITS rigure 2.1.1 1,(page 1 of 1) Reactor Core Safety _

Limits, x axis is titled "TilERMAL POWER (PERCENT)". The STS and correct x axis name is

PERCENT OF RATED TilERMAL POWER". The Figure should state the safety limit for a given thermal power level that is based on a .

percentage with respect to the

RATED" TilERMAL POWERi The percentage must be based upon a distinctive value such as RTP to be determined as a percent of the accepted value. Comment: Revise the submittal as described.

Comed Response to issue Resised the ITS submittal as described: The titles of the x axes for the Ilyton and Braidwood Reactor Core Safety Limits Figure 2.1 1 and the ITS Reactor Core Safety Limits figure 2.1,1 1 w ere revised to read " PERCENT OF RATED TilERMAL POWER" consistent with NUREO 1431 Revision 1.

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. I Response is NRC RAI Report 02 Sep 97

~NiiflIIfNumber NHC lasued Date RAI Status 2.0-02 8'$/97 Open . NRC Action Required NRC Description ofissue 2.0-02 JfD llPl liases 11S 2.1.1 in the Applicable Safety Analyses, second paragraph, first sentence states that RTS setpoints are from the UFSAR analyses and the setpoint methodology study w hich are then used in ITS 3.3.1. Ref. 2 is correct and shouH not be deleted. In the last paragraph, the deletion of the UFSAR Ref. 2 appears incorrect. These deletions are per llPl w hich does not explain the speclue technical reasons for these deletions. Comment: Revise the submittal as described.

Comed Response to issue Revised the ITS submittal as described: ITS and NUREO wcre revised to include "(Ref.2)" consistent with NUREG 1431 Revision 1.

NHC RAI Number NHC issued Date RAI Status 2.0 03 8/$/97 Open.NRC Action Required NRC Description ofissue 2.0 03 JFD IIP 5 Ilases ITS 2,1,1, page 112.0 3 in the Safety Limits. Orat sentence, the reference to the Ogure should be to the actual agure used in the SL Including the figure in the liases is optional, and easy to update ifincluded. Comment: Revise JFD llP$ as noted.

Comed Response to issue No change. The Ilackground Section of the liases for NUREO LCO 3.1.7 (page !! 3.1 39) states "An example is provided for information only in Figure 113.1.7.l" and Figure 113.1.7 1 states "This Ogure for illustration only. Do not use for operation." Similarly, Figure 112.1.1 1 states ' Tor illustration only. Do not use for operation." RAI 3.1.6 03, states

" Figure in STS is for illustrative purposes". In addition, the LCO Section of the flases for NUREO LCO 3.2.3 (page 113.2

31) states that " Figure 113.2.3A.1 shows a typical target band and typical AFD acceptable operation limits" (also Ref. RAI 3.2.3 03); Figure 113.2.3 A.I states "This Ogure for illustration only. Do not use for operation." including " illustration only" Ogures in the Itases is consistent with NUREO.1431 Revision 1. The convention adopted in the !!yron and Ilraidwood ITS submittal was to delete " illustration only" Ogures in the Ilases to eliminate the possibility of an Operator inadvertently using a Dases Ogure in place of an actual Ogure. Ilow ever, because !!ases Figure 112.1.1 1 contains more information than the LCO Figure, the Ogure was retained. Comed continues to pursue this change.

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Response to NRC RAI Report 02 sep-97 NRC RAI Number NRC issued Date RAI Status

2.0 04 8/3/97 Open NRC Action Required ,

NRC Description ofissue 2.0-04 JrDllP7 Ilases 113 2.1.2, page 112.0 7 in the Background discussion, second paragraph, the afhtlon of the text is acceptable. Ilowever, the JrD BP7 justification implies there are approved exemptions to the ASME tode. Comment: Revise JFD llP7 with a more detailed explanation and technical basis for this difference.

Comed Response to losue Revised the ITS submittal to expand liases JfD 2.0.P7 as follows: *Per 10 Cl R $0.55a (3) relief from ASME Code requirements can be granted by NRR if alternative methods provide an acceptable level of quality and safety or if compliance with Code requirements would result in hardship or unusual difficulty without a compensating increase in safety and quality. These exemptions from ASME code requirements are common for both inservice inspection of components and inservice testing of pumps and valves. In addition,10 CPR $0.55a(g)($)(ii) states that if a res ised inservice inspection program connicts with the Technical Specifications, the Licensee shall apply to the NRC for amendment to the Technical Specifications to the revised program."

NRC RAI Number NRC lasued Date RAI Status 2.0-05 8/$/97 Open NRC Action Required-NRC Description of issue 2.0-05 JFD llP2 liases ITS 2.1.2, page 112.0 9 in the discussion of Safety Limit Violations, the difference justified by JFD BP2 deletes the words *the RCS pressure" in lieu of SL "2.1.2". This change is equivalent but it eliminates a clear identification that the safety limit under discussion is the one conceming the "RCS pressure" SL rather than using a numerical identilication. Comment: Revise the submittal to adopt the STS wording.

Comed Response to issue Revised the submittal to adopt Dyron and Draidwood 113 wording for referencing Specifications: ITS and NUREG have been revised to replace NUREO wording "the RCS Pressure SL" in the Safety Limit Violations Section of the 11ases fc:

NUREO SL 2.1.2 with *SL 2.1.2,"RCS Pressure SL, *". %is change is consistent with the consention used throughout the ITS submittal for referencing ITS SLvtCOs.

NRC RAI Number NRC lisued Date RAI Status 2.0-06 8'5/97 Open Comed Action Required NRC Description oflisue 2.0-06 JFD llPII Bases ITS 2.1.2, page B 2.0 9 In the discussion of Safety Limit Violations, JFD BPil provides guidance if the SL CT is exceeded. Comment: Submit TSTP to incorporate BPil change into STS.

Comed Response in issue Comed will submit a traveler at the next Westinghouse Owner's Group (WOO) ITS meeting scheduled for November 19 and 20,1997 to propose the Byron and Ilraidwood plant specific change to the WOO. In the interim, Comed continues to pursue this change.

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R:sponse to NRC RAI Report 02 Sep.97

~5EU~RAI Number NRC lisued Date RAI Status

'3.1 01 8/5/97 Open . Comed Action Required NRC Deseription of lasue 3.1-01 JFD P19 SR 3.1.6.1, the verification of the estimated critical control bank position 1hc word *Once" has been added to the frequency w hich specifies an interval *Within" a particular time frame ('Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to criticality"). Comment: 1his is a legitimate use of the word "Once" in an SR frequency, and it is a generic change. This should be brought to the Tech Spec Task Force for future action.

Comi:d Response to issue ComCd will submit a traveler at the next Westinghouse Owner's Group (WOG) ITS meeting scheduled for November 19 and 20,1997 to propose the flyron and tiraidwood plant specific change to the WOG. In the interim, Comed continues to pursue this change.

