Text

Forwards Response to NRC RAI Re Questions & Comments Stemming from NRC Partial Review of Util Request Ltr to Amend Current Tech Specs for Byron Units 1 & 2 & Braidwood Units 1 & 2
	ML20217E966
Person / Time
Site:	Byron, Braidwood
Issue date:	04/16/1998
From:	Schwartz G; COMMONWEALTH EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	RTR-NUREG-1431 NUDOCS 9804280014
	Download: ML20217E966 (66)
	v • d • e

I Gemnumw calth lilivan Gimpany tirak!wtxed Generating $tation Route aI, ihm H1 liraces ille,11. G h0'-%19 i

Tel 815-458 2801 comr:d i

April 16,1998 United States Nuclear Regulatory Commission r

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 i

Commonwealth Edison's (Comed's) Response to the NRC's Request for Additional Information (RAI) for improved Technical Specifications (ITS)

Section 3.4 j

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References:

G. Stanley and K. Graesser (Comed) to NRC letter dated December 13,1996 The purpose of this letter is to transmit Comed's Response to the NRC's RAI for ITS Section 3.4. The responses to the RAI questions are contained in Attachment 1.

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

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9804280014 980416

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r U.S. Nuclear Regulatory Commission April 16,1998 -

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.

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

Sincerely,

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G. K. Schwartz Station Manager Braidwood Nuclear ower Station GKSM8025GKS. doe I

' Attachment 1: Response to NRC RAI Report cc:

Regional Administrator - Region 111, NRC Byron Project Manager - NRR Braidwood Project Manager - NRR i -

Senior Resident inspector - Braidwood Station Senior Resident inspector - Byron Station Office of Nuclear Facility Safety - IDNS L

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RcsponSe to NRC RAI Dated 03/09/98 16-A pr-98 I

NRC RAI Number NRC issued Date RAI Status 3.4.1-01 3/9'98 Open - NRC Action Required d

NRC Description of issue DOCS L4 and Ll I CTS 3/4.2.3 Action a.2 CTS 3/4.2.5 Action j

ITS 3.4.1 Action 11 DOC 1.4 is written tojustify the same change made to both CTS 3/4.2.3 Action a.2 and CTS 3.2.5 Actions. CTS 3.2.3 Action a.2 requires the reduction of TilERMAL POWER to < 50?h RTP and the reduction of the Power Range Neutron Flux-liigh Trip Setpoint to 55'b RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when RCS total flow is not within limit. CTS 3.2.5 Action requires the DNil related parameters restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or to reduce TilERMAL POWER to less than 59b of RATED TilERM AL POWER within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Iloth CTS Actions and 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limit are changed to be ITS 3.4.1 Condition B which specifies a Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to reach Mode 2. DOC Ll1 is written to justify the same change but only to CTS 3.2.5 Actions. Comment: It is recommended that L4 justify Action 3.2.3 only and L11 continue tojustify Action 3.2.5 which would not require revision of the CTS markup.

Comed Response to issue Comed will reuse DOC 3.4.L4 to only justify CTS Action 3.2.3.a.2. DOC 3.4-L4 will be revised to state," CTS Action 3.2.3.a.2 requires that when the RCS flowrate is outside the region of acceptable operation, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reduce TilERM AL POWER.. within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ." NUREG LCO 3.4.1, Condition A states that with one of the DNB parameters not within limits, a Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is provided to restore the parameter to within limits. In the event that Condition A is not met Condition B requires the plant be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS revises the CTS l

Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and therefore is considered a Less Restrictive change. Using the general rules of applicability, the unit must be placed in a Mode of non-applicability, which in this case is Mode 2. Reaching MODE 2 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is consistent with other LCOs that require the plant to be placed in MODE 2 from MODE 1. Therefore, the V)

Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable to reach the required unit conditions in an orderly manner." DOC 3.4-LI1 will

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be revised to state, " CTS Action 3.2.5 states that with any of the DNB related parameters exceeding its limit. restore the parameter to w ithin its limit within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , or reduce THERMAL POWER to less than 596 of RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

NUREG LCO 3.4.1, Condition A states that with one of the DNB parameters i.at within limits, a Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is pros ided to restore the parameter to within limits. In the event that Condition A is not met Condition B requires the plant be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS revises the CTS Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and therefore is considered a Less Restrictive change. Using the general rules of applicability, the unit must be placed in a Mode of non-applicability, which in this case is Mode 2. Reaching MODE 2 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is consistent with other LCOs that require the plant to be placed in MODE 2 from MODE 1. Therefore, the Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable to reach the required unit conditions in an ordtriy manner." These changes will be provided in our comprehensis e llS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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r RcSponSe to NRb RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC Issued Date

~ RAI S' atus t

3.4.1-02 3/9/98 Open - NRC Action Required NRC Description of issue DOC L35 JFD C6 CTS 4.2.3.5 CTS 4.2.3.5 requires the determination of RCS total flow rate by a precision heat balance measurement after each fuel loading and states that "The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months completion time provisions of Specification 4.0.3 are not applicable" ITS SR 3.4.1.4 -

l requires a precision heat balance measurement every 18 months and allows for the provisions ofITS SR 3.0.3 to apply.

l DOC L35 as submitted states a precision heat balance measurement will be perfomied per ITS SR 3.4.1.4. This is i

acceptable; however, JFD C6 deletes the precision heat balance measurement. Also JFD C6 refers to TSTF-105 w hich has been rejected. Comment: Revise the submitta! to adopt the STS and retain the CTS requirements. Make the justifications for these tw o CTS changes consistent.

Comed Response to issue Comed will withdraw TSTF-105 changes from the ITS submittal and retain "by precision heat balance that" in ITS SR I

3.4.1.4. CTS DOC LA18, LCO JFD C6, and Bases JFD C6 will be deleted. This change will be provided in our j

comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

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NRC RAI Number NRC issued Date RAI Status 3.4.1-03 3/9/98 Open - NRC Action Required l

NRC Description of issue l

DOC A1.1 CTS 4.2.3.1 CTS 4.2.3.1 states "The provisions of Specification 4.0.4 are not applicable." This CTS requirement is deleted with an l

editorial Ai justification rather than with a specific technicaljustification. Comment: Please provide a technical justification for this CTS change.

Comed Response to issue DOC 3.4-A3 discusses the deletion of this statement. The CTS Markup for CTS SR 4.2.3.1 will be revised to reflect the l

correct reference to DOC 3.4-A3. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

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Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC Issued Date

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RAI Status 3.4.1-04 3/9/98 Open - NRC Action Required NRC Description of Issue JFD P2 JFD BP2 ITS 3.4.1, Applicability Note The Applicability Note is proposed to be moved to a place following the LCO statement as an editorial enhancement to preclude misinterpretations ofITS SR 3.0.4. This technical basis is unacceptable. This change occurs frequently in this submittal; therefore, this is a generic change and it should be submitted for review under the STS generic change process.

Comment: Revise the submittal to adopt the STS format. The response to this comment should be global over the entire submittal.

j Comed Response to issue No change. Because the relocation of the Note from the Applicability to the LCO has been approved on a plant specific basis for previous submittals (e g., Ginna, Zion, and Vogtle), the WOG determined that this change was below the threshold for a generic change. Therefore, af of the Notes in the Applicability section 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

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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 of ITS LCOs in w hich this convention was 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 which the Note was moved by a TSTF: 3.2.3,3.5.2, and 3.5.3 (SR Note mos ed to LCO); LCOs in w hich the Note was added by a plant specific change: 3.7.12,3.8.5, and 3.9.4; LCOs in which the Note was added by a TSTF: 3.6.3, Comed continues to pursue this change. (See RAls 3.1.5-01,3.1.6-01, 3.4.10-03, and 3.4.12-01 item b.)

NRC RAI Number NRC Issued Date RAI Status 3.4.1-05 3/9/98 Open - NRC Action Required NRC Description of Issue JFD BPI Bases discussion of Applicable Safety Analyses, STS page B 3.4-2 In Applicable Safety Analyses, the second and third sentences regarding the DNB design criterion are not adopted. Why not state the plant specific DNB design criterion as the acceptance limit? Also, this is a not an editorial change but a technical change without a specific technicaljustification. Comment: Revise the Bases to be consistent with the STS.

Comed Response to issue Comed will revise the Bases to be consistent with the STS, incorporating the plant specific value of"1.5" in the brackets.

This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC Issued Date RAI Status 3.4.1-06 3/9/98 Open - NRC Action Required NRC Description of Issue JFD IIP 45 Ilases discussion of Applicable Safety Analyses. STS page 13 3.4-2 In the Applicable Safety Analyses, the second paragraph has been replaced with the insert B3.4-2A. Why do the LCO values not match the value assumed in the safety analyses and reported measurement accuracy in the first and the second paragraph. For example, it appears that the pressurizer limit LCO value should be > 2233.7 (2207 + 26.7) with the reponed measurement accuracy. Comment: Please revise the text in the insert to clarify the addition of this plant speci6c text to the flases.

Comed Response to issue No change, ITS LCO 3.4.1 states, "RCS DNB parameters for pressurizer pressure,. shall be within the limits specified below: a. Pressurizer pressure 2219 psig. " The Applicable Safety Analyses Section of the Bases for ITS LCO 3.4.1 states," Safety Analyses assumed a value of 2207 psia. This value is bounded by the LCO value of 2219 psig assuming a measurement accuracy of less than 26.7 psia." The NRC RAI asked why the pressurizer pressure LCO value did not match the liases value, stating that the LCO value should be 2233.7 based on using the safety analyses value of 2207 + 26.7. It is true that adding the safety analyses value (2207 psia) to the measurement accuracy ofless than 26.7 psia yielding a total of 2233.7 psia. The pressurizer value in the ITS is 2219 psig. Therefore,2233.7 psia - 14.7 = 2219 psig. Therefore, the LCO value matches the Bases value, and no change is required.

NRC RAI Number NRC Issued Date RAI Status 1

3.4.1-07 3/9/98 Open-NRC Action Required NRC Description of issue JFD IIP 51 Bases discussion of Actions, STS page il 3.4-3 i

t in the Bases discussion of Required Action A.1, all three paragraphs omit portions of the STS text. The deleted text explains the purpose of the Required Actions. JFD PSI states provides no explanation for the these omissions. Comment:

Revise the Bases to conform to the STS.

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Comed will revise the Bases to conform to the STS. This change will be provided in our comprehensive ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 e

NRC RAI Number NRC issued Date RAI Status 3.4.2-01 3/9/98 Open NRC Action Required NRC Description of Issue DOC LA29 DOC M9 JFD C2 (Based on superceded TSTF-27 Rev i ?)

CTS 4.1.1.4.b STS SR 3.4.2.1 i

DOC LA29 is not shown on the CTS markup. In addition, the text of LA29 contradicts JFD C2 w hich is based on TSTF-27 (replaced by Rev 2 which is penaing). Comment: Withdraw the change to CTS 4.1.1.4.b and adopt STS SR 3.4.2.1.

j Comed Response to issue DOC 3.4-M9 will be revised to state, " CTS 4.1.1.4.b requires the verification of the RCS average temperature every 30 minutes when the reactor is critical and the Reactor Coolant System Tavg is less than 557 F with the Tavg-Tref deviation alarm not reset. The proposed ITS SR 3.4.2.1 requires verification of the RCS average temperature every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . " The

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CTS Markup will be revised such that DOC 3.4-LA29 refers to the Deviation Alarm, and DOC 3.4-M9 only refers to the i

"12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ." This is consistent with similar changes in TSTF-27 for ITS LCOs 3.2.3 (CTS SR 4.2.1.1.b) and 3.2.4 (CTS SR 4.2.4.1.b). This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. Comed continues to pursue this change.

l NRC RAI Number NRC issued Date RAI Status 3.4.2-02 3/9/98 Open - NRC Action Required NRC Description ofissue JFD BPI Bases for Applicability ofITS 3.4.2, STS markup pages B 3.4-7 and B 3.4-8 The ITS Bases does not adopt the second paragraph of the Bases for the Applicability of STS 3.4.2 based upon an editorial l

change justification. This omission, however, is a technical change and has not been adequately justified. Furthermore, this l

paragraph is applicable to Byron and Braidw ood because STS 3.1.10 (equivalent to CTS 3.10.3) is adopted as ITS 3.1.8.

Comment: Revise the Bases to adopt the omitted STS paragraph.

Comed Response to issue Comed will revise the Bases to adopt the omitted STS paragraph. This change will be provided in our comprehensive ITS l

Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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l Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC Issued Date RAI Status 3.4.3-01 3/9/98 Open NRC Action Required NRC Description of issue DOC MI1 CTS 3.4.9.1 Action ITS 3.4.3 Action C CTS 3.4.9.1 Action requires an engineering evaluation to be performed, in accordance with the Applicability of"At all times", whenever the pressure or temperature limits for the RCS have been exceeded; however, there is no explicit time limit provided to complete this evaluation. If these limits have been exceeded with the unit in a condition other than in Mode 1,2,3 or 4 Required Action C.I for ITS 3.4.3 requires action be initiated immediately to restore com; liance with the limits for the RCS and Require Action C.2 requires the determination that the RCS is acceptable for continued operation prior to the unit entering Mode 4. The DOC states " CTS 3.4.9.1 does not specify any required action whenever the pressure or temperature limits for the RCS have been exceeded in a speciDed condition other than in Mode 1,2,3, or 4, or Mode 5 with RCS pressure 500 psig." As statement appears to be in error since the CTS has the same Action regardless of the unit's operating Mode, if the rcd limits are exceeded. Comment: Please revise the submittal with a revised technical justi6 cation.

Comed Response to issue Comed agrees and will revise DOC Mil to state, " CTS LCO 3.4.9.1 does not specify a completion time for whenever the pressure or temperature limits for the RCS have been exceeded in a speci6ed condition other than in Mode 1,2,3, or 4, or Mode 5. Condition C for ITS 3.4.3 requires that action be initiated immediately to restore compliance with the pressure and temperature limits for the RCS if these limits have been exceeded with the unit in a condition other than in Mode 1,2,3 or

4. Condition C requires the immediate initiation of action to restore parameters to within limits and the determination that the RCS is acceptable for continued operation prior to the unit entering MODE 4. These requirements are necessary to

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ensure that the RCPB is returned to a condition that has been verified by the stress analysis and that the RCPB integrity l O remains acceptable. This change represents a more restrictive change." This change will be provided in our comprehensive ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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NRC RAI Number NRC Issued Date RAI Status 3.4.3-02 3/9/98 Open NRC Action Required j

NRC Description of Issue Bases for ITS SR 3.4.3.1, STS Bases markup page B 3.415 The second paragraph has not been adopted; howes er, there is nojusti0 cation for this deviation from the STS. There is no identity for tracking this JFD change. Comment: Please revise the submittal to provide a technicaljusti0 cation for this JFD or adopt the STS.

Comed Response to issue Comed will revise the submittal to adopt the STS. This et ange will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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f Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC issued Date RAI Status 3.4.4-01 3/9/98 Open - NRC Action Required NRC Description of Issue JFD BP3 Bases for ITS LCO 3.4.4, STS Bases markup pages B 3.4-18 and B 3.4-19

a. In the first paragraph, the last sentence is not adopted and the BP3 insert is added. The insert does state that in addition to all loops in operation that they are also Operable. Secondly, "all" loops need to be stated as "four" loops are Operable to satisfy the movement of this requirement from CTS 3.2.3 to the Bases of 3.4.4 as described in DOC LA17. Comment:

Revise the Bases as indicated.

b. In the second paragraph, w hen referring to an Operable SG the phrase "in accordance with the Steam Generator Tube Surveillance Program" is replaced with "providing the necessary heat transfer capability." These phrases are not technically j

equivalent. This difference is not justinable as an editorial enhancement as indicated by JFD BP3. It is recommended that l

both phrases be used to define an Operable SG rather than one phrase in lieu of the other. Comment: Please revise the submittal to adopt the STS text.

l Comed Response to issue Comed w ill revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

NRC RAI Number NRC issued Date RAI Status j

3.4.5-01 3/9/98 Open - NRC Action Required NRC Description of Issue DOC L3 DOC L12 DOC L23

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JFD P6 JFD BP6 l

ITS 3.4.5 Actions l

CTS 3/4,4.1.2 Actions ITS 3.4.5 and associated Bases are to be revised to separately address the condition of one RCS loop not in operation with the rod control system incapable of rod withdrawal and two RCS loops not in operation with the rod control system capable of rod withdraw. Note: These changes are in addition to an unapproved generic change (TSTF-87 Rev 1); and also, these l

are not plant specific requirements because they are not part of the current licensing basis. This "P" difference is l

miscategorized under the NEl 96-06 guidelines of Section 2.7, Deviations from the Applicable ISTS. It is a "C" difference.

Note that TSTF-87 Revision 2 was approved 10/3/97. Comment: Revise the submittal to adopt Rev 2 to TSTF-87 l

consistent with plant design.