NRC RAI Number NRC lisued Date RAI Status 3.1.1 01 8/5/97 Open . NRC Action Required NRC Ikscription ofissue 3.1.1 01 liases discussion ofITS SR 3.1.1.1, page 113.1 6 1he sentence "1he SDM is specined in the COLR.' has been added to the Ilases.

Comment: Revise this insert to read "1he SDM limits are specified in the COLR."

Comi'd Response to issue ITS and NUREG were revised to reword the Bases insert (Ref liases JFD 3.1 P2 on page 113.16) to read *The SDM limits are specilled in the COLR."

NRC RAI Number NRC issued Date RAI Status 3.1.2 01 8/5/97 - - Open Comed Action Required NRC Description oflasue 3.1.2 01 JFD P4 JFD-IIP 9 ITS SR 3.1.2.1 and SR 3.1.2.2 STS SR 3.13.1 In lieu of adopting STS SR 3.1.3.1, veri 0 cation of core reactivity with two frequencies, the ITE specifies two SRs, SR 3.1.2.1 and SR 3.1.2.2, Comment: This is an editorial change. Submit a TSIT change request.

Comed Response to issue Comed will submit a traveler at the next Westinghouse Owner's Group (WOG) ITS meet %g scheduled for November 19 and 20,1997 to propose the Hyron and Hraidwood plant specific change to the WOG. In the interim. Comed continues to pursue this change.

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I Response to NRC RAI Rep:rt 02 sep 97 NRC mal Number NRC issued Date RAlStatus 3.1.3 01 8/5/97 Open.NRC Action Required NRC Description oflisue 3.1.3 01 JfD.llP6 11ases discussion for 11S SR 3.1.3.2, page 113.1 23 The discussion about the 300 ppm surveillance limit for the MIC has not been adopted. The reason given for this difference is that the discussion is at a level of detail not actually in the SR. This material is relevant to understanding the development of the 300 ppm MTC Surveillance limit. Comment: 1his is not ajustinable plant specine or editorial difference from the STS. Revise the submittal to adopt the STS discussion.

Comed Response to issue ITS and NUREO were revised to include in the Surveillance Requirements Section of the Bases for ITS LCO 3.1.3

llecause the RTP MTC value will gradually become more negative with further core depletic.a and boron concentration ieduction, a 300 ppm SR value of MTC should necessarily be less negative than the EOL LCO limit. The 300 ppm SR value is suf0ciently less negative than the EOL LCO limit value to ensure that the LCO limit will be met when the 300 ppm Surveillance criterion is met." As a result, liases JFD 3.1 P6 was changed to "Not used."

NRC RAI Number NRC lasued Date RAI Status 3.1.4 01 8/5/97 Open. Comed Action Required NRC Description oflasue 3.1 A 01 DOC.A6 JFD.p7 ITS 3.1.4, Required Action 11 CTS 3.1.3.1.b !

STS 3.1.5, Required Action 11.1 The CTS and STS contain the required action to restore rod alignment. the ITS deletes this action, since complying with the LCO is alwsys an option. Approved.

Comment: Provide a TSTF change request for this change.

Comed Resp <mse to issue Comed will submit a traveler at the next Westinghouse Owner's Group (WOO) ITS meeting scheduled for November 19 and 20,1997 to propose the flyton and 11raldwood plant specinc change to the WOO. In the interim, Comed continues to pursue this change. ,

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Response to NRC liAl Report 02 sep.97

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~NRC RAI Number NRC luued llate RAI Status 3.1.4-02 8/5/97 Open NRC Action Required ,

NRC Description of luue 3.1,4 02 DOC LA9 JFD-CIO 11S SR 3.1.4.1 CT S SR 4.1.3.1.1 STS SR 3.1.5.1 De CTS and STS have an herensed SR frequency to verify rod alignment w hen the rod position deviation monitor is inoperable. %ls change has been submitted in TSTF traveller i10. TSTF.110 final disposition is pending, and has been tecommended for rejection.

Comment: Retain increased SR frequency when the rod position deviation monitor is inoperable.

Comed Response to luue No change. TSTF.110 Revision 1 relocates conditional Surveillance Requirements (SRs) for functions with inoperable alanns from the Technical Specl0 cations (TSs) to plant procedures or programs. %e TSTFjustifies this by stating that the alanns do not directly relate to the LCO limits. Inoperable alarms do not afTect the operability of the TS function. This justification was used and accepted by the Staff during the development of the IlWR NUREGs to allow relocation of the alann fur.etions from the ilWR Tuhnical Speci0 cations to plant procedures. This justification was accepted by the Staff prior to the issuance of Revision 0 of the NUREUs. Typically these alanns are monitoring parameters u hich must be verified met on a specified Frequency (e.g.,12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ), ne basis for this Frequency is justined due to the operability of the alarm function. Whenever this alarm function becomes inoperable, a more frequent SR Frequency interval is performed on the parameter (e g.,4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ). His frequency continues until the alann function is restored to operable status, Relocating this detall to plant procedures or programs would not impact the safety signincance of the TS requirement since the parameter being monitored is presumed to be operable w henever the alarm becomes inoperable, ne inoperable alann function does not impact operability of the monitored parameter, in addition, other ITS SR Frequencies are stated in the ITS Ilases to be based on associated alarms or indicatim which are assumed to be operable or available, (e.g., The Actions Section of the liases for ITS LCO 3.2.4 for Required Action A.2 states "A 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is sufficient because any additional change in QpTR should be relatively slow. Further, this Completion Time is consistent with the Frequency required for the Surveillances with an inoperable alarm or instrumentation." ne Surveillance Requirements Section of the liases for ITS LCO 3.8.1 dir. cussing SR 3.8.1.4 states "The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alanns are provided and facility operators would be aware of any large uses of fuel oil during this period." ne Surveillance Requirements Section of the 11ases for ITS LCO 3.9.5 discussing SR 3.9.5.1 states

ne Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is surncient, considering the flow, temperature, pump control, and alann indications available to the operator in the control room for monitoring the RilR System." The Surveillance Requirements Section of the Ilases for ITS LCO 3.9.6 discussing SR 3.9.6.1 states "The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is suf0cient, considering the flow, temperature, pump control, and alann indications available to the operator for monitoring the RilR System.") These alanns' indications are not specified in the TSs but typically require additional actions within plant procedures to account for the slann/ indication not being available. Typically alarm response procedures provide guidance for any necessary actions whenever alarms are inoperable placing this detail in these procedures ensures that the operator has sullicient guidance to respond to the inoperable alarCunction and to perform the necessary conditional SRs. (See RAls 3.1.6-05 and 3.2.3 04)

Comed continues to pursue this change.

10

1 . .

1 .

Response to NHC RAI Report 02 Sep 97

~5iiC RAI Number NEiC lasued !) ate RAI Status 3.1.5 01 8/$/97 Open . NRC Action Required NRC I)escription of Issue 3.1.$ 01 JFD P12 JFD Pl4 1TS 3.1.5, Applicability liases for ITS 3.1.$ Applicability . page 113.1 36 51S 3.1.6 Applicability Note j

The STS Applicability Note states, *1his LCO is not applicable w hile performing SR 3.1.5.2." This note is adopted in corresponding ITS 3.1.5, with changes, but is placed with the LCO statement to prevent a possible misinterpretation of SR 3.0.4.1hc ITS note states

Shutdown banks may be outside the limit when required for performance of SR 3.1.4.2."

Comment: These are not justifia$3 1e plant specific or editorial differences from the STS. The STS presentation is clear.

Revise the submlaal to adopt the STS presentation.

Comed Response to lasue ITS and NUREG have been revised to adopt the NUREG wording for the Note. As a result, LCO JFD 3.1 P13 was changed to "Not used." llowever, the relocation of the Note from the Applicability to the LCO has not changed. Comed continues to pursue this change. All of the Notes in the Applicability settion of the NUREG LCOs have been moved to the LCO section of the ITS LCOs either plant specifically or as a result of a TSTF that was incorporated. The Note applies to exceptions to the entire LCO and not to exceptions to the Applicability, llaving a Note that modifies the Applicability requirements could imply an exception to the Applicability and thus, could lead to a misinterpretation of SR 3.0.4. Placing the Note in the LCO Section prevents misinterpretation of SR 3.0.4. The following is a list ofITS LCOs in which this convention w as adopted. LCOs in which the Note was moved by a plant specific change: 3.1.5,3.1.6,3.3.9,3.4.1,3.4.10, 3.4.12, and 3.9.6 (SR Note moved to LCO), LCOs in w hich the Note was moved by a TSTF: 3.2.3,3.5.2, and 3.$ 3 (SR Note moved to LCO); LCOs in which the Note was added by a plant specific change: 3.7.12,3.8.$, and 3.9.4; LCOs in which the Note was added by a TSTF: 3.6.3. (See RAI 3.1.6-01.)

NRC RAI Number NRC lasued llate RAI Status 3.1.5-02 8/$/97 Open NRC Action Required NRC Description ofIssue 3.1.5 02 JFD Cl2 ITS 3.1.5 Applicability (recurring editorial changes)

The ITS incorporates editorial changes to the presentation of the Applicability paragraph (semi-colons and the word "and" have been added). Comment: Revise the submutt.i to adopt the STS presentation.

Comed Response to issue WOG-81 was withdrawn from the ITS submittal. ITS and NUREG were revised to adopt the ISTS presentation in the Applicability section ofITS LCOs 3.1.1,3.1.3,3.1.$. and 3.l.6. As a result, LCO JFD 3.1.Cl2 was changed to "Not used."

11

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

II:sponse to NitC ltAl lleport 02 Sep-97 NitC RAI Number NHC lasued Date itAlStatus

3.1.6-01 8'5'97 open. NRC Action Required NRC Description of issue 3.1.6 01 JFD-Pl2 JFD-Pl4 ITS 3.1.6, Applicability liases discussion for ils 3.1.6, Applicability . page 113.142 l STS 3.1.7, Applicability Note The STS Applicability Note states,"This LCO is not applicable while performing SR 3.1.5.2.* This note is adopted in corresponding ITS 3.1.6, with changes, but is placed with the LCO statement to prevent a possible misinterpretation of SR l 3.0.4.1he ITS note states, " Shutdown banks may be outside the limit w he'i required for performance of SR 3.1.4.2.*

Comment: These are not justifiable plant specific or editorial differences from the S'lS.1he STS presentation is clear.

Revise the submittal to adopt the STS presentation.

Comed Response to issue ITS and NUREG hase been revised to adopt the NUREG wording for the Note. As a result, LCO JI D 3.1 Pl4 was changed to "Not used." llowever, the relocation of the Note from the Applicability to the LCO has not changed. Comed continues to pursue this change. All of the Notes in the Applicability section of the NUREO LCOs have been moved to the LCO section of the ITS LCOs either plant specifically or as a result of a TSTF that was incorporated. The Note applies to exceptions to the entire LCO and not to exceptions to the Applicability. llaving a Note that modifies the Applicability requirements could imply an exception to the Applicability and thus, could lead to a misinterpretation of SR 3.0.4. Placing I

the Note in the LCO Section presents misinterpretation of SR 3.0.4. The following is a list ofITS LCOs in which this convention was adopted.1.COs in w hich the Note was mosed by a plant specine change: 3.1.$, 3.1.6, 3.3.9, 3.4.1, 3.4,10, 3.4.12, and 3.9.6 (SR Note moved to LCO); 1.COs in which the Note w as moved by a TSTF: 3.2.3,3.5.2, and 3.5.3 (SR Note moved to LCO); LCOs in which the Note was added by a plant specinc change: 3.7.12,3.8.5, and 3.9.4; LCOs in which the Note was added by a TSTF: 3.6.3. (See RAI 3.1.5 01.)

12

._ . _ . . _ . . . . . _. .J

Response to NRC RAI Report 02.Sep.97 NRC RAI Number NRC lasued Date RAI Status 3.1.6-02 8/5/97 Open NRC Action Required NRC Description ofissue 3.1.6-02 C15 4.1.1.6 ITS SR 3.1.6.1 SR 3.1.6.1 provides the Surveillance Rcquirement and the associated Frequency for the verification of the estimated critical control bank position. Corresponding CTS 4.1.3.6 does not show this material. Comment: This material does not appear in the markup of CTS 3/4.1.3.6. Revise the submittal to show the addition of this Surveillance Requirement to the CTS.

Comi'.d Response to issue CTS markup pages 3/41 1 for CTS SR 4.1.1.1.1.b and 4.l.l.l.l.c were revised to include the material originally deleted by CTS DOC 3.1 RI. CTS SR 4.1.1.1.1.b was annotated with "SR 3.1.6.2" in the margin and CTS SR 4.1.1.1.1.c was annotated with "SR 3.1.6.1" in the margin, in addition, CTS markup pages 3/4121 and Insert 3.121C wcre revised to add SR 3.1.6.1 to CTS Insert 3.121C. CTS DOC 3.1 A23 was created to document this change and reads

CTS SR 4.1.1.1.1.b requires that the SDM shall be determined to be within the limits specified in the COLR when in MODE I or 2 with kefT greater than or equal to I at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that control bank insertion is within the limits of Specincation 3.1.3.6. This requirement has been retained in ITS as SR 3.1.6.2. In addition, CTS SR 4.1.1,1.1.c requires that the SDM shall be determined to be within the limits specified in the COLR w hen in MODE 2 with kcffless than I within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving reactor criticality by verifying that the predicted critical control rod position is within the .

' limits of Specification 3.1.3.6. This requirement has been retained in ITS as SR 3.1.6.1, Since the SRs have been changed in format and presentation only, and the original intent was not changed, this is considered to be an administrative change and is consistent with NUREG 1431."