Note to TSB review er: Ffollowing Comed's response and before closing this comment, review the revised Actions ofITS 3.4.5 to ensure consistency with either the CTS or Rev 2 to TSTF-87.

Comed Response to Issue Comed will revise LCO and Bases JFDs 3.4-C10 to reference TSTF-87. Revision 2. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAI 3.4-01 item 9.) llowever, Comed continues to pursue the plant specific changes associated uith LCO and Bases JFDs 3.4-P6.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RAI Status 3.4.5-02 3/9/98 Open - NRC Action Required G

NRC Description of Issue JFD P1 JFD PI JFD llPI ITS LCO 3.4.5.a and 3.4.5.b

a. The word " Operable" has been inserted before "RCS loop (s)" in LCO 3.4.5. This uord is redundant to th: LCO statement which already states "RCS loops shall be Operable" The word insertion is not accepted.

b.11S LCO 3.4.5 Note b CTS 3.4.1.2 Footnote

item (2)

The ITS note is changed as follows " Core outlet temperature is maintained at least loof below saturation temperature by 100F." The CTS requirement for this note is identical in wording to the STS text. There is no editorial enhancement perceised in this change. Changes are not accepted.

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c. Ilases ITS LCO 3.4.5, STS Ilases markup page 11 3.4-23 in the fifth paragraph, item b is reworded to conform to LCO Note b. This change is also not accepted.

Comment: For these three items, revise the submittal to adopt the STS text.

Comed Response to issue Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 (9

closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAls

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3.4.6-02,3.4.8-02, and 3.4.8-03.)

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NHC RAI Number NRC issued Date RAI Status

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3.4.5-03 3/9/98 Open - NRC Action Required NRC Description of Issue DOC L5 JFD B3 JFD BB3 ITS SR 3.4.5.2 CTS 4.4.1.2.2 Bases for ITS SR 3.4.5.2, STS Bases markup page B 3.4-26 1

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a. This change adds plant specific SG secondary side water level values w hich are different from those stated in the CTS.

DOC L5 justifies the new values. The adequacy of these values can not be verified. There is no acceptable method for l

approving the new values as presented in these JFDs. Comment: Revise the submittal to explain the large difference in the l

values between Units I and 2 and why this difference is the exact same for both Byron and Braidwood.

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b. The Bases for ITS SR 3.4.5.2 differs from the STS to conform to the proposed plant specific SG secondary side water levels values w hich are not the same as those stated in the CTS requirements. Comment: How was this change approved by the NRC fis e years ago but never incorporated into the CTS? Submit additional technicaljustification for this change.

Comed Response to Issue No change. NRC SER and Amendments 34 (Braidwood) and 45 (Byron). dated April 6,1992 approved Comed's request to change the Steam Generator (SG) secondary side narrow range water level to be greater than or equal to 33% for Unit I (Westinghouse D4 SGs) and 37% for Unit 2 (Westinghouse DS SGs). The difference in SG level values betw een Unit One (41% to 33%) and Unit Two (18% to 37%) is attributable to the CTS LAR encompassing water level setpoint optimization on both units, and SG level tap relocation on Unit Tw o only. This change was accurately made in CTS Tables 2.2-1 and 3.3-

4. Ilowever, CTS page 3/4 4-4 for CTS SR 4.4.1.3.2 was inadvertently not changed. In developing the CTS markup for the conversion to ITS, CTS page 3/4 4-4 was used and was marked up to reflect the correct values as approved in Amendments 34 and 45. Although this CTS SR contained the incorrect values, the plants administratively control the water I

level at greater than or equal to 41% w hich is more conservative. Comed continues to pursue this change. (See RAl 3.4.7-04.)

NRC RAI Number NRC issued Date RAI Status 3.4.5-04 3/9/98 Open - NRC Action Required NRC Description of Issue JFD BPI Bases for ITS LCO 3.4.5, STS Bases markup page B 3.4-23 in the last paragraph, w hen referring to an Operable SG, the phrase "in accordance with the Steam Generator Tube Surveillance Program" was not adopted. This phrase is important for stating under what additional conditions the SG must be Operable for this LCO. Also, JFD BPI does not adequatelyjustify this difference. Comment: Revise the Bases to adopt the STS text.

Comed Response to Issue Comed will revise the Bases to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RAI Status 3.4.5-05 3/9/98 Open - NRC Action Required NRC Description of issue JFD BPI Bases for ITS SR 3.4.5.3, STS Bases markup page B 3.4-26 l

The Bases discussion reduces requirements about how the safety analysis limits are met and adds a new basis for the 7 day Frequency. JFD BPI does not adequately justify these technical differences from the STS Bases. Comment: Revise the submittal to adopt the STS text.

1 Comed Response to Issue No change. ITS Bases SR 3.4.5.3 was revised to provide a discussion concerning the 7 day Frequency for SR 3.4.5.3. This change was added for consistency and clari0 cation. Other STS SRs contain a brief discussion as to the justincation/ reason for the specific SR Frequency. This change is no different. STS SR 3.4.5.3 does not contain any information pertaining to the 7 day Frequency. Comed provided additional information to assist the operator and enhance their knowledge concerning the reasoning behind the 7 day Frequency. This change does not alter any technical content or philosophy of the i

STS, and provides additional information for the user. Comed continues to pursue this change. Comed will, however, conform to the STS text for the first and second sentences for the Bases discussion ofITS SR 3.4.5.3.

NRC RAI Number NRC issued Date RAI Status 3.4.6-01 3/9/98 Open - NRC Action Required NRC Description of Issue DOC A8 JFD P7 and BP7 l

ITS 3.4.6 Action C CTS 3/4.4.1.2 Actions Unlike the STS, ITS 3.4.6 Action C addresses the condition of two required [RCS or RilR] loops not in operation. This dilTerence is not plant specific because the proposed action requirement is not in the CTS. This is a C-type difTerence.

Also, the CTS markup associated with DOC A8 does not accuratelyjustify the addition of proposed ITS 3.4.6 Action C.

Comment: Revise the submittal to adopt the STS action requirements.

Comed Response to issue No change. The LCO allows either RCS or RiiR loops to satisfy the requirement for decay heat removal in MODE 4. Any combination of two loops Operable may be used to satisfy the LCO. A loop is " required" when the loop is used to satisfy the LCO. Operable loops in excess of the two required to satisfy the LCO are not " required." Condition entry is only necessary w hen the total number of Operable loops is less than that required by the LCO. NUREG LCO 3.4.6 attempts to account for the designation of required loops by stating, "Two RiiR loops inoperable" in Condition A and "Two RCS loops inoperable" in Condition B. The presumption in Condition A is that when two RilR loops are inoperable, two RCS loops are then required. Similarly, Condition B presumes that when two RCS loops are inoperable, two RilR loops are required.

This logic does not hold for plants with three or more RCS or RilR loops or for situations in which the plant is using one RilR and one RCS loop to meet the LCO. Although the wording is different than the STS, the intent has not been changed.

In addition, the intent of the STS is to proside a Condition w here the required loops are either inoperable or not in operation. The STS Condition C accomplishes this by stating all combinations of RCS and RilR loops inoperable or not in operation. This approach was deemed confusing by Operators. In an attempt to clarify Condition C, Comed revised Condition C for two required loops inoperable no matter what combination of RilR or RCS loops. The condition w here no loops are in operation is contained in Condition A. This clarification does not change any intent or technical requirements as presented in the STS. A similar change was proposed by ll.B. Robinson plant and became WOG-109. In addition. TSTF-263 contains similar char.ges. The proposed change was approved plant specifically for li.B. Robinson. Comed continues to pursue this change. (See RAls 3.4.7-01,3.4.7-07,3.4.8-01, and 3.4.8-08.)

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I Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date R AI S'.atus

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3.4.6-02 l'9'98 Open - NRC Action Required (d

NRC beseription of hsue l

JFD P1 i

ITS LCO 3.4.6

a. The word " Operable" has been inserted in the last phrase stating with "one OPERABLE loop shall be in operation." This word is redundant to the 6rst part of the LCO statement which already states "..RCS and RilR loops shall be Operable, The word insertion is not accepted.

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b. JFD P1 ITS LCO 3.4.6 Note 1.b CTS 3.4.1.3 Footnote

item (2) l l

The ITS note is changed as follow s " Core outlet temperature is maintained at least 100F below saturation temperature by 100F." The Cl S requirement for this note is identical in wording to the STS text. There is no editorial enhancement perceived in this change,

c. JF D B PI Ilases for ITS LCO 3.4.6, STS Bases markup page B 3.4-28 l

l in the fifth paragraph, item b is reworded to conform to the LCO Note 1.b. This change is also not accepted.

l Comment: For the abos e differences, revise the submittal to adopt the STS text.

Comed Response to issue

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(V Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAls 3.4.5-02,3.4.8-02, and 3.4.8-03.)

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Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC Issued Date RAI Status hD 3.4.6-03 3/9'98 Open - NRC Action Required G

NRC Description of Issue ITS 3.4.6 Applicability Notes PlLR Letter from Capra (NRC) to Kingsley (Comed) dated I/21/98, regarding acceptance for referencing of PTLR, and enclosed safety evaluation (SRXil comment) ilyron & 11raidw ood's LTOP analyses account for RCP dynamic head effects and the resultant pressure drop between the location of the limiting sessel material and the pressure transmitter used to actuate the LTOP system. In the LTOP analyses, you assumed all four RCPs and both RilR pumps running when the RCS is above 120 F, and accounted for the maximum resulting head effect. Iloweser, for RCS temperature below 120'F you assumed only one RCP is in operation and accounted for the dynamic head effect of that single RCP (in addition to the two RilR pump). Comment:

Revise the Applicability Notes of ITS 3.4.6 with an additional note consistent with this assumption. This may be submitted in a form similar to the note to Section 3.4.6 w hich is related to the 50'F primary / secondary difference limit for starting a RCP.

Comed Response to issue No change. Comed disagrees. The referenced SER accurately redects the assumptions used in the LTOP analysis for operation above and below 120 F. These are assumptions incorporated in the Staff approved methodology. They do not, however, result in operational restrictions. The net impact of these conditions is to the LTOP setpoint, not the plant operation.

The tuo items that are in Tech Specs (TS) concerning the basis of LTOP setpoints define the initiating esents that the LTOP system protects against. These items are,1) the number of ECCS pumps injecting during an LTOP mass injection event (charging pump at full How), and 2) the temperature difference for the heat injection event (30'F) These tu o initiating

[O events are specifically discussed in Section 3.1 of WCAP-14040-NP-A, methodology used to develop cold overpressure

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mitigating system setpoints and RCS heatup and cooldown limit curves, and the associated SER. lleyond the initiating events, other factors are considered in the I. TOP setpoint determination. DifTerential pressure and instrument uncertainty are two of these. The application of these secondary items are administratively controlled by Comed. This concept of administrative control was accepted by the StatTin our recent discussions for the approval of the PTLR amendment. TS do not base restrictions on other secondary items (i.e., there are no TS requirements specific to the calibration of the instruments insolsed which will affect the total instrument tolerances applied to the LTOP setpoints). Comed belieses that it is not the StalTs intention to include these secondary issues in TS.

Additionally, the mode of applicability for ITS 3.4.6 is mode 4, which corresponds to a minimum temperature of 200 F.

The LTOP analysis assumes the most limiting operational parameters in this mode. Noting the different assumption for a condition not addressed by this specification is not desirable.

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Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC ' Issued Date RAI Status

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3.4.7-01 3/9/98 Open - NRC Action Required NRC Description of issue JFD P8 ITS 3.4.7 Actions CTS 3/4.4.1.4.1 Actions JFD flP8 Unlike the STS, ITS 3.4.7 addresses the condition of a required RilR loop not in operation. These differences are not plant specific because they are not in the CTS. This is a C-type difTerence. Also, why are there not equivalent CTS DOCS provided for these changes? The CTS does not reflect these changes. Comment: Revise the submittal to adopt the STS action requirements. Comed is encouraged to propose a generic change to the STS. See similar comments 3.4.6-01 and 3.4.8-01.

Comed Response to issue See Comed Response to RAI 3.4.6-01. (See RAls 3.4.6-01,3.4.7-07,3.4.8-01, and 3.4.8 08.)

NRC RAI Number NRC Issued Date RAI Status 3.4.7-02 3/9/98 Open - NRC Action Required NRC Description of Issue DOC A.I JFD PI ITS LCO 3.4.7.b CTS 3.4.l.4.1.b CTS 3/4.4.1.4.1 Action a JFD flPI Ilases for ITS 3.4.7 Applicability, STS Bases markup page 113.4-33 STS 3.4.7.b is reworded as follows: "The secondary side water level of a least two Steam Generators (SGs) shall be > [17%]

OPERABLE." Throughout the STS, an Operable SG means " Operable in accordance with the Steam Generator Tube Surveillance Program" The STS text is very explicit here to require the secondary side water level of an Operable SG to be a condition of Operability for this LCO. These are technical changes to the CTS requirements which are inadequately justified as an editorial change under DOC Al. As presented, this is a less restrictive change to the CTS which requires an "1." DOC. Correspondingly, JFD Pi is inadequatejustification for these changes. These change are not accepted as justified. Comment: Revise the submittal to adopt th ; STS text.

Comed Response to issue Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

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Response to NRC RAI Dated 03/09/98 i 6-A pr-98 NRC RAI Number NRC issued Date RAI Status 3.4.7-03 3/9/98 Open - NRC Action Required g

NRC Description of issue JFD P1 ITS LCO 3.4.7 Note 1.b CTS 3.4.1.4.1 Footnote

item (2) a The ITS note difTers from the corresponding STS note as follows " Core outlet temperature is maintained at least 10er l

below saturation temperature by loof." The CTS requirement for this note is identical in wording to the STS text. There is no editorial enhancement perceived in this change..

f JFD BPI Bases for ITS LCO 3.4.7, STS Bases markup page B 3 A-34 b in the third paragraph, item b is reworded to conform to LCO Note 1.b.

Comment: The above differences are not justifiable on a plant-specific or editorial basis. Revise the submittal to adopt the STS text.

Comed Response to issue Comed will revise the submittal to adopt the STS text This change w ill be provided in our comprehensive ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

NRC RAI Number NRC issued Date RAI Status 3.4.7-04 3/9/98 Open - NRC Action Required NRC Description ofIssue JFD B3 DOC LS ITS SR 3 A.7 2 CTS 3.4.1 A i.b JFD BB3 Bases for ITS SR 3.4.7.2, STS Bases markup page B 3.4-36 The ITS contains plant specific SG secondary side water level values which are different from the values in the CTS requirements, as discussed in DOC L5. The adequacy of these values can not be verified. There is no acceptable method for approving the new values as presented ir. these justifications. Also, explain the large difference in the values between Units I and 2 and why this difference is the exact same for both Byron and Braidwood.

Comment: 1 low was this change approved by the NRC five years ago but not incorporated into the CTS? Revise the submittal with additional technicaljustification for this change. See similar comment 3.4.5-03.

Comed Response to issue No change. NRC SER and Amendments 34 (Braidwood) and 45 (Byron), dated April 6,1992 approved Comed's request to change the Steam Generator (SG) secondary side narrow range water les el to be greater than or equal to 33% for Unit I (Westinghouse D4 SGs) and 37% for Unit 2 (Westinghouse D4 SGs). This change was accurately made in CTS Tables 2.2-I and 3.3-4. Ilowever, CTS page 3/4 4-4 for CTS SR 4.4.1.3.2 was inadvertently not changed. In developing the CTS l

markup for the conversion to ITS, CTS page 3/4 4-4 was used and was marked up to reflect the correct values as approved in Amendments 34 and 45. Although this CTS SR contained the incorrect values, the plants administratively control the water level at greater than or equal to 41% w hich is more conservative. Comed continues to pursue this change. (See RAI 3.4.5-03.)

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Rcsponse to NRC RAl' Dated 03/09/98 16-Apr-98 NRC RAI Number NRC Issued D' ate RAI Status 3.4.7-05 3/9/98 Open - NRC Action Required NRC Description of issue DOC A25 JFD P39 ITS SR 3.4.7.1-CTS 4.4.1.4.1.2 CTS 4.4.1.4.1.2 states "At least one RHR loop shall be verified in operation and circulating reactor coolant.. " w hich is onsistent with the STS. Alternatively, ITS SR 3.4.7.1 states this verification is for the " required" RilR loop in operation.

This change and difference introduces an ambiguity that is not present in the CTS and STS. The SR does not try to determine which is the " required" RCS or RilR in operation but explicitly states that any one must be in operation Comment: Withdraw the change and adopt the STS text.

Comed Response to issue No change. The w ord " required" was added to the SR for verifying one RHR loop is in operation to ensure that the RilR loop that is in " operation" is the RilR loop that is designated as the " OPERABLE" loop. This eliminates the possibility of crediting a non-operable (as required by the LCO) RilR loop as the RilR loop in operation. Comed continues to pursue this change. (See RAI 3.4.8-06.)