NRC RAI Number NRC lasued Date RAI Status 3.1.6-03 8/5/97 Open NRC Action Required NRC Description of issue 3.l.6 03 Ilp34 Dases for ITS 3.1.6, llackground page il 3.1 39 Figure 113.1.7 1, Control llank Insertion vs. percent RTp, has not been adopted. Thejustification for this difference is that the figure in the Bases duplicates the figure contained in the COLR, and to prevent misapplication and misinterpretation of the Ogure in the COLR. Comment: Figure in STS is for illustrative purposes. Consider using figure identical to figure in COLR.

Comed Response to issue No change. The convention adopted in the Dyron and tiraidwood ITS submittal was to delete " illustration only" figures in the llases to climinate the possibility of an Operator inadvenently using a llases figure in place of an actual figure. (See RAI 2.0-03.) Comed continues to pursue this change.

13

Response to NRC RAI Report 02.sep97 3.1.6-04 8/5/97 Open. Comed Action Required NRC Description of issue 3.1.6-04 JiD Pl9 iTS SR 3.1.6.1 STS SR 3.1.7.1

'Ihc word "Once" has been added to the frequency w hich specifies an interval *Within" a particular time frame (*Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to criticality"). Comment: 1his is a legitimate use of the word "Once" in an SR frequency, and it is a generic change. This should be brought to the Tech Spec Task Force for future action.

Comed Hesponse to issue Comed will submit a traseler at the next Westinghouse Owner's Group (WOG)ITS meeting scheuled for November 19 and 20,1997 to propose the Ilyron and Ilraidwood plant specific change to the WOG. In the interim, Corned continues to pursue this change.

l l

1 14

l Response to NRC RAI Report 02 Sep-97 4

NRC RAI Number NRC losued Date RAI Status

, '3.1.6-05 8/5/97 Open NRC Action Required NRC Description oflasue 3.1.6-05 JFD-CIO ITS SR 3.1.6.2 CTS SR 4.1.3.6 STS SR 3.1.7.2 ne CTS and STS have an increW Su fr~;.cy to ve:ify rod alignment when the rod position deviation monitor is inoperable, nis change has been submitted in 'l STF travell r 110. TSTF.110 final disposition is pending, and has been recommended for rejection.

Comment: Retain increased SR frequency when the rod position deviation monitor is inoperable.

Comed Response to issue No change. TSTF 110 Revision I relocates conditional Surveillance Requirements (Sl!s) for functions with inoperable alarms from the Technical Specl0 cations (TSS) to plant procedures or programs, ne TSTFhstines this by stating that the alarms do not directly relate to the LCO limits. Inoperable alanns do not affect the operability of the TS function. This just10 cation was used and accepted by the Staff during the development of the llWR NUREGs (d. low relocation of the alarm functions from the IlWR Technical Specifications to plant procedures. This justincation was accepted by the Stali prior to the issuance of Revision 0 of the NUREOs. Typically these alarms e monitoring parameters which must be verined met on a specified Frequency (e.g.,12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ). The basis for this Frequacy is justined due to the operability of the alarm function. Whenever this alarm function becomes inoperable, a more frequent SR Frequency interval is performed on

- the parameter (e.g.,4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ). His Frequency continues until the alarm function is restored to operable status. Relocating this detail to plant procedures or programs would not impact the safety signl0cance of the TS requirement since the parameter being monitored is presumed to be operable whenever the alarm becomes inoperabb. He inoperable alarm function does not impact operability of the monitored parameter, in addition, other ITS SR Frequencies are stated in the ITS Ilases to be based on associated alarms or indications which are assumed to be operable or available. (e.g., ne Actions Section of the Ilases for ITS LCO 3.2.4 for Required Action A.2 states "A 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is sumcient because any additional change in QPTR should be relatively slow. Further, this Completion Time is consistent with the Frequency required for the Surveillances with an inoperable alarm or instrumentation." ne Surveillance Requirements Section of the 11ases for ITS LCO 3.8.1 discussing SR 3.8.1.4 states "ne 31 day Frequency is adequate to assure that a sumclent supply

- of fuel oil is available, since low level alreas are provided and facility operators would be aware of any large uses of fuel oil during this period." The Surveillance Requirements Section of the liases for ITS LCO 3.9.5 discussing SR 3.9.5.1 states "De Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sumcient, considering the Dow, temperature, pump control, and alarm indications available to the operator in the control room for monitoring the RilR System." ne Surveillance Requirements Section of the flases for ITS LCO 3.9.6 discussing SR 3.9.6.1 states "The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sumcient, considering the Dow, temperature, pump control, and alann indications available to the operator for monitoring the RilR System.") nese alanns/ indications are not specified in the TSs but typically require additional actions within plant procedures to account for the alarm! indication not being available. Typically alarm response procedures provide guidance for any necessary actions whenever alanns are inoperable. Placing this detail in these procedures ensures that the operator has sufucient guidance to respond to the inoperable alann function and to perform the necessary conditional SRs. (See RAls 3.1.4 02 and 3.2.3-04)

Comed continues to pursue this change.

15

Response is NRC RAI R: port 02 Sep 97 NRC RAI Number NHC losued Date RAI Status 3.1.6-06 8/5/97 Open.NRC Action Required NRC Description of Issue 3.1.6-06 JFD-P1 ITS SR 3.1.6.3 STS SR 3.1.7.3 ITS SR 3.1.6.3 has been editorially rewritten.

Comment: 'Ihese are notjustinable plant speel0c or editorial differences from the STS He STS presentation is clear.

Revise the submittal to adopt the STS presentation.

Comed Response to issue No change. He change was for consistency in parallel construction within the LCO, the Required Actions, and the other two SRs. He LCO states "(Esch control bank) shall be within the (insertion, sequence, and overlap) limits specified in the COLR." The Required Actions and the SRs were constructed similarly (i.e., ' Verify (...) is within the (...) limits specified i

in the COLR."). Required Acitons A.I.I and B.1.1 state " Verify (SDM) is within the limits specined in the COLR." SR 3.1.6.1 states " Verify (estimated critical control bank position) is within the limits specified in the COLR." SR 3.1.6.2 states " Verify (each control bank) is within the (insertion) limits specified in the COLR." Likewise, SR 3.1.6.3 states

" Verify (each control bank not fully withdrawn from the core) is within the (sequence and overlap) limits specified in the ,

COLR." This change has been previr sly approved by the NRC as documented in the Ginna and Vogtle Safety !

Evaluation Reports. Comed continues to pursue this change.

NRC RAI Number NRC issued Date RAI Status 3.1.7 01 8/5/97 Open . NRC Action Required NRC Description ofissue 3.1.7 01 DOC Lil DOC L4 JFD-Cl3 JFD PIO ITS 3.1.7 CTS 3.1.3.2 STS 3.1.8 CTS 3.1.3.2 contair, provisions for one Digital Rod Position Indication (DRPI) per bank inoperable. He STS relaxes this requirement by a90 wing one DRPI per group inoperable. The ITS attempts to takes this a step further and allow all DRPI to be inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; by rewording the ACTIONS NOTE, and replacing CONDITION D, DOCS L4 and Lil do not adequately or accurately address these changes. Justincation for these changes is based upon WOG 73, which has not been approved through the TSTP process. nese changes are not consistent with NI; REG 1431 as stated. Comment:

Revise the subrnittal to adopt the STS wording. Revise the CTS merkup to shode entire proposed change.

Comed Response to issue No change. De NRC, Owner's Group Chairpersons, and utility management a*e scheduling a meeting to discuss generic -

issues (i.e., TSTFs) that involve changes to the improved Technical Specincatio is (ITS). He main foci 9f this meeting is to discuss a schedule for reviewing the TSTFs, who is reviewing the TSTFs, and what direction is to be p.ovided to utilities w hich have submitted ITS and have taken credit for the TSTFs that have not yet been approved. %erefore, the status of this RAI is pending resolution of these issues.

16

Resp::nse to NRC RAI Report 02 selw97 NRC MAI Number NRC issued Date RAI Status 3.1.7 02 8/$/97 Open NRC Action Required NRC Description of Issue 3.1.7 02 liases discussion for ITS 3.1.7 llackground, page 113.147 11ases insert il 3.147A states that the llank Demand Position Indication 5) stem is "not very reliable..." No additional quantiDention has been provided. In contrast with this, llases insert 113.14711 provides substantially more information about the Digital Rod Position Indication System. Comment: Revise the submittal to provide additional information about the reliability of the llank Demand Position Indication System.

Comed Response to issue No change. Clarifying information about the reliability of the llank Demand position Indication System is found in the llackground Section of the 11ases for ITS LCO 3.1.7. In the flases Markups scetion, page 113.147, second paragraph,last sentence, it states "For example, if a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod." Comed continues to pursue this change.

NRC RAI Number NRC lisued Date RAI Status 3.l.8-01 8/5/97 Open NRC Action Required NRC Description of lisue 3.1.8 01 Ilases discussion for ITS 3.1.8 Ilackground, page !! 3.1 63 An insert has been proposed that discusses the beginning oflife (110L) and end oflife (EOL) moderator temperature coefficient (MTC) tests that are performed and the associated Surveillance Requirements that they fulfill. Comment: The I

EOL MTC test is not performed in Mode 2, it is performed at pow er. The physics test exceptions provided by ITS 3.1.8 do not relate to the EOL MTC test. Revise the submittal and delete the reference to the EOL MTC test from the insert, Comed Response to issue ITS and NUREO were revised to delete the reference to the EOL MTC test from the insert and to delete the reference to SR 3.1.3.2 from the insert 'the insert now reads "The Moderator Temperature Coe(Ticient (MTC) at lleginning Of Life (llOL) is determined from the measured 11C. This test satis 0es the requirement of SR 3.1.3.1."

l 17

Response to NRC RAIReport 02 sep-97 NRC RAI Number NRC lasued Date RAL Status 3.2.1 01_ 8/5/97 Open . NRC Action Required NRC Description of issue 3.2.1 01 JFD P4 ITS SR 3.2.1.1 and SR 3.2.1.2 Bases discussion for ITS SR 3.2.1.1 and SR 3.2.1.2 In the STS the Frequency for these Surveillances state in part, "Once within [12] hours after achieving equilibrium conditions after exceeding, by greater than or equal to 10% RTP, the Thermal Power at w hkh Tcq(Z) was last verified." In contrast, the ITS proposes to utilize 20% instead of 10%. The explanation that has been provided for this difference is that the tunem licensing basis which utilites Fxy methodology for a similar surveillance utillies the 20% value. STS SR 3.2.1.2 Note 2 of STS 3.2.1 A (Fxy methodology) utillies 20%. Ilowever, the FQ methodology has been proposed for the STS not the Fxy methodology. Comment: This is not ajustifiable plant specific or editorial difTerence. Revise the submittsi to conform to the STS.

Comed Response to issue ITS and NUREG t.COs and liases were revised to change "20% RT P" in ITS SR 3.2.1.1 and SR 3.2.1.2 to "10% RTP " As a result,l.CO /FD 3.2 P4 and liases JFD 3.2 P7 were changed to *Not used."

NRC RAI Number NRC Issued Date RAI Status 3.2.1 02 8/5/97 Open. Comed Action Required NRC Description oflisue 3.2.102 ~ JFD "9 ITS 3.2.1 Required Action 11.1.1 The ITS proposed Required Action D.l.1 states," Reduce Thermal Power below the Allowed Power Limit (APL)." This proposed statement is provided as an option to the STS Required Action of, " Reduce Thermal Power greater than or equal to 1% RTP for each 1% FWQ(Z) exceeds limit." Comment: The proposed Required Actions for Condition B are under review. Submit a TSTF change request for this change.

Comed Response to lasue Comed will submit a traveler at the next Westinghouse Owner's Group (WOG)ITS meeting scheduled for November 19 and 20,1997 to propose the Byron and Braidwood plant specific change to the WOG. In the interim, Comed continues to pursue this change.

18

I RGsponse to NRC RAI Report c2.sep-97

~NiifRAI Number NRC losued Date liAlStatus 3.2.1 03 8/$/97 Open . NRC Action Required NRC Ikseription of issue 3.2.1 03 JrD P9 113 3.2.1 Condition A Note flases discussion for ITS 3.2.1 Actions, page B 3.2 15, insert 113.2 15 A A note has been added to Condition A ofITS 3.2,111 and associated liases that stipulates that Required Action A.4 must be completed whenever Condition A is entered. Comment: This proposed NOTE is redundant to the Completion Time for Required Action A.4, and is unnecessary, Comed Response to issue ITS and NURLO LCO 3.2.1 and Bases, and CTS Markups, were revised to delete the Note that was added in Revision A of the II$ submittal. As a result, LCO JfD 3.2 P9 and liases JFD 3.2 P9 were revised to delete the first sentence which states "NUREO Condition A of LCO 3.2.111 and associated liases were rewised to add a note requiring that Required Action A.4 be completed whenever Condition A is entered even though the requirements of the LCO may have been met."

NRC RAI Number NRC lisved Date RAI Status 3.2.2 01 8/5/97 Open. Comed Action Required NRC Ikseription of issue 3.2.2 01 JFD P5 ITS 3.2.2 STS 3.2.2 ITS deletes Required Action to restore llot Channel factor to within limits.

Comment: Submit TSTF request to adopt change.

Comed Response to issue Comed will submit a traveler at the next Westinghouse Owner's Group (WOO)ITS meeting scheduled for November 19 and 20,1997 to propose the flyron and litaldwood plant specific change to the WOO. In the interim, Comed continues to pursue this change.

19

l . ..