NRC RAI Number NRC Issued Date RAI Status 3.4.7-06 3/9/98 Open - NRC Action Required NRC Description ofIssue DOC M3 CTS 3.4.1.4.1 Footnote

ITS LCO 3.4.7 Note i TSTF-153 (approved 4/II/97)

STS LCO 3.4.7 Note 1 as revised by TSTF-153 does not begin with the word "all" as does the ITS note. Comment: This difference is not justifiable on a plant-specific or editorial basis. Revise the ITS note to conform to the STS as revised by TSTF-153.

Comed Response to Issue Comed will revise the ITS note to conform to the STS as revised by TSTF-153. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-A pr-98

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NRC RAI Number NRC Issucd Date RAI Status 3.4.7-07 3/9/98 Open - NRC Action Required NRC Description of issue DOC M13 CTS 3/4.4.1.4.1 Action b STS 3.4.7 Action B ITS 3.4.7 Actions A, B & C i

CTS 3.4.1.4.1 Action b provides action with no RilR loop in operation. STS 3.4.7 Action B provides Required Actions w ith ' Required' RilR loops inoperable OR no RllR loop in operation. The compensatory Actions for both the CTS and STS are the same. DOC M13 states "ITS 3.4.7 and ITS 3.4.8, Condition C, adds the Condition, two required RilR loops inoperable. This Condition does not exist in CTS." Two inoperable RilR loops are the same as no RilR loops in operation in Mode 5. There is no change here but an equivalence between the CTS and the STS w hich is obscured by the reformatting of the Actions as described by JFD P8. Comment: Withdraw the change and adopt the STS action requirements.

Comed Response to issue Comed disagrees that two inoperable RilR loops is the same as no RHR loops in operation, which is why the DOC was categorized as an 'M' DOC. In addition. NUREG LCOs 3.4.5,3.4.6,3.4.7, and 3.4.8 specify ". shall be OPERABLE and in operation. " indicating two separate and distinct requirements. Therefore, the ITS Actions and SRs were written accordingly. (See RAls 3.4.6-01,3.4.7-01,3.4.8-01, and 3.4.8-08.)

NRC RAI Number NRC issued Date RAI Status 3.4.7-08 3/9'98 Open NRC Action Required NRC Description of issue

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JFD P9 ITS SR 3.4.7.1 Note CTS 3.4.1.4.1.b JFD P9justines including a note in ITS SR 3.4.7.1 that the STS does not have. The new Note says "Only required w hen complying with LCO 3 A.7.b" The CTS do not allow this relaxation of the Operability requirements of CTS 3.4.1 A.l.b.

This note would permit a SG to remain inoperable and thus not immediately available,in the event the backup RHR loop became inoperable. Also, a note like this should never be buried in the SR but placed in the LCO. There is no less restrictive technical DOC provided for this change. Comment: This change and difference are not justinable on a plant-specine or editorial basis. Revise the submittal to withdraw the note.

Comed Response to issue Comed disagrees with the statement, "The CTS does not allow this relaxation of the Operability requirements of CTS 3.4.1.4.1.b," but Comed agrees with the statement, "T his note would permit a SG to remain inoperable and thus not immediately available, in the event the backup RilR loop became inoperable." CTS SR states, "The secondary side water level of at least two steam generators WHEN REQUIRED shall be..." in addition, NUREG SR 3.4.7.2 states," Verify SG secondary side water level is greater than or equal to [17]% in REQUIRED SGs." When the LCO is being met with one RHR loop OPERABLE and in operation and an additional RilR loop OPERABLE, there is no requirement for SGs and therefore SR 3 A.7.2 which verines SG secondary side water level is not required to be performed. SR 3 A.7.2 is only required to be performed when the LCO is being met with one RilR loop OPERABLE and in operation and the water les el of two SGs OPERABLE. Ilowever, since SR 3 A.7.2 contains the words " required SGs" the Note will be deleted. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (Correction Note: LCO JFD 3.4-P9justines adding a Note in ITS SR 3.4.7.2, not ITS SR 3 A.7.1.)

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Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC issued Date

' RA'l Status 3.4.7-09 3/9/98 Open - NRC Action Required NRC Description of Issue JFD Cl4 ITS LCO 3.4.7 Note 1 CTS 3.4.1.4.1 Footnote

TSTF-153 ITS LCO 3.4.7 Note I contains a proposed change to permit "All RilR pumps.. " to be de-energized. CTS 3.4.1.4.1 Footnote

only permits "The RilR pump _ " or one RilR pump to be de-energized. Comment: See comment 3.4.7-06.

Comed Response to issue Comed will revise the ITS note to confonn to the STS as revised by TSTF-153. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAI 3.4.7-06.)

NRC RAI Number NRC issued Date RAI Status 3.4.7-10 3/9/98 Open - NRC Action Required NRC Description of issue JFD llPI Hases for ITS LCO 3.4.7, SIS Bases markup page 113.4-33 In the first paragraph, the discussion pertaining to any combination of tw o RCS or RilR loops does not adopt the reason for

" meeting single failure considerations" and adds in its place to " provide adequate redundancy for decay hea' removal".

Comment: This difference is not justifiable on a plant-specific or editorial basis. Revise the submittal to adopt the STS text.

Comed Response to issue Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI. (See RAI 3.4.8-09.)

NRC RAI Number NRC issued Date RAI Status 3.4.8-01 3/9/98 Open NRC Action Required NRC Description of Issue JFD PIO ITS 3.4.8 Actions CTS 3/4.4.1.4.2 Actions JFD 11P10

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ITS 3.4.8 Action A and associated Bases address the Condition of a required RilR loop not in operation, as discussed in JFD P10. STS 3.4.8 Action 13, however, addresses this same condition. Thus there is no need to deviate from the format of the STS Actions. In addition, this difference is not plant specific because this requirement is not in the CTS. Therefore, this is a C-type difference. Comment: Withdraw the difference and adopt the STS format for the Actions. See similar comments 3.4.6-01 and 3.4.7-01 Comed Response to Issue See Comed Response to RAI 3.4.6-01. (See RAls 3.4.6-01,3.4.7-01,3.4.7-07, and 3.4.8-08.)

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Response to NRC RAI Dated 03/09/98 16-Apr-98

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NRC RAI Number NRC issued Date

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RAI Status 3.4.8-02 3/9/98 Open - NRC Action Required NRC Description of Issue JFD P1 ITS 3.4.8, LCO Note 1.b CTS 3.4.1.4.2 Footnote " item (2)

The ITS note differs from the corresponding STS note as follows: " Core outlet temperature is maintained > 100F below saturation temperature by > 100F." There is no editorial enhancement perceived in this change. Comment: Revise the submittal to adopt the STS presentation.

Comed Response to Issue Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. See RAls 3.4.5-02,3.4.6-02, and 3.4.8-03.

NRC RAI Number NRC lssued Date RAI Status 3.4.8-03 3/9/98 Open - NRC Action Required NRC Description of issue JFD P1 ITS LCO 3.4.8 The word " Operable" has been inserted in the last phive of STS LCO 3.4.8 to state that "one OPERABLE RilR loop shall be in operation." This word is redundant to the first part of the LCO statement which already states "Two...RilR loops shall be Operable, " The word insertion is not accepted. Comment: Revise the submittal to adopt the STS text.

Comed Response to issue Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAls l

3.4.5-02,3.4.6-02, and 3.4.8-02.)

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Response tINRC R l Dated 03/09/98 16-Apr-98 NRC RAI Number NRC Issued Date

~ RA'l Status 3.4.8-04 3/9/98 Open - NRC Action Required NRC Description of issue JFD P32 ITS 3.4.8 Note i STS 3.4.8 Note l CTS 3.4.1.4.2 Note "

JFD BP37 ITS 3.4.8 Note I states "All RilR pumps may be [de-energized] for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months " STS 3.4.8 Note I states "All RilR pumps may be de-energized for < 15 minutes when switching from one loop to another.. " CTS Footnote ** states only "The RilR pump may be de-energized for up to one hour.. "; but does not state a reason for de-energizing. JFD P32 deals only with the length of time issue for this difference. It states de-energizing all RilR pumps is consistent with the CTS requirements, but this is not so. Comment: JFD P32 states 15 minutes is adequate to switch loops; if so, why not adopt the STS text as is? If one hour is needed for each pump, then add a note to match the CTS requirement for one RilR pump de-energized at a time. Revise the submittal to adopt the STS or revise it consistent with the CTS, as described.

Comed Response to issue No change. It is Byron's and Braidwood's Current Licensing Basis (CLB) to allow de-energizing an RilR pump for I hour without stating a reason for the de-energization. LCO JFD 3.4-P32 was only intended tojustify maintaining the CLB of I hour LCO JFD 3.4-P35 justifies maintaining the CLB fcr not limiting the de-energization of the RilR pumps to "when switching from one loop to another." Further, since both CTS and ITS require only one RilR loop be in operation, Comed perceives the CTS wording of"The RilR pump may be. " to be equivalent to the ITS wording of"All RilR pumps may be

" Comed disagrees with the statement, "If one hour is needed for each pump, then add a note to match the CTS requirement for one RilR pump de-energized at a time." There is neither a restriction for preventing or requiring the second OPERABLE RilR pump from being in operation. Therefore, the second pump does not need a Note governing its operation. Comed continues to pursue this change. (See RAI 3.4.8-05.)

NRC RAI Number NRC Issued Date RAI Status l

3.4.8-05 3/9/98 Open - NRC Action Required NRC Description of issue JFD F35 ITS LCO 3.4.8 Note i S1S LCO 3.4.8 Note 1 CTS 3.4.1.4.2 Note "

JFD BP49 Bases for ITS LCO 3.4.8, STS Bases markup page B 3.4 38 ITS LCO 3.4.8 Note i states "All RilR pumps may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .. " STS 3.4.8 Note I states "All RilR pumps may be de-energized for < 15 minutes when switching from one loop to another.. " CTS Footnote "

states "The RHR pump may be de-energized for up to one hour..."; without a stated reason for de-energizing. JFD P35 deals only with the stated reason for de-energizing the RilR pumps and misquotes the CTS footnote ** as being applicable to all RilR pumps, rather than one; so, adopt the STS text as is. If one hour is needed for each pump, then add a note to match the CTS requirement for one RilR pump de-energized at a time. Comment: Revise the submittal to adopt the STS or revise it consistent with the CTS, as described. Recommend coordinating the response to this comment with the response to comment 3.4.8-04.

Comed Response to issue See Comed Response to RAI 3.4.8-04.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC lssued Date

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RAI Status 3.4.8-06 3/9'98 Open - NRC Action Required NRC Description of Issue DOC A25 JFD P39 ITS SR 3.4.8.1 l

CTS 4.4.1.4.2 I

JFD BP39 CTS 4.4.1.4.2 states "At least one RilR loop shall be verified in operation and circulating reactor coolant.. " ITS SR 3.4.8.1 revises this requirement to state this verification is for the " required" RilR loop in operation. This change introduces an ambiguity that is not present in the STS. The SR does not try to determine which is the " required" RCS or RilR in operation, but explicitly, states that any loop must be in operation. Comment: Adept the STS text which is consistent with the CTS requirement.

Comed Response to issue See Comed Response to RAI 3.4.7-05.

NRC RAI Number NRC issued Date RAI Status i

3.4.8-07 3/9/98 Open - NRC Action Required l

l NRC Description of Issue l

DOC M2 f

CTS 3.4.1.4.2 Footnote *

l ITS LCO 3.4.8 Note Ic I

l-CTS 3.4.1.4.2 Footnote " shows the additions of a Note 3 to this footnote; however, the footnote does not match the note in the ITS. The wording of this note which is adopted from the STS has been editorially enhanced. The acceptable wording is as follows "(3) No draining operations are permitted that would further reduce the RCS water volume." Comment:

Revise the CTS markup to be consistent with the ITS.

Comed Response to issue Comed will revise the CTS markup to be consistent with the ITS. This change will be provided in our comprehensive ITS l

Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI N' umber NRC issued Date RAI Status

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3.4.8-08 3/9/98 Open - NRC Action Required

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NRC Description ofissue DOC M13 CTS 3/4.4.1.4.2 Action b STS 3.4.8 Action B ITS 3.4.8 Action A, B & C CTS 3/4.4.1.4.2 Action b addresses the Condition of no RilR loop in operation. STS 3.4.8 Action B provides Required Actions with Required RilR loops inoperable OR no RilR loop in operation. The compensatory Actions for both the CTS and STS are the same. DOC M13 states "ITS LCO 3.4.7 and ITS LCO 3.4.8, Condition C, adds the Condition, two required RilR loops inoperable. This Condition does not exist in CTS." Two inoperable RilR loops are the same as no RilR loop in operation in Mode 5. There is no change here but an equivalence between the CTS and the STS which is obscured by the reformatting of the LCO under JFD p10. Comment: Withdraw the change and adopt the STS Conditions, as written. See comment 3.4.7-07.

Comed Response to Issue See Comed Response to RAI 3.4.7-07, l

NRC RAI Number NRC issued Date RAI Status 3.4.8-09 3/9/98 Open - NRC Action Required NRC Description of issue JFD BPI Bases for ITS LCO 3.4.8, STS Bases markup page B 3.4-37 in the first paragraph pertaining to the discussion of any combination of two RCS or RilR loops, the ITS does not adopt the STS reason for " meeting single failure considerations" but adds in its place the words " provide adequate redundancy for decay heat removal" Comment: This is not ajustifiable plant-specific or editorial difference. Revise the submittal to adopt the STS text.

Comed Response to issue Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI. (See RAI 3.4.7-10.)

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC Issued Date RAI Status

[G 3.4.9-01 3.'9/98 Open - NRC Action Required NRC Description of Issue JFD P40 ITS 3.4.9 Action B CTS 3/4.4.3 Action a ITS 3.4.9 Action 11, corresponding to CTS 3/4.4.3 Action a, allows both required groups of pressuriier heaters to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this condition, the pressurizer heater function is lost. Also, it is possible under the multiple condition entry convention of the STS, that the pressurizer level could be concurrently inoperable. Were this to occur, none of the LCO requirements would be met - which produces a loss of function condition for this LCO. Corresponding S~IS 3.4.9 Action il permits only one group of heaters to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months only w hile an Operable redundant group is Operable. Therefore, this is not consistent with the flases as the technicaljustification states. NUREG-0452 on which the CTS is based does not permit both pressurizer heater groups to be inoperable.

JFD BP40 JFD llPI JFD BP3 Bases discussions of Required Actions B.1, C.1, and C.2, STS Bases markup page B 3.4-43.

Acceptance of the changes to the two Bases discussions listed are contingent upon resolution of the differences addressed by JFD P40. JFDs BPI and IlP3 are linked to JFD BP40. Comment: Reference the NRC safety evaluation w hich made this change to allow both required groups to be inoperable, or adopt the more restrictive requirements of the STS.

Comed Response to luue The Actions Section of the Bases for ITS 1.CO 3.4.9 will be revised to state,"If the required groups of pressurizer heaters (b

are inoperable, restoration is required within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is reasonable considering the

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anticipation that a demand caused by loss of offsite power would be unlikely in this period. Pressure control may be maintained during this time using the remaining pressurizer heater capability." This change will be provided in our comprehensise ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the Ii S Section 3.4 RAl.

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NRC IkAl Numher

'NRC IssuckDa'te

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~ RAI batus 3.4.9-02 3/9/98 Open -NRC Action Required NRC Description ofissue JFD BP41 JFD BP48 Bases for ITS LCO 3.4.9, STS Bases markup page B 3.4-41 In the second paragraph of the STS Bases states that the two required pressurizer heater groups are " capable of being powered from either the offsite power source or the emergency power supply." The ITS replaces these words with the statement that the heater groups are " capable of being powered from an ESF power supplied bus," and omits information regarding the capability of being powered from an offsite power source. In addition, the ITS adds a sentence to explain that offsite (normal) pow er is not required for pressurizer heater operability. Comment: The proposed differences from the Bases are unnecessary because the ITS dennition of operability requires either emergency or offsite power, not both, for the supported system to be operable. Revise the Bases to adopt the STS wording.

Comed Response to Issue ITS LCO 3.4.9 item b is being revised to state, "Two groups of pressurizer heaters OPERABLE with. and capable of being powered from redundant Engineered Safety Feature (ESF) power supplied buses." Correspondingly, the second paragraph in the LCO Section of the Bases for ITS LCO 3.4.9 is being revised to state, "The LCO requires two groups.., capable of being powered from redundant ESF power supplied buses." This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

The pressurizer heaters are non-safety related. Plant design consists of a total heater capacity of 1800 kw which is divided into four groups (A, B, C, and D) with separate controls for the proportional group (C) and the back up groups ( A, B, and D). Ileater groups A and D are supplied by non-ESF bus 143, while groups B and C are supplied from non-ESF bus 144.