Respors) to NRC RAI Report 02 sep 97 i

3RC RAI Number NRC lasued Date RAI Status I

3.2.3 01 8/5/97 Open NRC Action Required NRC Description oflisue l 3.2.3 01 JfD P8 ITS 3.2.3 Actions, Note for Condition C Bases discussion for 11S 3.2.3 Actions, page 113.2 33 in the STS Condition C contains a note that states,

Required Action C.1 must be completed w henever Condition C is entered." 1his note has not been adopted in the ITS. The corresponding STS Bases discussion also has not been adopted.

Comment: 1his is not a justillable plant specific or editorial difTerence. Revise the submittal to conform to the STS.

Comed Response to issue ITS and NUREO LCO 3.2.3 and llases, and CTS Markups, were revised to adopt the Note in Condition C, As a result, LCO JfD 3.2 P8 and liases JfD 3.2 P16 were changed to "Not used." In addtion, CTS DOC 3.2 MI was created to document this change and reads " CTS Action 3.2.1.b.1 aquires with TilERMAL POWER less than 90% but equal to or greater than 50% of RATED TilERMAL POWER, redu';c TilERMAL POWER to less than 50% of RATED TilERMAL POWER within 30 minutes. ITS 3.2.3, Reqaired Action C contains the same requirement but adds a Note stating,

" Required Action C.1 must be completed w henever Condition C is entered." The ITS also provides an additional part to Condition C stating,OR TilERMAL POWER <90% RTP and greater than or equal to 50% RTP with AFD not within the acceptable operation limits, reduce TilERMAL LOWER to < $0% RTP within 30 minutes." Although an "OR" statement, this is considered to be more restrictive since, if chosen, will require TilERMAL POWER to be reduced to less than or equal to $0% RTP, even if the AFD is restored to within limits prior to completing the RTP reduction to less than or equal to 50%.1his change is consistent with the NUREG 1431."

NRC RAI Number NRC lasued Date RAI Status 3.2.3 02 8/5/97 Open NRC Action Required NRC Description oflisue 3.2.3-02 Ilases discussion for ITS 3.2.3 llackground, page B 3.2 28 1he STS description of target flux difference detenninations stat es that Control Bank D should be inserted near its normal position (i.e., greater than or equal to 210 steps withdrawn) for stWv state operation at high power levels. The ITS has not adopted the parenthetical phrase "(l.c., greater than or equal to 210 stcps withdrawn)". Comment: This is neither a justifiable plant specific difTerence nor a change that adds clarity. Revise the submittal to conform to the STS.

Comed Response to lasue ITS and NURCO were revised to adopt the phrase *(i.e., > or = 210 Steps withdrawn)" and the Bases Markup teferencing liases JFD 3.2 Pil was deleted, it should be noted that Byron and Braidwood do not necessarily operate with Control llank jCB) D at 210 steps withdrawn. The CB D position varies with core flux.

20

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R:sponse to NRC RAI Report 02 sep.97 1 =

NRC RAI Number

=-=======:==:-_======================-._:=~==z NRC issued Date RAI Str.tus l

l 3.2.3-03 8!5/97 Open. Comed Action Required NRC Description of lasue 3.2.3-03 Bases discussion for ITS LCO 3.4.3, page 113.2 3 i STS liases iigure 113.2.3A 1, Asiall'lus Difference Acceptable Operation Limits and Target Band Limits as a l' unction of Rated Thermal Power The S1S states that l'igure H 3.2.3 A 1 shows a typical target band and typical Al'D acceptable operation limits. This statement and the Agure have not been adopted by the ITS Instead, the 11S proposes the COLR to contain the Ogure showing the target band and AI'D acceptable operating limits. Comment: Suggest including copy of actual Ogure in Ilases.

Comi:d Response to issue No change.1he convention adopted in the Byron and litaldw ood ITS submittal was to delete

illustration only" Ogures in the liases to eliminate the possibihty of an Operator inadvertently using a Bases Ogure in place of an actual Ogure. (See RAI 2.0-03.) Comi d: continues to pursue this change. (Correction Note to NRC Description ofissue: Reference should be to 11S LCO 3.2.3, not 3.4.3.)

2l

i 1

7- -_._.--_7-.._7 _ . . . _ . . _ , . _ . . _ . . _ . _ _ , __ _

Respo:Se t: NRC RAI Report 02 sep 97 j NRC RAI Number NRC issued Date RAI Status 3.2.3 04 8/5/97 Open Comed Action Required NRC Description of issue 3.2.3-04 DOC LA4 JFD C9 JFD Cl ITS SR 3.2.3.2 C1SSR4.2.1.4 SIS SR 3.2.3.2 & SR 3.2.3.3 ITS combines details of STS SR 3.2.3.2 & SR 3.2.3.3 into one SR 3.2.3.2. Some STS details are removed from the ITS.

These changes are based upon T STF Il0.

Comments: 1STF Ilo has not been approved and is recommended for rejtetion. TSTF 24 has been rejected. Retain STS detail in ITS.

Comed Response to issue Regarding TSTF 24: TSTF 24 was withdrawn from the 11S submittal. Action item #31 of the generic traveler tracking system used by the Westinghouse Owner's Group (WOG) revises NUREG LCO 3.2.1 to correct errors and to reDect the majority of the core monitoring methodology used by Westinghouse plants. WOG members have reviewed this traveler and agreed to the proposed changes. The trascler is currently under review by the other Owner's Groups (OGs). lherefore, the status of this RAl is pending review by the OGs. Regarding TSTF-Il0: No change. TSTF 110 Revision I relocates conditional Surveillance Requirements (SRs) for functions with inoperable alanns from the Technical Speci0 cations (TSs) to plant procedures or programs. The TSTFjustifies this by stating that the alanns do not directly relate to the LCO limits.

Inoperable alanns do not afTect the operability of the TS function. Thisjustification was used and accepted by the Staff during the deselopment of the IlWR NUREGs to allow relocation of the alarm functions from the llWR Technical Specifications to plant procedures,1hisjusti0 cation was accepted by the Staff prior to the issuance of Revision 0 of the NURI:Gs. Typically these alanns are monitoring parameters which must be verified met on a specified Frequency (e.g.,12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ). The basis for this Frequency isjustified due to the operability of the alarm function. Whenever this alarm function becomes inoperable, a more frequent SR Frequency interval is perfonned on the parameter (e g.,4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ).1his Frequency continues until the alann function is restored to operable status. Relocating this detail to plant procedures or programs would not impact the safety signincance of the TS requirement since the parameter being monitored is presumed to be operable w henever the alarm becomes inoperable. The inoperable alarm function does not impact operability of the monitoicd parameter. In addition, other ITS SR Frequencies are stated in the ITS Bases to be based on associated alanus or indications which are assumed to be operable or as allable. (e.g.,lhe Actions Section of the Bases for ITS LCO 3.2.4 for Required Action A.2 states "A 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is suf0cient because any additional change in QpTR thould be relatively slow. Further, this Completion Time is consistent with the Frequency required for the Surveillances with an inoperable alann or instrumentation " 1he Surveillance Requirements Section of the Bases for ITS LCO 3.8.1 discussing SR 3.8.1.4 states "The 31 day Frequency is adequate to assure that a sufTicient supply of fuel oil is available, since low level alanns are provided and facility operators w ould be aware of any large uses of fuel oil during this period." The Surveillance Requirements Section of the Bases for ITS LCO 3.9.5 discussing SR 3.9.5.1 states "The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considenng the flow, temperature, pump control, and alarm indications available to the operator in the control room for monitoring the RilR System." The Suncillance Requirements Section of the Bases for ITS LCO 3.9.6 discussing SR 3.9.6.1 states The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is suflicient, considering the liow, temperature, pump control, and alann indications available to the operator for monitoring the RilR System.") These alarms / indications are not specified in the TSs but typically require additional actions within plant procedures to account for the alann' indication not being available.

Typically alann response procedures provide guidance for any necessary actions whenever alarms are inoperable. placing this detail ia these procedures ensures that the operator has sufficient guidance to respond to the inoperable alarm function and to perfonn the necessary conditional SRs (See RAls 3.1.4 02 and 3.1.6-05) Comed continues to pursue this change.

22

i o *.

~

] Response to NRC RAI Report 02 ssp.97 NRC RAI Number NRC losued D$e RAI Status 3.2.3 05 8/5/97 Open. NRC Action Required

NRC Description of lisue 3.2.3 05 JFD C8 I

Ils 3.2,3 Action D '

, CTS 3/4.2.3 l STS 3.2.3 Action D TSTFll2 ,

ITS 3.2.3 omits STS 3.2.3 Action D as proposed by TSTF 112 which was superseded by TSTF 112 Revision 1; Revision I to TSTF ll2 has been approved but retains a modined Action D in STS 3.2.3 (the Note was removed). Comment: Revise the submittal to adopt the modined Action D.

Comed Response to issue ITS and NUREO LCO 3.2.3 and Dases, and CTS Markups, wcre revised to incorporate TSTF il2 Revision 1 which retains Condition D, but deletes the Condition D Note. As a result, CTS DOC 3.2 M2 was created to document this change and ,

reads "NUREO LCO 3.2.3, Condition D has been added. NUREO Condition C requires that with TilERMAL POWER <

90% RTP and greater than or equal to 50% RTP with eumulative penalty deviation time > 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , OR TilERMAL POWER <90% RTP and greater than or equal to 50% with the AFD not within the acceptable operation limits, reduce TilERMAL POWER to < $0% RTP within 30 minutes, in the event that Condition C cannot be 4 met, Condition D is entered, Condition D states,

Required Action and associated Completion Time for Condition C not met, reduce TilERMAL POWER to < 15 % RTP within 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months ." CTS Action 3.2,l.c requires,"With the indicated AFD outside of the required target band for more than I hour of cumulative penalty deviation time during the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

and with TilERMAL POWER less than 50% but greater than 15% of RATED TilERMAL POWER, the TilERMAL !

POWER shall not be increased equal to or greater than 50% of RATED TilERMAL POWER until the indicated AFD is l within the required target band." *lhe CTS would allow indennite operation in this condition until the AFD is restored to '

within the target band. The ITS however, would require that the RTP be < 15% RTP within 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months . This is a more ,

restrictive change since the iTS only allow s operation in this condition for 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months instead of an indefinite period of time.

This change represents a more restrictive change and is consistent with NUREG 1431 as modined by NRC approved TSTF.

I12, Revslon 1." In addition, liases JFD 3.2 C8 was revised to reference TSTF il2, Revision 1. (Correction Note to NRC Desciiption of issue: Reference should be to CTS 3/4.2.1, not CTS 3/4.2,3.) i NRC RAI Number NRC issued Date RAI Status 3.2.3 06 8/5/97 Open Comed Action Required NRC Description oflisue 3.2.3 06 JFD CIO ITS 3.2.3 CTS 3.2.3 1hc ITS combines LCO NOTES per proposed WOO 75. Comment: Submit TSTF request for aporoval.

Comed Response to issue No change. No action required. This revision is in accordance with NRC Approsed generic traveler TSTF 164 (WOG 75 Revision 1).

i I

23

a< <.

R':sponse to NRC RAI Report 02 Sep.97

~NRC RAI Number NRC issued Date RAI Status 3.2.4 01 R/5/97 Open . NRC Action Required l

NRC Description of lasue i 3.2.4-01 JFD Pl4 11S3.2.4 STS 3.2.4 1

ne 113 revises Required Action A.4 Completion Time by adding detail about the need for achieving equilibrium conditions. Comment: P14 adds unnecessary detail to the CT, Remove detail and include in Bases.

Comed Response to lasue WOO 93 Revision I revises NUREO LCO 3.2.4 and associated 11ases to provide more appropriate Required Actions and Surveillance Requirements when QPTR is exceeded. A proposed change in WOO 95 Revision I modines the first performance Frequency (i.e., NURFO Required Action A 3 Completion Time) to require the peaking factors to be verified l

within "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions from a TilFRMAL POWER reduction per Required Action A.I."

A signincant fraction of the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months could be spent waiting for the plant to stabilize at the new power level, leaving insufficient time to measure and analyze the peaking factors or resulting in the peaking factors being measured w hen the i plant is not stable, thereby yleiding inaccurate information. Since the peaking factors are of prime importance, the proposed change will allow suf0clent time to obtain an accurate measurement. Furthermore, literal compliance with ITS and ITS

'ules of usage would not permit this allowance to achieve equilibrium to be added as detall to the 11ases only. WOO '

members have reviewed this traveler and agreed to the proposed changes. ne traveler is currently under review by the ,

other Owner's Groups (OGs). In the interim, Comed will continue to pursue this change. (Correction Note to NDC ,

Description ofIssue: Reference should be to Required Action A.3, not Required Action A.4)

NRC RAI Number NRC lasued Date RAI Status ;

3.2.4 02 8/5/97 Open.NRC Action Required NRC Description of issue 3.2.4-02 JFD C2 JFD Cil ITS 3.2.4 STS 3.2.# .

~ ,

ne ITS incorporates editorial changes in the wording of Required Actions, based upon proposed TSTF 25. Comment:

TSW.25 has been rejected. Retain STS wording of QPTR Required Actions. Proposed changes do not add clarity.

Comed Response to issue No change. Regarding TSTF.25: TSTF 25 was withdrawn from the ITS submittal. WOO-95 Revision I revises NUREO LCO 3.2.4 and associated llases to provide more appropriate Required Actions and Surveillance Requirements when QPTR is exceeded. A proposed change in WOO 95 Revision 1.modines NUREO Required Action A.6 Completion Time to -

require the peaking factors to be verified within *24 hours after achieving equilibrium conditions above the limit of Required Action A.I." A signincant fruction of the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months could be spent waiting for the plant to stabilize at the new power level, leaving insullicient time to measure and analyze the peaking factors or resulting in the peaking factors being measured when the plant is not stable, thereby yiciding inaccurate information. Since the peaking factors are ofi ime importance, the proposed change will allow sufficient time to obtain an accurate measurement. WOG members have reviewed this traveler and agreed to the proposed changes. The traveler is currently under review by the other Owner's Groups (OGs), in the interim, Comed will continue to pursue this change.