The non-ESF buses servicing the pressurizer heaters (buses 143 and 144) can be powered by either the Unit Auxiliary Transformer (UAT), or the unit-specine System Auxiliary Transformer (SAT) which is termed " normal power" per ITS Section 3.8. The ESF buses (buses 141 and 142) can be powered by the unit-specific SAT (which is termed " normal pow er" per ITS Section 3.8), the opposite-unit SAT (which is termed " reserve power" per ITS Section 3.8), or the emergency diesel generator. The ESF buses must be capable of powering, via a cross-tie, the non-ESF buses to satisfy ITS SR 3.4.9.3.

Therefore, the statement in the LCO Section of the Bases for ITS LCO 3.4.9, "The LCO requires two groups., capable of being powered from redundant ESF power supplied buses" reDects the current plant design. Since the only safety function for pressurizer heaters is in a loss of offsite power condition, normal power is not required for OPERABILITY. That is,

" normal" power to a non-ESF bus is not required, but rather the non-ESF bus must be capable of being powered from an ESF bus. Comed continues to pursue this change.

NRC RAI Number NRC issued Date RAI Status 3.4.9-03 3/9/98 Open - NRC Action Required NRC Description of Issue JFD BPI Bases for ITS SR 3.4.9.1, STS Bases markup page B 3.4-43 The first sentence of the Hrst paragraph of the listed ITS Bases discussion differs from the STS as follows: "This SR requires that during steady state operation, pressurizer level to be maintained below the nominal upper limit to provide a minimum space for a steam bubble." Comment: This difference is notjustifiable on a plant-specific or editorial basis. The STS sentence is clear. Revise the Bases to adopt the STS words.

ComF.d Response to issue Comed will revise the Bases to adopt the STS wording. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RAI Status 3.4.10-01 3/9/98 Closed NRC Description of issue Not used Comed Response to issue No response required.

NRC RAI Number NRC issued Date RAI Status 3.4.10-02 3/9'98 Open - NRC Action Required NRC Description of issue DOC M17 CTS 3.4.2.2 and Footnote

ITS 3.4.10 Applicability Note CTS 3.4.2.2 and Footnote

requires the pressurizer safety valves to be set within the lift setting limits at normal operating temperature and pressure. The Applicability Note to ITS 3.4.10 allows entry into Mode 3 at normal operating temperature and pressure for up to 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months to set the lift settings at normal operating temperature and pressure. CTS 3.4.2.2 has no exception to CTS 3.0.4. Thus, if the IST requirements for setting the valves to within 1% of the setpoint are due, there is no basis for entering Mode 3 without first verifying the Operability of the safety valves at normal operating temperature and pressure (perhaps bench testing with a suitable test rig is implied, as opposed to in-situ testing). Assuming the hot setting is seguired by the IST, and provided that the cold settings have been completed, the ITS note allows entry into Mode 3, but requires completing the hot settings within 54 houn. following entery into Mode 3. This limited time period is sufficient to set the pressurizer safety valves under normal operating ambient conditions. Adoption of the STS allowance granted by this note constitutes a less restrictive change to the CTS. Comment: Revise the submittal by replacing DOC M 17 with a less restrictive CTS change justification. In the response to this comment, describe current IST practices for cold and hot setting of the pressurizer safety valves and how they are consistent with the CTS requirements and w hether any changes are needed to be consistent with the ITS requirements.

Comed Response to Issue DOC M17 will be changed to an 'L' DOC (less restrictive change), and will state, " CTS 3.4.2.2 Footnote

requires the pressurizer safety valve lift setting pressure correspond to ambient corditions of the valve at nominal operating temperature and pressure. The Applicability of the CTS requirement is in Modes 1,2, and 3. Therefore, complying with Jhe CTS, the lift setting must be set at operating temperature and pressure prior to entering Mode 3. The ITS LCO 3.4.10 LCO Note allows entry into Mode 3 with the lift settings outside the LCO limits. This permits testing and examination of the safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. This change represents a less restrictive change, and is consistent with NUREG-1431." This change will be provided in our comprehensive ITS Section 3.4 closeout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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RcSponse to NRC RAI Dattil 03/09/98 16-A pr-98 NRC RAI Number NRC Issued Date

' RAI Status 3.4.10-03 3/9/98 Open - NRC Action Required NRC Description of Issue JFD P13 ITS 3.4.10 Applicability Note JFD BPl3 Bases for Applicability ofITS 3.4.10, STS Bases markup page B 3.4-47 The ITS proposes to place the STS 3.4.10 Applicability Note with the LCO statement as an editorial enhancement to preclude misinterpretations ofITS SR 3.0.4. StafTdisagrees with this technical basis. This difference is generic and should be submitted as a generic change to the STS. Comment: Withdraw this deviation from the STS, and adopt the STS format.

This change occurs frequently in this submittal; thus the response to this comment should be global over the w hole submittal. This comment likely occurs in other sections. A single response with references to it is acceptable.

Comed Response to Issue See Comed Response to RAI 3.4.104. (See RAls 3.1.5-01,3.1.6-01,3.4.1 04, and 3.4.12-01 Item b.)

NRC RAI Number NRC Issued Date RAI Status 3.4.10-04 3/9/98 Open - NRC Action Required NRC Description of Issue JFL) P33 ITS SR 3.4.10.1 JFD BP38 Bases for ITS SR 3.4.10.1, STS Bases markup page B 3.4-48 ITS SR 3.4.10.1 omits the last sentence of STS SR 3.4.10.I, "Following testing, lift settings shall be within 1%", because the licensee believes the I.CO and Bases are inconsistent. The staff disagrees. In addition, omission of this sentence from the STS would require a generic change. Comment: Revise ITS SR 3.4.10.1 to adopt the sentence omitted from STS SR 3.4.10.1.

Comed Response to issue Comed will revise ITS SR 3.4.10.1 to adopt the sentence omitted from STS SR 3.4.10.1. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

NRC RAI Number NRC issued Date RAI Status 3.4.10-05' 3/9'98 Open - NRC Action Required NRC Description of issue DOC Ml7 JFD B43 ITS 3.4.10 Applicability Note The Applicability note has been modiGed in the second sentence by identifying Mode 3 as the " normal operating l

temperature and pressure" where the lift settings are veri 6ed. The insertion of this text is redundant to the earlier sentence w here the " ambient (hot) conditions" are discussed. These changes to the note are not accepted.

Note: This modi 6 cation is also shown in CTS change with M17 DOC but is not separately identined. Comment: Revise the submittal to adopt the STS text of the Applicability Note.

Comed Response to issue Comed will revise the submittal to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Rcsponse to NRC RAI Dated 03/09/98 16-A pr-98 i

NRC RAI Number NRC Issued Date RAI Status p) 3.4.11-01 3/9/98 Open - NRC Action Required gv NRC Description of issue DOC A10 JFD P14 DOC L8 JFD C12 CTS 3/4.4.4 Actions a through d ITS 3.4.11 Actions B, D, E, F, & G JFD BCl3 Bases for ITS Required Actions D.1 and D.2, insert B 3.4-54A, STS Bases markup page B 3.4-54

a. The Applicability ofITS 3.4.11 is Modes 1,2, and 3, yet the action requirements never require exiting Mode 3 (RCS average temperature below 350 degrees Fahrenheit), only going to Mode 3 with RCS average temperature below 500 degrees Fahrenheit, which is addressed by DOC L8 and JFD Cl2, based on TSTF-113 w hich is still pending with the staff.

This is illogical. Comment: Revise the submittal to adopt the STS shutdown requirements which are consistent with the CTS action requirements,

b. The submittal does not justify adding bb a valves to STS 3.4.11 Actions Note I and allowing separate Condition entry for inoperable PORVs and block valves. The reasons given in DOC A10 and JFD Pl4 are insufGcient tojustify these changes and differences. The licensee's perception stated in DOC A10 that separate Condition entry is the intent of the CTS action requirements is incorrect. Comment: Revise the submittal with a L-type technicaljustification for allowing separate Condition entry for the PORVs and associated block valves. Revise JFD P14 with a plant-specinc justification for adding block valves to STS 3.4.11 Actions Note I allowing separate Condition entry. Otherwise, adopt the STS version of the note.

Comed Response to Issue Comed Response to NRC Comment a: Comed will revise the submittal to adopt the STS text and withdraw TSTF-l 13 V

from the submittal. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. Comed Response to NRC Comment b: TSTF-247 revises NUREG LCO 3.4.11 to allow separate condition entry for each block valve, and thereby eliminating bracketed Required Action F.3. This change was proposed by Byron and Braidwood and has been approved by TSTF. LCO JFD 3.4-Pl4 will be revised to state,"NUREG and ITS LCO 3.4.11 allow separate condition entry for each PORV. The Conditions and Required Actions provide appropriate compensatory measures for separate condition entry. ITS has been modined to add the phrase," Separate Condition entry is allowed for each PORV and each block valve," consistent with TSTF-247. In the event a PORV becomes inoperable and not capable of being manually cycled (Condition B), the Required Action is to close the associated block vahe and remove power from the block vahe within I hour. In accordance with the Bases, once power is rer nved from the block valve, it is no longer OPERABLE and Condition C is also entered. Per ITS Required Action B.3, the inoperable PORV is to be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Required Action C.2 requires the inoperable block valve to be restored to OPERABLE (restore power) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In the event the second PORV becomes inoperable.

Condition E Required Actions require the associated block vahe to be closed and power remosed from the valve, rendering it inoperable. Condition B is re-entered for the second PORV. This results in 2 PORVs and 2 block valves inoperable and Condition F is entered for 2 inoperable block valves. If the first PORV is restored to OPERABI E, Condition E is exited, leasing Condition B entry for the second PORV with the remainder ofits 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months available in order to restore it to OPERABLE status. Ilow ever, without separate Condition entry for the block vahes, the second PORV and associated block valve must be restored to OPERABIP. within the initial 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months clock of the Erst block s ah e. If the second PORY and associated block valve are not restored within this initial 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , Condition D is entered which requires the unit to be shutdown. As provided for the PORVs, the Conditions and. Required Actions also provide appropriate compensatory actions for separate condition entry for each block valve. Thus, the Actions Note is modined to allow separate condition entry for each block valve." Comed continues to pursue this change.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RA'l Status 3.4.11-02 3/9/98 Open - NRC Action Required NRC Description of Issue DOC A1 CTS 4.4.4.1 The first phrase of CTS 4.4.4.1, "In addition to the requirements of the Specification 4.0.5, each PORV shall be demonstrated..", has not been retained in the Surveillance Requirements ofITS 3.4.11. This omission is incorrectly categorized as an administrative change by DOC A1. It is a specific technical change which must be discussed andjustified separately. Comment: Revise the submittal with a technicaljustification for this CTS change.

Comed Response to Issue DOC A33 was created to discuss CTS Specification 4.0.5 relocation. DOC A33 states " CTS Specification 4.0.5 provides surveillance requirements for inservice inspection and testing of ASME Code Class I,2, and 3 components. In accordance with NUREG-1431 CTS Specification 4.0.5 has been relocated to ITS Specification 5.5.8, " Inservice Testing Program."

The requirements for Inservice Testing have not changed and are still consistent with ASME Section XI. The requirements for the Inservice Inspection are contained in 10 CFR 50.55a and therefore not included in the NUREG. This change has beenjustified in the ITS submittal as an administrative change throughout the CTS markups since no ASME or CTS Inservice Testing requirements were changed. The only change that was made was in relocation of the requirements from CTS 4.0.5 to ITS 5.5.8." This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAI 3.4.12-07.)

NRC RAI Number NRC issued Date RAI Status 3.4.11-03 3/9/98 Open - NRC Action Required NRC Description ofIssue

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JFD BP3 Bases Background discussion for ITS 3.4.11, STS Bases markup page B 3.4-50 The ITS Bases do not adopt the words which stme normal power is "from the vital buses from ofTsite sources but are capable of being powered from emergency power sources"in the fifth paragraph of the Bases Background discussion for STS 3.4.11. This omission appears to contradict the discussion about PORV power sources in JFD. The proposed omission and related editorial changes result in misleading the reader into thinking that the PORVs only have emergency power sources. Comment: Rcvise the Bases ofITS 3.4.11 to conform to the STS Bases consistent with plant design.

Comed Response to Issue Comed will revise the Bases ofITS 3.4.1 I to conform to the STS Bases. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

Response to NRC RAI Dated 03/09/98 16-A p r-98 NRC RAI Number NRC Issued Date RAI Status 3.4.11-04 3'9'98 Open - NRC Action Required NRC Description of Issue DOC 1AH CTS SR 4.4.4.1.a The licensee proposes to move the CT S requirement for Channel Calibration of the PORV actuation instrumentation to the T RM, but does not fully explain why specifying this requirement in TS is not necessary to ensure Operability of the PORV actuation instrumentation or how the retained surveillances ensure the Operability of this instrumentation. Comment:

Revise DOC LA8 to address the concerns noted.

Comed Response to Issue Comed will revise the ITS submittal to reflect our proposed resolution to the " Spurious Si at Power" issue. The CTS License Amendment Request (LAR)is expected to be docketed by April,30,1998. An ITS Revision incorporating the CTS LAR will be submitted subsequently.

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Response to NRC RAI Dated 03/09/98 16-A p r-98 NRC RAI Number NRC issued Date

'RAI Status (Ov) 3.4.12-01 3/9/98 Open-NRC Action Required NRC Description of Issue DOC M7 JFD PII JFD P19 JFD P21 JFD C9 (WOG 51); CIS (WOG 81)

ITS 3.4.12; LCO, Actions A thru D, and SRs CTS 3/4.4.9.3; CTS 3/4.5.3; CTS 3/4.5.4.1 and CTS 3/4.5.4.2 ITS 3.4.12 and associated Bases contain extensive deviations from STS 3.4.12.

a. JFD Pl 1 applies to differences from the STS LCO, Applicability, Actions, and SRs so that the ITS properly specify the plant specific limitations of the Byron and Braidwood LTOP system analysis. Comment: Revise JFD P1 I to explain how each limitation given in the CTS has changed. Also explain how each corresponding limitation proposed in the ITS reflects those changes or reflects an additional limitation based on the LTOP analysis. List each specific limitation from the LTOP analysis and the corresponding limitation in the ITS - refer to each specific ITS 3.4.12 requirement. The foregoing request is made to facilitate verification by the staff that the proposed requirements are appropriate and consistent with the LTOP analysis.

b. JFD Pl9 incorporates the Applicability Note into the LCO, which is an unacceptable type of STS generic change l

proposal common to this submittal. Comment: Revise the submittal to adopt the STS presentation of the note in the Applicability.

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c. Deviations to the Applicability based on JFD C9 (WOG 51) and CIS (WOG 81) are rejected. Comment: Revise ITS

(v) 3.4.12 to adopt the STS Applicability requirements consistent with plant design and current licensing basis.

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d. JFD P21 applies to the notes to the SRs.

The note to ITS SR 3.4.12.2 appears generic, not plant specific. Thus it is rejected.

l The note to ITS SR 3.4.12.3 is related to the generic movement of the Applicability note to the LCO; thus it is also

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generic. This note is rejected.

The note to ITS SR 3.4.12.5 is unnecessary since it only applies to RilR suction valves associated with " required" RilR suction relief valves. It is also generic. This note is rejected.

The note to ITS SR 3.4.12.6 is unnecessary since it only applies to PORV block valves associated with each " required" PORV. It is also generic. This note is rejected.

Comment: Revise the above SRs by withdrawing the proposed notes.

c. DOC M7 collectively justifies the changes to the CTS corresponding to the proposed STS deviations noted above and which are considered unacceptable. Comment: Revise DOC M7 as appropriate to be consistent with the resolutioin of the preceding comments.