24

I 1

Attachment 2 Comed Response to 8/5/97 NRC RAI ITS Submittal Affected Page List i Maredtits\rai's'4397,R2W7tte doc 4

l

. ( $ a Attachment 2 Comed Response to August 5. 1997 NRC RAI ITS Submittal Affected Page List RAI # BYRON PtWD BYRON BRdD CTS DOC LCO M/V LCO Basts Bast $

115 115 d 5 M/0 0 5 M/u Jr0 M/V .)F D 1.0 01 X X 14 14 x x x k/A N/A 1,0 02 1.2-2 1.2 2 Insert insert 1.2 2 N/A X P2 N/A 1.2 3 1,2 3 1 9A 1 9A 1.2 3 1.3 3 1.3 3 Pages Pages 1.3 3 1.3 4 1.3 4 2 21 2 21 '34 1,}6 1.3 6 .3 6 1.J B 1.3 8 .3 8 1.3 9 1.3 9 ..39 1,310 1,3 10 1.3 10 1.3 12 1.3 12 '

. 3 12 1.4 2 ),4 2 .4 2 1.4 3 1.4 3 43 1.4 4 1.4 4 .4 4 1.44 1,44 ng 1.0 03 (3) (3) (3) (3) (1) (3) (3) N/A N/A 1.0 04 X X Insert insert A13 1.14 (3 N/A N/A 14A 14A ng P6 1.0 05 (3) (3) (3) (3) (3) (3) (3) N/A N/A 1.0 06 1.4 4 1.4 4 Insert insert X 1.4 4 X N/A N/A 1 9A 1 9A Pace 70 Page ?0 1.0 07 (4) (4) (4) (4) (4) (4) (4) N/A N/A 2,0 01 2.0 2 2.0 2 22 2 2a X Insert X X X

? 0 ?A 2.0 02 B? 0 ? B? 0 ? u 1 x r r B? 0 ? r 2.0 03 (1) (1) (1) (1) (1) (1) (1) (1) (1) 2.0 04 X X X X X X Y X 07 P.0 05 B? 0 9 B? 0 9 X X X X X B? 0 9 X 2.0 06 (?) (?) (?) (?) (?) (?) (?) (?) (?)

, 3.1 01 (2) (?) (?) (?) (?) (?) (?) (?) (?)

3.1,1+ B3.1 6 B3.14 X 01 X X X X B3.1 6 1 3.1.2 (2) (2) (2) (2) (2) (2) (2) (2) (2) 01 3.1.3- B3.1-22 B3.1 22 X X X .X X - B3.1 23-. P6 01 3.1.4- (2) (2) (2) (2) (2) (2) (2)- (2) (2) 01 3.144' (3) (3) (3) (3) (3) (3) (3) (3) (3) 02

- 1 : \ sha red \ i ts\ ra i 's\ 8597 \8597pg s . wpf

. s>e Attachment 2 Comed Response to August 5, 1997 NRC RAI Ils Submittal Atfected Page List RAI i BYRON- BRWD BYRON BRWD CTS DOC LCO M/V LCO BASES BAST $

tis 11s tis M/u c1s M/u arD M/V JfD 3.1.$. 3.1 11 3.1 11 1 1 X- 3.1 12 P13 B3.1-36 X 01 B3.1 41 B3.1 41 !

Insert i B3 1-36A !

3.1.$. 3.1 1 3.1 1 l X X X 3.1 1 C12 X X !

02 3.1 4 3.1 4 .1 5 3.1 11 3.1 11 .1 12 3113 3113 1 14 31 3.1 13 3,1 13 X X X 3.1 14 P14 B3.1 42

i .6 X Wi%

3.1.6 X X 3/4 1 1 3/4 1 1 A23 X X X X 02 3/4 1 21 3/4 1 21

$!h$c $!hkt 3.1.6- (1) (1) (1) (1) (1) (1) (1) (1) 03 (1) 3 1.6+ _(2) (2) (2) (2) (2) (2) (2) (2) (2) 3.1.6 (3) (3) (3) (3) (3) (3) (3) (3)

Os (3) 3.1.6 (1) (1) (1) (1) (1) (1) (1) - (1) 06 (1) 3.1.7 (3) (3) (3) (3) (3) (3) (3) (3) 01 (3) 3.1.7 (1) (1) (1) (1) (1) (1) (1) (1) of (1) 3.1,8- B3.1 63 B3.1 63 X X X 01 X X B3.1-63 X

3. 2.1. - 3.2 3 3.2 3 jnsert insert 3.2 6 F4 X B3.2 16 P7 01 3.2 5 3.2 6 s.2 7A 3.2 7A 3,2 6 B3.2-17 B3.2 8 B3.2 8 B3.2 9 B3.2 19 B3.2 9 B3 211 B3 ? 11 3.2.1- (2) (2) (2) (2) (2) (2) (2) (2) 01 (2) 3.2.1- 3.2 1 3.2 1 3/4 2 4 3/4 2 4 X 3.2 4 P9 B3.2 15 P9 03 B3.2 5 B325 Insert B3 2 lhA p;2.2- (2) (2) (2) (2) . (2) (2) (2) (2) (2) 3.2.3 3.2 10 3.2 10 3/4 2 1 3/4 2-1 M1 3.2 13 P8 B3.2 33 P16 01 B3 7 ?B B3 7-?B 3.2.3- B3.2 21 B3.2 21 X X X X X B3.2 28 X 07 3.2.3' (1) (1) (1) (1) (1) (1) (1) (1) (1) 03 1:\ shared \its\rai's\8597\8597pgs.wpf

os *e Attachment 2 Comed Response to August 5. 1997 NRC RAI ITS Submittal Affected Page List RAI f BiCN BRC BYRON BRc CTS DDC LCO M/V LCO EASIS ITs BASLS ils cts M/u (Ts M/V JF D M/u Jr0 3 2.3 (3) (3) (3) (3) (3) (3) (3) (3) (3) 3.2.3 3.2 10 3210 3/4 2 1 3/4 2 1 M2 3.2 14 C8 B3 2 33 (8 05 83 7 ?R B3 2 ?B B3 ? 34 3.2.3- (1) (1) (1) (1) (1) (1) (1) (1) 06 (1) 3.2.4 (3) (3) (3) (3) (3) (3) (3) (3) 01 (3) 3.2.4 (3) (3) (3) (3) (3) (3) (3) (3) 02 (3) 1:\ shared \its\rai's\8597\8597pgs.wpf

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ML20216C020

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