Comed Response to issue Comed Response to NRC Comment a: No change. LCO JFD 3.4-PII does not change any CTS requirements. ITS LCO 3.4.12 item a corresponds to CTS 3.5.3.a footnote; ITS LCO 3.4.12 item b corresponds to CTS SR 4.5.3.2; ITS LCO 3.4.12 item e is a more restrictive requirement as discussed in DOC 3.4-M7; and ITS LCO item d corresponds to CTS 3.4.9.3.a and

b. LCO JFD 3.4-P11 merely discusses including the requirements associated with ITS LCO 3.4.12 items a and b into the ITS LTOP specification from the CTS ECCS Subsystems specification 3.5.3. Comed Response to NRC Comment b: See Comed Response to RAI 3.4.1-04. (See RAls 3.1.5-01,3.1.6-01,3.4.1-04, and 3.4.10-03.) Comed Response to NRC Comment c: WOG-51, Revision I will be withdrawn from the submittal. LCO JFDs 3.4-C9 and 3.4-PI, Bases JFDs 3.4-C9 and 3.4-P21, and the markups will be revised accordingly. This change will be provided in our comprehensive ITS Section p

3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. Comed 1

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Response to NRC Comment d: SR 3.4.12.2 Note will be deleted based on withdrawing WOG-51, Revision 1. SR 3.4.12.4, SR 3.4.12.5, and SR 3.4.12.6 Notes will be deleted due to being redundant to the use of the word " required" in the SRs themselves. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's 29 l

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Response to NRC RAI Dated 03/09/98 16-A pr-98 concurrence with the Comed Responses to the ITS Section 3.4 RAI. (See R Als 3.4.12-03 and 3.4.12-04.) llow es er, SR

,O 3.4.12.3 Note is being retained. Without the Note, wheneser the unit enters MODE 4 from MODE 3 the SR would hase to O

be met in MODE 3 prior to entering MODE 4. Verifying the accumulator isolated is not a requirement of the LCO unless the accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the PTI limit curves. Therefore, Comed believes that the use of the " met" Note isjusti0able and necessary to j

reDect the requirements of ITS LCO 3.4.12 and SR 3.4.12.3. Comed Response to NRC Comment e: ITS 1 CO 3.4.12 requires accumulator isolation w henever accumulator pressure is greater than or equal to the maximum RCS pressure for the existing cold leg temperature allow ed in the PTLR, no safety injection pumps capable ofinjecting into the RCS, and a maximum of one charging pump (centrifugal) capable ofinjecting into the RCS. As DOC 3.4-M7 states, CTS LCO 3.4.9.3 does not include requirements for overpressure protection associated with an SI pump capable of injecting into the RCS or two charging (centrifugal) pumps or one charging (positive displacement) pump capable of injecting into the RCS.

Ilowever CTS 3.5.3.a footnote (ITS LCO 3.4.12 item a) and CTS SR 4.5.3.2 (ITS LCO 3.4.12 item b) contain these same requirements, but the requirements hase been mosed to the LTOP specification (ITS LCO 3.4.12) in iIS. As DOC 3.4-M7 I

also states, CTS LCO 3.4.9.3 does not include requirements for an unisolated accumulator whenever accumulator pressure is greater than or equal to the maximum RCS pressure for the existing cold leg temperature allowed in the PTLR.

Therefore, ITS LCO 3.4.12 item c is a more restrictise requirement as discussed in DOC 3.4-M7. Even with the changes discussed above in Comed's Responses to NRC Comments a-d, DOC 3.4-M7 justification still remains valid and unchanged.

NRC RAI Number NRC issued Date RAI Status 3.4.12-02 3/9'98 Open - NRC Action Required i

NRC Description ofIssue j

JFD Pil ITS SR 3.4.12.2 The JFD P11 discussion states that the positive displacement charging pump is not allowed to be capable ofinjection during O

the LTOP conditions. Periodic verification that this is so is required by ITS SR 3.4.12.2. Neither this SR nor the Bases for ITS 3.4.12, however, speci0cally mention the positive displacement pump. Note that ITS SR 3.4.12.1 specifically requires serifying the incapahility of the Si pumps to inject into the RCS. Comment: Revise ITS SR 3.4.12.2 and appropriate parts of the Bases for ITS 3.4.12 to specifically address the positive displacement charging pump to make it unambiguous that these requirements and associated Bases apply to it.

Comed Response to Issue No change. LCO 3.4.12 item a and SR 3.4.12.2 added "(centrifugal)" to clarify that the Positive Displacement Pump (PDP) is not allowed to be capable ofinjection during the LTOP conditions. Because this is Byron /Braidwood current licensing basis and has been adequately addressed in training, Comed does not believe it cost or time beneficial to revise the submittal to incorporate this change.

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NRC RAIdatcd d509/h8

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NRC RAI Number NRC Issued Date

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R IStatus 3.4.12-03 3/9/98 Open - NRC Action Required NRC Description of issue

- DOC A20 DOC L10 JFD P38 JFD 13P50 CTS 3/4.4.9.3 Action d CTS 4.4.9.3.1.a ITS SR 3.4.12.4 and SR 3.4.1.2.7

a. With the RCS vented per Actions a, b, or c CTS 3/4.4.9.3 Action d requires verifying every 31 days that the RCS vent path is open. This action requirement is retained (per DOC A20) as ITS SR 3.4.12.4 which contains a note, that for the most part is consistent with the note to corresponding STS SR 3.4.12.5. The ITS note states this verification is only needed when l

the RCS vent path is relied upon for pressure relief per compliance with ITS LCO 3.4.12.d.4. As discussed by JFD P38, the ITS note replaces the STS note words "only required to be performed" with"only required to be met." (Note that the CTS markup, insert 3.4-39c and DOC A20, mistakenly shows the ITS note as replacing the STS words with the words "only required.") Comment: The concerns expressed in JFD 38 regarding " met" versus " performed" are not valid; this difference l

would represent a generic change to the STS, as apparently addressed by WOG-87. Revise the note to ITS SR 3.4.12.4 to adopt the words of the corresponding STS note. Also, adopt the affected wording of the STS Bases. Finally, correct the l

CTS markup error noted above.

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b. When the PORVs are being used for cold overpressure protection, CTS 4.4.9.3.1.a requires performance of an Analog Channel Operational Test (ACOT) on the PORV actuation channel every 31 days. ITS SR 3.4.12.7 retains this CTS test

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requirement and clarifies, per DOC L10, when it is required with a note, that for the most part is consistent with the note in corresponding STS SR 3.4.12.8. The ITS note replaces the STS words "not required to be met" with "not required to be l.

performed" as discussed in JFD 38. Comment: The concerns expressed in JFD 38 regarding " met" versus " performed" are not valid; this difference would represent a generic change to the STS, as apparently addressed by WOG-87. Revise the note to ITS SR 3.4.12.7 to adopt the words of the corresponding STS note. Also, adopt the affected wording of the STS l

Bases.

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Comed Response to Issue Comed Response to NRC Comment a: Per Comed Response to NRC Comment d for RAI 3.4.12 01, SR 3.4.12.2 Note will be deleted based on withdrawing WOG-51, Revision 1. SR 3.4.12.4, SR 3.4.12.5, and SR 3.4.12.6 Notes will be deleted due to being redundant to the use of the word " required" in the SRs themselves. Therefore, CTS Insert 3.4-39C and DOC 3.4-A20 will be deleted as well. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAls 3.4.12-01 and 3.4.12-04.) Comed Response to NRC Comment b: "Not required to be met. " is more restrictive than "Not required to be performed. " Since CTS SR 4.4.9.3.1.a does not contain a *SR 3.0.4 is not applicable" allowance, Comed cannot justify the use of the " met" Note. By allowing SR 3.4.12.7 to not be " met," the unit would be allowed to enter the mode of applicability with the required PORV(s) knowingly not being able to pass a COT surveillance. Comed believes that this is 1

not the intent of ITS. Furthermore, this is not an allowance in CTS. The unit should have every confidence that the PORV is operable and would pass the Channel Operational Test if performed, but it is not required to be " performed" due to unit conditions. Therefore, the Note should read only "not required to be perfonned.. " Comed continues to pursue this change.

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Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC issued Date RAI Status 3.4.12-04 3/9/98 Open - NRC Action Required NRC Description of Issue JFD P21 ITS SR 3.4.12.2, SR 3.4.12.5 and SR 3.4.12.6 STS SR 3.4.12.2, SR 3.4.12.4, and SR 3.4.12.6 The listed STS SRs do not contain the notes included in the corresponding ITS SRs, as described in the following, and somewhat in JFD 21.

The note to ITS SR 3.4.12.2 states that the verification that no SI pumps are capable ofinjecting into the RCS is "not required to be met during [Sl] pump swap operation. This is a new SR to ensure compliance with new LCO 3.4.12.b. as discussed in DOC M.7. Ilowever, the note is not technicallyjustified or even discussed in DOC M.7. Thus, it may be a valid plant-specific difference from the STS. Unfortunately, JFD P21 doesn'tjustify it either.

The note to ITS SR 3.4.12.5 states that the verification that RIIR suction valves are open for each required RilR suction relief path is "only required to be met w hen complying with LCO 3.4.12.d.2 [two RIIR suction relief valves providing the pre sure relief capability] or LCO 3.4.12.d.3 [one PORV and one RilR suction relief valve providing the pressure relid capability)." This SR retains the requirements of CTS 4.4.9.3.2, and ensures compliance with LCO 3.4.12.d.2 or LCO 3.4.12.d.3, as applicable.

The note to ITS SR 3.4.12.6 states that the verification that each PORV block valve is open for each required PORV is "only required to be met when complying with LCO 3.4.12.d.] [two PORVs providing the pressure relief capability] or LCO 3.4.12.d.3. This SR retains the requirements of CTS 4.4.9.3.1.c, and ensures compliance with LCO 3.4.12.d.1 or LCO 3.4.12.d.3, as applicable.

The CTS markup does not appear tojustify these notes. Also, JFD 21 is not accepted because it represents a generic editorial change to the STS, and is unnecessary. Comment: (1) Technically justify the note to ITS SR 3.4.12.2 on a plant-specific basis, or withdraw it making appropriate changes. (2) Revise the submittal to withdraw the other notes making appropriate changes to the DOCS, JFD 21, and 13ases. The response to this comment may be combined with the response to similar comment 3.4.12-01. Note, the proposed generic changes represented by these notes are related to WOG-100.

Comed Roponse to issue Per Comed Response to NRC Comment d for RAI 3.4.12-01, SR 3.4.12.2 Note will be deleted based on withdrawing WOG-51, Revision 1 (not WOG-100). SR 3.4.12.4, SR 3.4.12.5, and SR 3.4.12.6 Notes will be deleted due to being redundant to the use of the w ord " required"in the SRs themselves. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAls 3.4.12-01 and 3.4.12-03.)

NRC RAI Number NRC issued Date RAI Status 3.4.12-05 3/9/98 Closed NRC Description of issue Not used Comed Response to Issue No response required.

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Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC issued Date RAI Status

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3.4.12-06 3/9'98 Open - NRC Action Required NRC Description of Issue CTS 4.4.9.3.2, item a and b STS SR 3.4.12.4 ITS SR 3.4.12.5 CTS 4.4.9.3.2 item a and b require that at least once every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months that the RilR suction valves are verified to be open.

ITS SR 3.4.12.5 retains this verification requirement, including the 72-hour Frequency. Corresponding STS SR 3.4.12.4, however, requires this serification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The ITS Basesjustifies the 72-hour Frequency using the STS Bases' justification for the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency; how can that be acceptable? In addition, the Frequency should be consistent with the Frequencies of similar verifications of RiiR loop Operability specified by ITS SR 3.4.6.1, ITS SR 3.4.7.1, and ITS SR 3.4.8.1. Each of these require that the required RilR loops be verified as Operable and.'or in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Operable means to verify the position of valves in the flow path which is the same check required by ITS SR 3.4.12.5.

Comment: Revise the submittal to adopt the STS Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and add a justification for this more restrictive surveillance interval. The requirements in the ITS for RiiR system ought to be as consistent as are the corresponding requirements in the STS.

Comed Response to issue No change. Verifying that the RilR suction relief valves are open at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is current licensing basis.

Furthermore. STS SR 3.4.12.4 is a bracketed surseillance, whereby in the conversion to ITS the utility adds their plant specific value. Comlid continues to pursue the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months frequency of our current licensing basis.

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RcSponSe to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RAI Status

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3.4.12-07 3/9/98 Open - NRC Action Required NRC Description of Issue DOC Al JFD BPI CTS 4.4.9.3.2.c ITS SR 3.4.12.5 STS SR 3.4.12.4 CTS 4.4.9.3.2.c requires for the RHR suction relief vahes " Testing pursuant to Specification 4.0.5." The ITS apparently does not retain this specific requirement.

Also, the Bases of ITS SR 3.4.12.5 does not adopt the text regarding IST contained in the Bases discussion for corresponding STS SR 3.4.12.4. This change and difference are not editorial but are less restrictive uchnical CTS changes uhich require a separate justification. Comment: Revise the submittal with additional technical justification for deleting the IST program CTS requirements for RilR relief valves. Why is there no SR for testing in accordance with the IST Program for these valves? See comment 3.4.12-11.

Comed Response to issue DOC A33 was created to discuss CTS Specification 4.0.5 relocation. DOC A33 states. " CTS Specification 4.0.5 provides surveillance requirements for inservice inspection and testing of ASME Code Class I,2, and 3 components. In accordance w ith NUREG-1431, CTS Specification 4.0.5 has been relocated to ITS Specification 5.5.8, " Inservice Testing Program."

The requirements for Inservice Testing have not changed and are still consistent with ASME Section XI. The requirements for the inservice inspection are contained in 10 CFR 50.55a and therefore not included in the NUREG. This change has been justified in the ITS submittal as an administratise change throughout the CTS markups since no ASME or CTS l

Inservice Testing requirements were changed. The only change that was made was in relocation of the requirements from CTS 4.0.5 to ITS 5.5.8." In addition, Comed will revise the Bases for ITS SR 3.4.12.5 to adopt the STS text stating, "The ASME Code,Section XI (Ref. 7), test per Inservice Testing Program serifies OPERABILITY by proving proper relief valve mechanical motion and by measuring and, if required, adjusting the lift setpoint." This change w ill be provided in our s

comprehensise ITS Section 3.4 closecut submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI. (See RAI 3.4.11-02.)

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC lssued Date RAI Status 3.4.12-08 3/9/98 Open - NRC Action Required NRC Description of Issue IFD P20 CTS 3/4.4.9.3 Action f ITS 3.4.12 Actions Note CTS 3/4.4.9.3 Action f states "The provisions of Specification 3.0A are not applicable." Since CTS 3/4.4.9.3 only addresses the RilR suction relief valves and the PORVs, it appears that this Mode-change restiction exception is retained as the Actions Note to ITS 3.4.12. This Actions Note states "LCO 3.0.4 is not applicable to the RCS relief valves." Based on maintaing the CTS allowance, this appears acceptable. This note does not address the RCS vents. The STS, however, does not contain this note. JFD 20 does not adequately explain why it is acceptable to enter into the Applicability of ITS 3.4.12 without first serifying the Operability of the RCS relief valves that are to be relied upon for overpressure protection. The statement in JFD P20 and the Bases for this note, that the Required Actions for inoperable relief valves provide an acceptable level of safety, is not convincing. In Mode 4, Action E allows 7 days to restore an inoperbale relief valve. In Mode 5 and Mode 6 with the sessel head on, Action F allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . And in any of these Modes, Action G allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore two inoperable relief vahes. For any of these conditions and failure to satisfy these Actions, Action G requires depressuring the RCS with an open RCS sent. These Completion Times are consistent with the STS. Yet the STS does not allow an exception to LCO 3.0.4. Comment: Please revise the submittal to provide additional discussion and technicaljustification for the Actions note.

Comed Response to issue CTS 3.4.9.3 requires at least two overpressure protection devices to be OPERABLE, either an RilR suction relief valve or a PORV, in Modes 4,5, and 6 with the reactor vessel head on. In the event that one or both required devices are inoperable, the C15 provides specific actions with Completion Times ranging from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 7 days. The CTS also contains Action f w hich states, "The provisions of Specification 3.0.4 are not applicable." Action f allows changing Modes without having

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the overpressure protection devices OPERABLE. As previously stated, the inoperability can range from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 7 days.

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The ClS actions also require that the inoperable device (s) be returned to OPERABLE or an RCS vent be established (at least 2 square inch sent) within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . STS LCO 3.4.12 requires the same pressure relief capabilities be OPERABLE in the same Modes as the CTS. The STS however, adds the RCS vents to the LCO as one of the pressure relief capabilities. In addition, the STS does not allow any LCO 3.0.4 exceptions. Therefore, the pressure relief capabilities required by the LCO must be OPERABLE for any rnode changes to occur. The ITS Note is being revised to state, "LCO 3.0.4 is not applicable to the RCS pressure relief capabilities." Adding this Note brings the ITS into compliance with our current licensing basis. Comed believes this to be acceptable since the ITS Required Actions and associated Completion Times are the same as those in the CTS. Therefore, there is no change in any assumptions, calculations or equipment between our current licensing basis and the ITS. Thus, no increase in any probability of any accident previously analyzed, no new or different accident introduced, and no decrease in the margin of safety. Based on the above, Comed will continue to pursue and maintain our current licensing basis by retaining the Actions Note as revised by this RAl. This change will be provided in our comprehensive ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed responses to the ITS Section 3.4 RAl.

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l Response to NRC RAI Dated 03/09/98 16-Apr-98

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NRC RAI Number NRC issued Date RAI Status lg 3.4.12-09 3/9/98 Open - NRC Action Required NRC Description of Issue JFD Pl 13ases JFD Pl j

ITS LCO 3.4.12 The initial words of ITS LCO 3.4.12 differ from the STS as follows: "An LTOP System shall be OPERABLE provided i

with:" This difference is not editorial because LTOP is apparently no longer considered a system and it no longer requires an Operability requirement. The first part should closely follow the STS v ording, as follows: "An LTOP System shall be OPERABLE with:" Comment: The proposed editorial difference from the STS is not justifiable on a plant-specific or editorial basis. Revise the LCO to adopt the suggested words and make appropriate language changes in the Bases to l

conform to the STS.

Comed Response to Issue i

Comed will revise the LCO to adopt the suggested words and make appropriate language changes in the Bases to conform j

to the STS. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

NRC RAI Number NRC Issued Date RAI Status 3.4.12-10 3/9/98 Closed I

l NRC Description of issue Not Used i

Comed Response to Issue No response required.

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Rcsponse to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RAI Status

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3.4.12-11 3/9'98 Open - NRC Action Required f

v NRC Description of issue JFD 112 Bases JFD B2 STS SR 3.4.12.7

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Bases llackground discussion for suction relief salve requirements.

l STS markup page B 3.4-60 Bases JFD P31 ITS does not adopt STS SR 3.4.12.7, verification that each required open RilR suction isolation valve is locked open with power removed (apparently needed when the associated RllR relief valve is used to satisfy the LCO for overpressure protection). JFD B2 and JFD Bases B2 are not detailed enough to determine the validity of this omission. Comment:

Revise the submittal with plant-specific technicaljustification for this deviation from the STS. The CTS markup page 3/4 5-5 indicates that CTS 4.5.2.d.1)is retained as ITS SR 3.4.14.2. The NRC staff understands that the RilR suction valve autoclosure is no longer a part of the unit design. Note - the absence of the autoclosure feature from the unit design was discussed with Kelly Root of Braidwood on 2/13/98 by telcon. Ilowever, the information m the submittal does not clearly explain w hy this design difTerence necessitates deviations from the STS; niether does it clearly list all such deviations.

Note - Bases JFD P31 contradicts the preceding stated staff understanding about the autoclosure interlock; JFD P31 states it is a part of the unit design as described in FSAR Section 5.4.7.2.3, but is controlled by procedure. Ifit is part of the unit design, then the STS provisions related to it and associated Bases ought to be adopted to ensure the Operability of the RilR relief valses w hen they are relied upon for RCS overpressure protection to meet ITS LCO 3.4.12. Note FSAR Section 5.4.7.2.3 was reviewed and it supports the absence of the autoclosure interlock from the design. Suggest that JFD P42 he resised to also address not adopting STS SR 3.4.12.7.

Comed Response to issue

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No change. NUREG SR 3.4.12.7, SR 3.4.14.2, and SR 3.4.14.3 are bracketed suneillances. Comed believes that I.CO

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JFDs 3.4-B2 and 3.4-B3 are sufficient forjustifying the deletion ofinformation that is not applicable to Byron and Braidwood, and that this approach is consistent with conversion guidelines and the process used throughout the submittal.

Comed agrees that Bases JFD 3.4-P31 is incorrect in stating that an autoclosure interlock is provided. Bases JFD 3.4-P31 l

will be resised to state, "NUREG-1431 SR 3.4.14.3 and associated Bases have been deleted and the Bases for both LCO 3.4.12 and LCO 3.4.14 are revised to omit references to the autoclosure interlock. Only the open permissive interlock l

function is included. This is consistent with CTS SR 4.5.2.d.1 and NRC SER dated 8/31/90 for Amendment 38'25. The l

interlock is discussed in UFSAR Section 5.4.7.2.3 " This JFD discussion is bred on the following excerpt from UFSAR Section 5.4.7.2.3, "During plant startup, the inlet isolation valves are shut admmistratisely. However, an alarm is provided l

to alert the operator in the event that double isolation is not being maintained w hen RCS pressure increases above 400 psig.

These isolation vak es are pros ided w ith " prevent-open" interlocks, which are designed to prevent possible exposure of the RilR System to normal RCS operating pressure.. The use of two independently powered motor-operated valves in each of the tw o inlet lines, along with tw o independent pressure interlock signals in the opening and alarm circuitry ensures a design which meets applicable single failure criteria." This change will be provided in our comprehensive ITS Section 3.4 closcout i

submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC Issued Date RAI Status 3.4.12-12 3/9/98 Open - NRC Action Required NRC Description of issue LA14 CTS 4.5 4 2.1 (Note - this is the principal reference for this comment.)

CTS 4.5.4.1 and associated Note

CTS 3.5.4.1 CTS 3/4.5.4.1 Ac' ion CTS 4.5.3.2 ITS SR 3.4.12.1 Bases for ITS 3.4.12 CTS 4.5.4.2.1 requires at least one Si pump shall be demonstrated available when required es ery 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.12.1 s erifies no SI pump is capable of injecting into the RCS. These two SRs do not appear to be equivalent, but this is implied by the CTS markup, page 3/4 5-10. Also, the discussion in DOC LA14 only supports removing details about restricting sources of high pressure water injection into the RCS. This change, however, removes details related to the Operabihty of required Si pump and associated How path from the RWST to the RCS. Further, the discussion in DOC LA14 does not specifically address (or list) CTS 4.5.4.2.1, so there is a question about w hether it applies to the detail removal as indicated l

in the CTS markup. A new CTS DOC seems to be required tojustify the removing the details of CTS 4.5.4.2.1 to the Bases. Comment: Revise the submittal with the indicated technicaljustification. In addition, state where the information, j

as indicated by the markup of CTS 4.5.4.2.1, is contained in the ITS Bases.

Comed Response to Issue JFD 3.4-LA14 will be revised to add a paragraph which states, " CTS LCO 3.5.4.2 establishes controls which ensure that diverse means ofintroducing makeup water from the RWST to the RCS are available in the event that a loss ofinsentory or loss of forced circulation occurs which results in a loss of decay heat removal. De LCO requires a Safety injection (SI)

O pump and flow path or an adequate RCS vent to allow gravity feed from the RWST to be available when in Mode 5 and 6 h

with the pressurizer level less than or equal to 5 percent. These requirements were added in response to Generic Letter (GL) 88-17. " Loss of Decay lleat Removal." This Specification does not satisfy the Technical Specification Screening Criteria (see iTS Section 3.5 DOC RI). Iloweser, CTS SR 4.5.4.2.1 also provides Low Temperature (cold) Overpressure Protection (LTOP) from inadvertent Si actuation as indicated in the SER for Byron /Braidwood Amendment 38/25, Section 2.2 dated At. gust 31,1990. This portion of the requirements is retained in ITS SR 3.4.12.1. The detail of demonstrating the availability of the Si pump is relocated to the TRM. The relocation of this information maintains the consistency with NUREG-1431. Any change to this iequirement is made in accordance with 10 CFR 50.59." This change will be provided in our comprehensive ITS Section 3.4 closeout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

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Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RAI Status 3.4.12-13 3/9/98 Open - NRC Action Required NRC Description of issue D.OC LA25 CTS 3/4.4.9.3 Action e CTS 3/4.4.9.3 Action e, requires a report to the NRC in the event the specified pressure relief valves are used to mitigate an RCS pressure transient, pursuamt to CTS 6.9.2. This Action is not retained in ITS 3.4.12 but is moved to the TRM. The 4

justification in DOC LA25 states it is acceptable to relocate this requirement to the TRM because the Special Report is not approved by the NRC. Staff disagrees. The only acceptable basis for this relocation is whether there exists any redundancy in regulatory requirements w hich control the preparation and submittal of the event reports to the NRC. Comment: Revise the submittal to provide additional technicaljustification for moving this reporting requirement to the TRM. If not addressed in response to another similar comment, list the dispostion of all such CTS reporting requirements, and show that the submitted justifications are consistent with the accptable basis noted above. (i.e., this may be a global comment.)

Comed Response to Issue Comed will revise DOC 1.A25 to state, " CTS 3.4.9.3.e provides a requirement to submit a Special Report in accordance with CTS Specification 6.9.2 in the event that the PORVs, the R11R suction relief valves, or the RCS vents are used to mitigate an RCS pressure transient. This requirement is to be relocated to the TRM. Relocating this requirement to the TRM is consistent with other required reports in the CTS. As discussed in Section 5.0, DOC Al2, CTS Specification 6.9.2 has been res ised to delete the reference to the submittal location for the Special Reports. The requirements related to report submittal are contained in 10 CFR 50.36,10 CFR 50.72, and 10 CFR 50.73. Since conformance to 10 CFR 50 is a condition of the license, specific identification of this requirement in the TS would be duplicative and is not necessary. In addition, the Special Reporting requirements are deleted from the STS since they do not meet 10 CFR 50.36(c)(2)(ii) criteria for retention in the T S. As such, the relocated requirement is not required to be in the TS to provide adequate protection of the public health and safety. The relocation of this requirement maintains the consistency with NUREG-1431. Any l

changes to this requirement will be made in accordance with 10 CFR 50.59." This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed responses to the ITS Section 3.4 RAl.

NRC RAI Number NRC Issued Date RAI Status 3.4.12-14 3/9/98 Closed NRC Description of Issue Not used Comed Response to issue No response required.

NRC RAI Number NRC lssued Date RAI Status 3.4.12-15 3/9/98 Closed NRC Description of issue Not used Comed Response to issue No response required.

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Rcsponse to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC lisucEl Date RAI Status 3.4.12-16 3/9/98 Closed NRC Description of Issue Not used Comed Response to Issue No response required.

NRC RAI Number NRC issued Date RAI Status 3.4,12-17 3/9/98 Open - NRC Action Required NRC Description of Issue flases JFD PI Bases for ITS SR 3.4.12.7, STS markup page B 3.4-71 The second paragraph of the Bases for STS SR 3.4.12.8 has not been adopted in the llases for corresponding ITS SR 3.4.12.7. This omission is not explicitly justified.

Comment: Revise the submittal to adopt the omitted paragraph.

Comed Response to Issue Comed will revise the submittal to adopt the omitted paragraph. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

NRC RAI Niimber NRC Issued Date RAI Status j

3.4.13-01 3/9/98 Closed D

NRC Description of Issue Not used Comed Response to issue No response required.

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Rcsponse to NRC RAI Dated 03/09/98 16-Apr.98 NRC RAI Number NRC Issued Date RAI Status 3.4.13-02 3/9'98 Open-NRC Action Required NRC Description of issue DOC LA24 CTS 4.4.6.2.1.a. b, and e CTSs 4.4.6.2.1.a. b, and e require monitoring the containment atmosphere radiation monitor, the reactor cavity sump discharge, and the containment Door drain sump discharge and inventory at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and the reactor head Hange leakoff system at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . DOC LA24 states these surveillances are relocated to the TRM because they are not necessary to ensure RCS operational leakage is maintained within limits. This is not a sufGcient technical justiGcation. Comment: Revise DOC LA24 with additional technicaljustiGeation for moving these SRs to the TRM.

Describe how the ITS will ensure RCS of.erational leakage is maintained within limits.

Comed Response to issue Comed will revise DOC LA24 to state, " CTS SR 4.4.6.2.1.a, SR 4.4.6.2.1.b, and SR 4.4.6.2.1.e provide requirements for monitoring the containment atmosphere radioactivity, reactor cavity sump discharge, the containment Door drain sump discharge, and ins entory, and the reactor head Hange leakoff. These requirements are being relocated to the Technical Requirements Manual (TRM). These requirements, along with other ITS requirements, provide monitoring functions for indicating RCS Operational Leakage. These speciGe requirements do not meet the 10 CFR 50.36(c)(2)(ii) criteria for retention in the STS and therefore the ITS. However, their function provides an additional and independent operational indicator for RCS leakage and needs to be retained in a Licensee Controlled Document. The requirements of ITS LCO 3.4.13 provide adequate assurance that RCS Operational Leakage is maintained within the required limits. The relocateo information is not necessary to be in ITS to ensure RCS Operational Leakage is within limits. As such, the relocated information is not required to be in the ITS to provide adequate protection of the public health and safety. The relocation of these requirements maintains the consistency with NUREG-1431. Any change to these requirements will be made in accordance with 10 CFR 50.59. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed responses to the ITS Section 3.4 RAl.

NRC RAI Number NRC Issued Date RAI Status 3.4.13-03 3/9/98 Open - NRC Action Required NRC Description of issue 13ases JFD Pl Bases for STS 3.4.13 Action B, STS markup page B 3.4-76 The Grst paragraph, second sentence of the Bases for Required Actions B.I and B.2 is not adopted. The following is not retained: "It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE." Bases JFD P1 does not explain why this statement is not applicable to Byron & Braidwood. Comment: Revise the submittal to adopt the omitted sentence, which is generally applicable to Westinghouse 4-loop design.

Comed Response to issue Comed will revise the submittal to adopt the omitted sentence. This change will be provided in our comprehensive ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

41

Rcsponse to NIIC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC issued Date

' RAI Status O

3.4.13-04 3/9/98 b

Open - NRC Action Required NRC Description ofIssue Bases JFD P43 Bases for SR 3.4.13.1, STS markup page B 3.4-77 The fourth paragraph of the Bases discussion of STS SR 3.4.13.1 is not adopted. This text clearly explains that the leakage monitoring requirements of CTS 3/4.4.6.2 are now located in ITS 3.4.15 which is important information rather than just a cross reference in the Bases. This Bases text (and Comment number 3.4.13-02 above) denotes the importance of these monitors for the detection of reactor coolant system pressure boundary leakage and unidentified leakage. The omitted Bases text applies. Comment: Revise the Bases to adopt the omitted paragraph.

Comed Response to issue Comed will revise the Bases to adopt the omitted paragraph with one exception. The word " automatic" is being deleted '

since there is no automatic system associated with containment sump level. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

i NRC RAI Number NRC issued Date RAI Status 3.4.14 01 3/9/98 Open - NRC Action Required NRC Description of Issue JFD P41 ITS LCO 3.4.14 STS LCO 3.4.14 j

CTS 4.4.6.2.2 j

ITS LCO 3.4.14 states Each RCS PlV shall be OPERABLE." STS LCO 3.4.14 states " Leakage from each RCS PlV shall be within limits " JFD P41 states the revision is to reflect both the leakage requirements and the interlock functions requirements. This deviation from the STS is generic and is not justifiable on a plant-specific basis.

Comment: Revise ITS LCO 3.4.14 to conform to STS LCO 3.4.14 which is consistent with CTS 4.4.6.2.2.

Comed Response to Issue Comed will revise ITS LCO 3.4.14 to conform to STS LCO 3.4.14. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

e 42

Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number

' NRC issued Date RAI Status l

3.4.14-02 3/9/98 Open - NRC Action Required NRC Description of issue JFD P46 ITS 3.4.14 Actions Note 2 ITS 3.4.14 Actions Note 2 differs from the STS note as indicated: " Enter applicable Conditions and Rcquired Actions for systems if made inoperable by an inoperable PlV." Acceptance of this editorial deviation would require approval of a l

generic change to the STS addressing all applicable locations in the STS rather than sporadic changes here and there as implied by JFD P46. Besides, the STS presentation is clearer than the proposed deviation. Comment: Revise the Actions note to conform to the STS wording.

l Comed Response to issue l

The Note will be revised to adopt the STS w ording. This change will be provided in our comprehensive ITS Section 3.4 l

closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. Note: This i

change is applicable to ITS LCOs 3.3.5, 3.3.6, 3.4.14, 3.6.2, 3.6.3. 3.7.7, 3.7.8, 3.8. I, 3.8.2, and 3.8.7. (See RAis 3.6.2-02, 3.7.7-04, and 3.7.8-06.)

NRC RAI Number NRC issued Date RAI Status 3.4.14-03 3/9/98 Open - NRC Action Required NRC Description of issue JFD Bl JFD B2 ITS 3.4.14 Action A Note STS 3.4.'4 Grst alternative Required Action A.2 (bracketed)

ITS 3.4.14 Action A Note has adopted the bracketed phrase "[or the high pressure portion of the system]" in the STS Action A note. Ilowever the ITS does not adopt bracketed STS 3.4.14 first alternative Required Action A.2, pertaining to vahes in the high pressure portion of the system. This is an inconsistent usage of the STS. If Comed does not used the Grst alternate, then this bracketed phrase in the note cannot be adopted. Comment: Revise the submittal to correct this STS technical usage error.

Comed Response to issue ITS 3.4.14 Required Action A Note has adopted the bracketed phrase "[or the high pressure portion of the system]" of the NUREG. Comed will revise the submittal to adopt the bracketed Grst alternative speciGed in Required Action A.2 to make the ITS Note and the Required Actions consistent. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

l O

43 l

1 h

Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC issued Date RAI Status 3.4.14-04 3/9/98 Open - NRC Action Required NRC Description of Issue JFD P1 ITS 3.4.14 Required Actions A.1 and B.1 ITS 3.4.14 Required Action A.1 difTers from the STS by adding a "de-energized power operated" valve to the list of valve alternatives. And ITS 3.4.14 Required Action B.I differs from corresponding STS 3.4.14 Required Action C.1 so only a "de-energized" valve is used instead of a closed manual or de-activated automatic valve. These are not editorial deviations but are technical deviations that are not justified by JFD Pl. Comment: Revise the submittal to adopt the STS word;ng or add a JFD with an appropriate plant-specife justification.

Comed Response to issue Comed will add an LCO JFD tojustify this change. The JFD will state, "The references to " manual," " remote-manual,"

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

Automatic air operated valves and automatic electric operated valves fall into this category power operated valves, on the other hand, require a motive force to actuate, such as air or electric, but do not receive an automatic actuation signal. Air power operated valves and electric power operated valves fall into this category. Therefore, including the reference to

" power operated" isolation valves reduces the potential for misinterpreting the requirements of the Required Action, while maintaining the assumptions of the accident analysis, and is consistent with plant specific terminology. The words " closed manual or deactivated automatic" have been deleted from NUREG Required Action (RA) C.I due to those classifications of valves not being applicable to the penetrations with the RiiR System suction isolation valves. With the RilR System suction isolation valve interlock function inoperable, ITS RA B.1 requires that the affected RilR suction penetration be isolated by at least one de-energized pow er operated valve, i.e., an RilR suction isolation valve " This change will be

[

provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAI 3.6.3-07.)

NRC RAI Number NRC Issued Date RAI Status 3.4.14-05 3/9/98 Closed NRC Description of issue Not used Comed Response to Issue No response required.

NRC RAI Number NRC Issued Date RAI Status 3.4.14-06 3/9'98 Open - NRC Action Required NRC Description of Issue JFD Pl CTS 4.4.6.2.2.b ITS SR 3.4.14.1

'The Frequency Note Stating " Prior to entering Mode 2.. " has been editorially changed in ITS SR 3.4.14.1 w hen the CTS'STS wording for this statement is identical. Comment: Please revise the submittal. The STS text is applicable, clear, and should be adopted.

Comed Response to Issue No change. While Comed agrees that the NUREG text is clear as written, it is not standard Il S format to use "w ords" in F

place of equalities and inequalities in ITS. A phrase such as "7 days or more" is not used anywhere else in the NUREG and therefore, Comed continues to pursue this change for consistency throughout ITS.

44

1 lhshonse to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number ~

~ liAlStatus NRC issued Date 3.4.14-07 3/9/98 Open - NRC Action Required NRC Description of Issue JFD Pl C fS 3.4.6.2.f footnote

ITS SR 3.4.14.1 Bases for STS LCO 3.4.14, STS markup page B 3.4-81 in ITS SR 3.4.14.1, the test pressure for PlV leakage testing differs from the STS requirement because it specifies an

" equivalent" RCS pressure for testing PlVs. CTS 3.4.6.2.f footnote *, w hich pertains to defining the equivalent pressure for PlV testing, is moved to the TRM, as explained by DOC LA10, because these details are not needed in the ITS. Note, however, that the last paragraph of the Bases for STS LCO 3.4.14 already contains the information specified by the CTS footnote. Comment: The addition of the modifier " equivalent" is an unnecessary generic change and is not accepted. Revise the submittal to adopt the STS wording. Revise DOC LA 10 to explain that the allowance to use an equivalent pressure is moved to the Bases in addition to the TRM. Suggest augmenting the Bases for ITS SR 3.4.14.1 to explicitly discuss the testing at lower pressures; i.e., at equivalent pressures - scaling the leakage measured at a reduced pressure to the equivalent leakage at the specifiied test pressure for comparison to the specified leakage limit.

Comed Response to issue DOC 3.4-LA10 will be revised to state, " CTS LCO 3.4.6.2 Footnote

provides details of Pressure Isolation Valve (PlV) test performance for various unit conditions. These details are to be relocated to the ITS Bases. The requirements ofITS SR 3.4.14.1, which include leakage limits stated in terms of equivalent leakage rates with a specified pressure range, are adequate to ensure RCS PlV leakage is within required limits. As a result, the relocated details are not necessary for ensuring RCS PlV leakage is within required limits and do not need to be included in the TS to provided adequate protection of the public health and safety. The relocation of these details maintains the consistency with NUREG-1431.

Any change to these details will be made in accordance with the Bases Control Program described in ITS Section 5.5 " In

[

addition, the modifier " equivalent" will be withdrawn from ITS SR 3.4.14.1, and the ITS Bases will be revised to include the details associated with the CTS footnote. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

NRC RAI Number NRC Issued Date RAI Status 3.4.14-08 3/9/98 Open NRC Action Required NRC Description ofIssue JFD P26 ITS SR 3.4.14.1 ITS SR 3.4.14.1 omits the STS' requirement to perform PlV leakage testing at a Frequency in accordance with the Inservice Test Program. The ITS requiress the test to be performed at 18 month intervals but not per the IST Program. JFD P26 and Bases JFD P1 for SR 3.4.14.2 do not adequatelyjustify this deviation. Comment: Revise ITS SR 3.4.14.1, and associated i

Bases, to adopt the STS Frequency of"in accordance with the Inservice Test Program."

Comed Response to issue Comed will revise ITS SR 3.4.14.1 Frequency to state,"In accordance with the Inservice Testing Program." The PlVs are tested in accordance with the Station's IST Program which was developed in accordance with ASME Section XI requirements. In addition, Comed will delete the 18 month Frequency currently in ITS since the Inservice Testing Program Frequency is also 18 months. It is not standard NUREG format to include specific times with Frequencies which are in accordance with Programs, such as "In accordance with the Inservice Testing Program." There is no benefit in stating the same time Frequency for the same SR twice. Comed will revise the ITS Bases for SR 3.4.14.1 to include the STS wording referencing the Inservice Testing Program. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

O 45

Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC issued Date RAI Status 3.4.14-09 3/9/98 Open - NRC Action Required NRC Description of issue JFD P47 CTS 4.4.6.2.2.b ITS SR 3.4.14.1 Frequency The wording of the third Frequency ofITS SR 3.4.14.1 difTers from the STS. Instead of"Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following., it says "Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after. " Comment: These editorial changes are unnecessary and not justificable on an editorial or plant-specific basis. The STS wording is clear. Adopt the STS version of the Frequency.

Comed Response to issue Comed will adopt the STS version of the Frequency. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAls 3.1 01,3.1.6-04,3.6.3-09,3.4.16-05, and 3.4.18-03.)

NRC RAI Number NRC issued Date RAI Status 3.4.14-10 3/9/98 Closed NRC Description of issue Not used Comed Response to issue No response required.

NRC RAI Number NRC issued Date RAI Status

(.

3.4.14-11 3/9/98 Closed NRC Description of issue Not used Comed Response to Issue No response required.

NRC RAI Number NRC issued Date RAI Status 3.4.14-12 3/9/98 Open - NRC Action Required NRC Description of issue Bases JFD Pl Bases for ITS 3.4.14 Action Notes, STS markup page B 3.4-81 in the first paragraph, the fourth sentence the ITS differs from the STS as follows: " Note 2 requires an evaluation of affected systems Emergency Core Cooling System subsystems if a PlV is inoperable. The ITS wording appears to be less restrictise than the STS wording because some of these PlVs could also be considered to be in the CVCS or RCS Systems. Thus, this may not be just an editorial change, and may also be generic. Comment: Revise the Bases to adopt the STS wording.

Comed Response to issue Comed will revise the Bases to adopt the STS wording. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

O 46

Rcsponse to NRC RAI Datcd 03/09/98 16-A pr-98

~

NRC RAI Number NRC lssued Date RAI Status 3.4.14-13 3/9/98 Closed NRC Description of Issue Not used Comed Response to issue No response required.

NRC RAI Number NRC issued Date RAI Status 3.4.15-01 3/9/98 Open - NRC Action Required NRC Description ofIssue DOC Ll7 DOC L19 JFD P27 JFD BP27 CTS 3.4.6.1.a and c CTS 3.4.6.1 Action c ITS 3.4.15 and Action B CTS 3.4.6.1.a, b, and c define three separate RCS leakage system monitors as required to be Operable. Reg Guide 1.45 requires this number of diverse monitors and a minimum of two shall always be Operable. STS 3.4.15 contains provisions to ensure that two diverse monitors are Operable. ITS 3.4.15 and Action B have changed the CTS requirements to combine i

the separate gaseous and particulate monitoring functions into one monitor. The result is that when the one monitor is lost then both functions are lost. Also, the time permitted for this inoperable condition has been extended from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 30 days with only the one sump monitor Operable during this period. For a 30 day period, w hen one of three are inoperable (if Condition B was changed to a gaseous or paniculate monitor is inoperable) perfonning SR 3.4.13.1 is acceptable compensatory action. When two of the three (both gaseous and particulate functions) monitors are inoperable for a 30 day period, SR 3.4.13.1 or grab samples as the next monitoring system is not acceptable because the monitoring response times are greatly extended. This ITS Action B is contrary to the intent of Reg Guide 1.45. Comment: Please provide additional discussion and technicaljustification for this less restrictive change.

Comed Response to Issue Comed will rew rite ITS 3.4.15 to incorporate a Condition w hen one gaseous or particulate containment atmosphere radioactivity monitoring function is lost, and w hen both the gaseous and paniculate containment atmosphere radioactivity monitoring functions are lost. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

NRC RAI Number NRC lssued Date RAI Status 3.4.15-02 3/9/98 Closed NRC Description of Issue Not used Comed Response to Issue No response required.

N 47

f I

i Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NRC Issued Date RAI Status 3.4.15-03 3/9/98 Open - NRC Action Required NRC Description of Issue DOC LA9 CTS 3/4.4.6.1 Action a Bases for ITS 3.4.15 Action B, STS markup page B 3.4-89 l

l CTS 3.4.6.1 Action a requires analysis of the containment atmosphere grab samples for gaseous and particulate l

radioactivity. DOC LA9 says the specific requirement to analyze the grab samples for both particu ate and gaseous activity l

is a detail which is moved to the ITS Bases. The Bases for ITS 3.4.15 Action B, however, only mentions taking grab samples, but does not describe the CTS requirement for analysis. Comment: Even though the proposed discussion in the i

Bases for ITS 3.4.15 Action B is consistent with the STS, it must be res ised so that the statement in DOC LA9 is accurate.

Comed Response to Issue The first paragraph of the Actions Section of the Bases for ITS LCO 3.4.15 for Actions B.1 and B.2 will be revised to state, "Either grab samples of the containment atmosphere must be taken and analyzed for gaseous and particulate radioactivity or water insentory balances, in accordance. " This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAI.

NRC RAI Number NRC Issued Date RAI Status 1

3.4.16-01 3/9/98 Closed NRC Description of issue Not used Comed Response to issue No response required.

NRC RAI Number NRC issued Date RAI Status 3.4.16-02 3/9/98 Closed NRC Description of Issue Not used Comed Response to issue No response required.

NRC RAI Number NRC lssued Date RAI Status 3.4.16-03 3/9/98 Closed NRC Description of issue Not used Comed Response to issue No response required.

7 48

Response to NRC Rkl Dated 53/09/98 16-Apr-98 NRC RAI Number

'NRC Issued Dcte RAI Status 3.4.16-04 3/9/98 Open-NRC Action Required NRC Description of Issue JFD P29 CTS Table 4.4-4 Measurement Type 3. Footnote

STS SR 3.4.16.3 and Note ITS SR 3.4.16.3 and Note CTS Table 4.4-4 Measurement Type 3, Footnote

states the timing for the beginning of Frequency for when the E-bar determination is to be taken. STS SR 3.4.1.6.3 states this interval in both the Note and the SR 3.4.16.3. ITS SR 3.4.16.3 only states this timing in the Note. The change is not a plant specific change based upon a current CTS requirement.

Comment: Revise the submittal to adopt the omitted text of STS SR 3.4.16.3.

Comed Response to issue Comed will revise the submittal to adopt the omitted text of STS SR 3.4.16.3. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

NRC RAI Number NRC issued Date RAI Status 3.4.16-05 3/9/98 Open - NRC Action Required NRC Description of issue i

JFD P47 Bases JFD Pl i

CTS Table 4.4-4, Measurement Type 4b STS SR 3.4.16.2 Frequency and associated Bases ITS SR 3.4.16.2 Frequency and associated Bases in ITS SR 3.4.16.2, the word "once" is added to the STS Frequency which specifies a Frequency of"within" a particular time frame. For this Frequency, "within" is "between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months atler a Thermal Power change of 15% RTP within a i hour period." It is clear that the STS (and CTS) Frequency means once for each such power change. Also, the STS SR Frequency is u orded the same as the wording of the Frequency for CTS Table 4.4-4 Measurement Type 4b. Comment:

l This generic editorial deviation is unnecessary. Revise the Frequency consistent with the STS and CTS. Also withdraw the two apparent generic editorial deviations from the Bases for STS SR 3.4.16.2. In particular, the replacement of" inaccurate" i

with "less conservative" in the Bases is actually a technical change and is notjustified.

Comed Response to issue Comed will revise the Frequency consistent with the STS, and will withdraw the changes to the Bases for STS SR 3.4.16.2.

This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence w ith the Comed Responses to the iTS Section 3.4 RAl. (See RAls 3.1-01,3.1.6-04,3.6.3-09,3.4.14-09, and 3.4.18-03.)

I I

I i

O 1

49

I Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RA'l Number NR'C issued Date RAI Status r

3.4.16-06 3/9/98 Open - NRC Action Required NRC Description of Issue CTS 3.4.8 Table 4.4-4 Measurement Types 2 and 4b ITS 3.4.16.2 Note if the unit is in Mode 1,2 or 3, CTS 3.4.8 Table 4.4-4 Measurement Type 4b requires an isotopic analysis of a reactor coolant sample for lodine including 1-131,1-133, and I-135 on a Frequency of"between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months aller a Thermal Power change of 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period." The CTS markup indicates that ITS 3.4.16.2, verification of reactor coolant Dose Equivalent 1-131 specific activity, corresponds to this isotopic analysis. ITS SR 3.4.16.2 contains a note, consistent with the STS, that only requires this test at the CTS Frequency if the unit is in Mode 1, which is less restrictive than the CTS applicability requirement. The submittal contains no technicaljustification for this change in applicability.

Notice that the CTS markup also indicates that ITS SR 3.4.16.2 corresponds to CTS Table 4.4-4 Measurement Type 2, isotopic analysis for Dose Equivalent 1-131 concentration, which is only required to be performed in Mode 1. Comment:

Add an L-type DOC with tecimicaljustification for this less restrictive change to the CTS. Explain why ITS SR 3.4.16.2 satisfies the requirements of both Measurement Types 2 and 4b, as implied by the CTS markup.

Comed Response to issue Comed will revise the submittal to include DOC 3.4-LA30 stating, " CTS Table 4.4-4 Item 2 requires DOSE EQUIVALENT (DE) 1-131 concentration to be determined to be less than or equal to 0.35 pCilgm for Unit I (1.0 pCi/gm for Unit 2) once per 14 days w hile in Mode 1. Item 4 requires an isotopic analysis for lodine including 1-131,1-133, and I-135 once between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following a TilERMAL POWER change exceeding 15% of the RATED TilERMAL POWER within a I hour period while in Modes I,2, and 3 with no limit imposed. NUREG SR 3.4.16.2 requires DE l-131 to be determined once per 14 days and once between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months aller a T11ERMAL POWER change of greater than or equal to 15% RTP within a i hour period while in Mode 1. NUREG SR 3.4.16.2 places a limit ofless than or equal to 1.0 Cilgm for DE l-131. The NUREG, and therefore ITS, do not require the isotopic Analysis for 1-131,1-133, or I-135 to be performed. The purpose for the analysis ofI-131,1-133, and I-135 with a power change of greater than or equal to 15% is to trend possible fuel cladding leakage or failure following fast power changes when fuel failure is more apt to occur.

Relocating this requirement to the TRM still maintains its SR function for trending any fuel leakage. However, this requirement is not necessary to ensure DE l-131 is maintained. As such, the relocated requirement is not required to be l

maintained in the ITS, per 10 CFR 50.36(c)(2)(ii), and is not required to provide adequate protection to the public health and safety. Any changes to this requirement will be made in accordance with 10 CFR 50.59." In addition, the Frequency of "Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of greater than or equal to 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period" will be deleted from NUREG SR 3.4.6.2 Surveillance Requirement and the Surveillance Requirements Section of the Bases for ITS LCO 3.4.16. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

NRC RAI Number NRC issued Date RAI Status 3.4.16-07 3/9/98 Open-NRC Action Required I

NRC Description of Issue Bases JFL) PI Bases discussion Applicable Safety Analyses, STS markup page B 3.4-93 in the first paragraph,last sentence, the STS text pertaining to the safety analysis assumption for secondary specific reactivity was not adopted. The ITS Bases only retains a redernece to ITS LCO 3.7.17. This is a technical change (and not an editorial change) w hich requires an explanation or adoption of the STS text. Comment: Revise the Bases to adopt the STS text.

Comed Response to issue Comed will revise the Bases to adopt the STS text. This change will be provided in our comprehensive ITS Section 3.4 3

closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

50

Rcsponse to NRC RAI Dated 03/09/98 isApr-98

~

NRC RAI Number NRC issued Date

~

RAI Status

(

3.4.16-08 3/9/98 Open - NRC Action Required NRC Description of issue liases JFD P3 Bases discussion Applicable Safety Analyses, STS markup page B 3.4-95 The eighth paragraph is not adopted based on editorial enhancement. The omitted text, however,is applicable to a standard plant, and should be adopted. In addition, this is a generic technical deviation from the STS. Comment: Revise the Bases to adopt the omitted STS text.

Comed Response to issue Comed will revise the Bases to adopt the omitted STS text. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAL NRC RAI Number NRC Issued Date RAI Status 3.4.17-01 3/9/98 Open - NRC Action Required NRC Description ofIssue

{

Bases JFD P3 Bases discussion of Background, STS markup page B 3.4-99 The Bases Background text identified as items a, b and e in the second paragraph is not adopted. This omission is characterized by Bases JFD P3 as a plant specific editorial enhancement. This editorial deviation from the STS Bases is generic and could apply to all Westinghouse plants with RCS loop isolation valves. Comment: Revise the Bases to adopt the omitted STS text. See similar comment 3.4.18-04.

O Comed Response to issue The paragraphs omitted from the Background Section of the Bases for ITS LCO 3.4.17 pertaining to ITS LCO 3.4.18 for opening the RCS loop isolation valves will be retained with appropriate changes made to reflect corresponding changes made to ITS LCO 3.4.18. This change will be provided in our comprehensive ITS Section 3.4 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAL (See RAI 3.4.18-04.)

NRC RAI Number NRC issued Date RAI Status 3.4.17-02 3/9/98 Open - NRC Action Required NRC Description of issue Bases JFD P44 Bases for ITS LCO 3.4.17, STS Markup page B 3.4-100 Bases insert B 3.4100A JFD P44 states the paragraph was not adopted because the discussion relates to ITS 3.4.18. StalTthinks it is appropriate to state what happens in related LCOs to fully explain the context of the LCO requirements. Thus the omitted STS text should be adopted as applicable. Not doing so would be an unjustified generic deviation from the STS. Note that Bases Insert B 3.4-100A is acceptable and can be included with suitable editorial changes to accommodcte the STS text. Comment:

Revise the Bases to adopt the omitted STS text.

Comed Response to issue Comed will revise the ITS Bases to adopt the omitted STS text, but will also retain Bases insert B3.4-100A as a second paragraph in the LCO Section of the Bases for ITS LCO 3.4.17. This change will be provided in our comprehensise ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl.

i 51 t

Response to NRC RAI Dated 03/09/98 16-A pr-98 l

NitC llAl Number NitC issued Date ilAlStatus b>

3.4.17-03 3/9/98 Closed NitC Description of Issue Not used Comed flesponse to Issue No response required.

l C

52

- - _ - -., = =.

Response to NRC RAI Dated 03/09/98 17-Apr-98 NRdRAINidber

'NRC hssue~d Ihte

~

^

~

RAI Status 3.4.18-01 3/9/98 Open - NRC Action Required NRC Description of issue DOC A28 DOC Ll8 JFD P31 Bases JFD P36 Bases JFD PI ITS 3.4.18 CTS 3/4.4.1.5.2 ITS 3.4.18 and associated Bases differ significantly from the STS in that the ITS state requirements for conditions needed to unisolate an isolated loop - rather than conditions for maintaining a loop isolated, in addition, the ITS proposes to permit unisolating a loop with the boron concentration in the loop less than the remainder of the RCS, provided that it is greater than the required SDM boron concentration. Note: These changes are not plant specific requirements and are not part of the current licensing basis. This deviation is miscategorized as plant-specific under the NEl 96-06 guidelines of Section 2.7, Deviations from the Applicable STS. This is a generic deviation from the STS. DOCS A28 and L18 are prepared to implement the P31 deviation in the CTS. Stafican not review these CTS changes until a generic change to the STS consistent with the deviations addressed by JFD P31 is approved by the staff. Therefore, ITS 3.4.18 and all associated deviations from the STS Bases can not be reviewed at this time. Note: There are also editorial changes categorized as P1 and BPI when they are changes incorporating the technical change P31. Comment: Revise ITS 3.4.18 to be consistent w ith STS 3.4.18 and CTS 3/4.4.1.5.2.

Comed Response to issue As discussed with the NRC Reviewer during the April 2,1998 meeting in Rockville, this change is not a generic change since the only other Westinghouse plants equipped with loop stop valves are Zion and Millstone. Zion is not implementing ITS and Millstone will be pursing an ITS conversion within six months following their restart. Therefore, per conversations with the NRC Reviewer, since Byron and Braidwood are the only operating plants for which this specification applies, Comed will pursue this change as plant specific. NUREG LCO 3.4.18, "RCS isolated Loop Startup," con 0icted with the nomenclature of CTS 3.4.1.5.2 " Loop IsolMion Valves - Shutdown" by referring to conditions to maintain the loops isolated rather than identifying the requirements needed to unisolate the RCS loop. Along with Comed's response to the LCO 3.4.18 RAls. Comed believes that DOC 3.4-A28 adequately addresses plant specific changes associated with LCO JFD 3.4-P31.

In reference to DOC 3.4-L18, this change was approved in the Zion Safety Evaluation Report for implementation of the improved Technical Specifications as a less restrictive change from Current Licensing Basis (CLB) aller the isolated loop boron concentration was greater than or equal to the required cold shutdown boron concentration of the unisolated portion of the RCS. This change was approved by the Staff May 30,1975 for Zion amendment number 9 (DPR-39) for Unit I, and amendment number 6 (DpR-48) for Unit 2. The issuance of the above amendments also allowed the plant the flexibility to not meet the requirements for the cold leg stop valve temperature limitation ofless than or equal to 10 degrees F if the boron concentration was met. Comed believes that requiring the boron concentration in the loop to bc unisolated to be higher than the boron concentration required for the entire RCS is unnecessarily restrictive. Proposed ITS LCOs 3.1.1 and 3.9.1 provide adequate requirements to assure reactivity control in Modes 5 and 6, respectively. The justification supplied to the NRC for the previous amendments for Corned's Zion Station supports the less restrictive change for the unique Westinghouse design for four loop plants equipped with loof

top isolation valves. Comed continues to pursue this change on a plant specific basis.

.=

52

Response to NRC RAI Dated 03/09/98 16-Apr-98 NRC RAI Number NRC Issued Date RAI Status sv) 3.4.18-02 3/9'98 Open - NRC Action Required

(

NRC Description of Issue DOC L9 ITS LCO 3.4.18.b ITS 3.4.18 Required Action B.I CTS 3/4.4.1.5.2 Action CTS 3/4.4.1.5.2 Action prohibits opening either the hot leg or cold leg stop valves whenever the temperature requirement of CTS 3.4.1.5.2.b is not met. ITS 3.4.18 Required Action B.1 requires the immediate closure of only the :old leg isolation valve w henever the temperature requirement is not met, consistent with the STS. This change would be acceptable under the STS guidance; howes er, ITS 3.4.18 differs significantly from the STS, as described in comment 3.4.18-01. Provided that comment is resolved as requested, the CTS change addressed by DOC 1.9 w ill be accepted. Otherwise, the CTS requirements must be retained. Comment: Respond according to the resolution of comment 3.4.18-01.

Comed Response to issue With the conditions of CTS 3.4.1.5.2 not met, the action is to not open either the hot leg or the cold leg stop valves. ITS LCO 3.4.18a requires that only the boron concentration be met to open the hot leg loop stop valve, and that the boron concentration and the temperature be met to open the cold leg loop stop valve. The hot leg loop stop vahe has no opening interlock on temperature limits. only that the cold leg loop stop valve be closed. With the cold leg stop vahe closed, there can be no driving force (delta p) to allow mixing of the fluids in the isolated loop and the operating portion of the RCS.

Interlocks are provided on the cold leg stop vake to present opening the cold leg stop valve until the hot leg stop valve is open and the temperature requirement is satisfied. An administrative control is placed on the hot and cold leg stop valves to prevent opening the valves until the boron concentration requirement is satisfied. Comed believes ITS LCO 3.4.18 Required Action B.1 correctly addresses the safety analysis concern of a positive reactivity addition due to the addition of cold water from the isolated loop and is consistent with CTS. Comed continues to pursue this change.

\\w r\\

I V

54

Response to NRC RAI Dated 03/09/98 16-A pr-98 NRC RAI Number NR'C issued Date RA'l Status 3.4.18-03 3/9/98 Open - NRC Action Required NRC Description of issue JFD P47 ITS SR 3.4.18.1 and SR 3.4.18.2 Bases JFD Pi Bases F - SRs 3.4.18.1 and 2, STS Bases markup page B 3.4-105

a. ITS SR 3.4.18.1 and SR 3.4.18.2 have the word "once" inserted before the Frequency interval because JFD P47 states this provides "..a particular time frame..and.., is necessary to comply with the SR" and ITS SR 3.0.2. This change does not achieve the stated technical objective because the SR may haSe to be perfonned several times in order to actually be within the time interval " prior" to the opening of the cold leg isolation valve. The adding of"once" to an interval stated as occurring "after" any action, starts a clock which cannot be changed. The adding of"once" to an interval as occurring

" prior" to any action does not start a clock, until the action has actually occurred. This proposed change introduces an ambiguity not present in the STS which can cause the SR Frequency to be exceeded. Comment: Adopt the STS Frequencies for ITS SRs 3.4.18.1 and 3.4.18.2.

b. Deviations from the STS Bases related to JFD P47 are characterized as editorial under Bases JFD Pl. w hen in fact, they are technical changes. Thus a technicaljustification is required. Comment: Withdraw the Bases deviations and adopt the STS which is clear and accurate as written.

Comed Response to issue Comed will revise the Frequency consistent with the STS, and will withdraw the changes to the Bases for STS SRs 3.4.18.1 and 3.4.18.2. This change will be provided in our comprehensive ITS Section 3.4 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAls 3.1-01,3.1.6-04,3.6.3-09,3.4.14-09, and 3.4.16-05.)

l NRC RAI Number NRC Issued Date RAI Status 3,4.18-04 3/9/98 Open - NRC Action Required NRC Description of Issue Bases JFD P3 Bases Background discussion ofITS 3.4.18, STS markup page B 3.4-103 The Bases Background text identified as paragraphs a. b and c has not been adopted. This omission is stated as a plant specific editorial enhancement; whereas, the omitted text is applicable to all Westinghouse plants with RCS loop isolation valves. The submittal contains no technicaljustification for this change. Comment: Adopt the omitted STS text.

See similar comment 3.4.17-01.

Comed Response to issue The paragraphs omitted from the Background Section of the Bases for ITS LCO 3.4.18 for opening the RCS loop isolation valves will be retained with appropriate changes made to reflect corresponding changes made to ITS LCO 3.4.18. This change will be provided in our comprehensive ITS Section 3.4 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.4 RAl. (See RAI 3.4.17-01.)

/

l 55

Response to NRC RAI Datcd 03/09/98 16-A p r-98 NRC RAI Number NRC issued Date RAI Status O

3.4-01 3/9/98 Open - NRC Action Required NRC Description of issue See table below Proposed changes based on STS generic change proposals that are still pending or that have been rejected, as indicated in the table, should be withdraw n. For each applicable line item, either adopt the STS or maintain the CTS requirements. See separate correspondence regarding line items for beyond scope changes (reasons 4 and 5) that should have been addressed separately by the licensing project manager and NRR technical staff as appropriate. Line items considered closed are indicated by shading.

' Reasons for exempting c' ange from review:

1. Cover letter 12-13-96, Attachment #3 Existing and Future Licensing Amendrnents to be incorporated into ITS.

2. Cos er letter 12-13-96, Attachment #4 Pending and Proposed IST S Change Travelers

3. Comed letter 2-24-97, Attachment #1, Generic Changes versus CTS DOCS

4. Cover letter 12-13-96, Attachment #5 Beyond Scope Change (changes that are different than both CTS and ITS).

5. Cover letter 12-13-96, Attachment #6 Beyond Scope Bracketed Changes 6 Comed letter 2-24-97, Attachment #2, plant Specific Change Justifications Which are Now in the Generic STS Change Process

7. Other Reason as identified in comments to this table and'or with the prior approval of the NRC Technical Monitor as referenced.

By ronliraidwood Units I and 2 "Beyond Contractor Review Scope (BCRS)" Table Section 3.4, Reactor Coolant System

\\'"")

TableLine No.

ITS Reference DOC JFD

Reasons for Exemption of Review Comment (if required) l 1234567 15.5.9 5.6.9 - - X - - - - - - Comed Amendment praposal dated 8 19 Note, ITS Section 5.0, DOC A24 adds the SG 3.0 volt criteria to CTS 4.4.5 for the SG Tube Surveillance Program.

2 3.4.16 - - - X - - - - - TSTF-3 R 1, Not incorporated 3 3.4.2 L36 Cl BC1 - X X ---- TSTF-26 approved 9/16/96 4 3.4.2 M9 C2 BC2 - X X ---- TSTF-27 Rl; superceded by Rev. 2 w hich is pending 5 3.4.16 - C3 BC3 - X - - - - - 1 S1 F-28 appros ed 9/16.'96 6 51ases for 3.4.13 - BC4 - X -- - - - TSTF-54, Comed states replaces " identified" with " unidentified" Should adopt Revision I w hich l

was appros ed 4/10'97 7 3.4.15 - -- X - - - - 1 STF-60, Not incorporated - Comed states contradicts Condition D for entering LCO 3.0.3.

pros ed 9'17/96; Comed should adopt.

[3.4.13) - Cl 1 - X - - - - - TSTT-61, appros ed 9'17/96: Comed should adopt.

93.4.5 l

56

Response to NRC RAI Dated 03/09/98 16-A pr-98 3.4.9 L3 O')

Ll

(v L23 L26 C10 P37

[P36] IlC10 - X X - - - X TSTF-87 R1, Comed specifies RA is " Initiate action to place" rather than " Place.." on "Immediate frequency" [Per C. liarbuck P36 is llCRS from typo in JFD CIO ] revision 2 approved 10/3'97; Comed should adopt Revision 2 10 3.4.9 A13 C5 llc 5 - X X - - - - TSTF-93, 1 i 3.4.9 - - - X - -- - - - TSTF-94, Not incorporated - Comed provides brackets for w ords that w ere incorporated into CTS.

Comed should adopt Rev. I which was approved 9/30'97.

12 3.4.1 LA18 C6 IlC6 - X X ---- TSTF-105 was rejected.

13 3.4.19 - P30 llP35 - X ---- X TSTF-108, Not incorporated -Comed states LCO 3.4.19 is for NTOL plants. Per C liarbuck this is not ilCRS.

14 3.4.11 L8 Cl2 IICl3 - X X ---- TSTF-113 RI. still pending 15 3.4.7 - IlC11

!!P3 - X - - - - - TSTF-l l4, approved 12/31/96 16 3.4.13 I

3.4.15 L21 L22 L24 C8 P23 IICH IIP 23 - X X - - - - TSTF-l 16, superceded by Rev i w hich is pending j

17 Ilases 3.4.11 - IlCl4 - X - - -- - TSTF-151 (WOG-61), Owners Groups asked to modify as suggested by TSil - waiting for response i83.4.5 g(-)

[3.4.6]

[3.4.7]

[3.4.8] A31 Cl4 IlCIS - X X ---- TSTF-153 (WOG-63) approved 4/l1/97 19 3.4.1 A22 C7 llc 7 - X X - --- WOG-21 20 3.4

[3.4.12] Ll6 C9 Pl1 P21 IlC9 IIPl l IlPl9 !!P21

[Pl7] [P19]- X X --- X WOG-51 R1, C9 states generic change is modined by plant specific changes PI land P2l [P19 is tied to Pil] and [Pl7 is tied to C9]

21 3.4

[3.4.11] L27 Cl3 IICIS - X X ---- WOG-60 22 3.4

[3.4.9] - IlC 17 - X - - - - - WOG-68 23 3.4

[3.4.2]

[3.4.16] - CI S - X - - - - - WOG-81 24 liases for Section 3.4

[ All speci-6 cations) - IIC16 - X - - - - Editorial-1 25 SR 3.4.1.4 Note M I 5 P3 - - - X - - -

26 3.4.3 L28 P44 - - - X - - -

27 3.4.18 L18 (A28] P31

[IlP36] - - X - X ltems in bracket are added because both are tied to the P31 change.

28 SR 3.4.18.2 Ll4 P4 - - - X - - -

/

29 SRs 3.4.5.2 b

3.4.6.2 3.4.7.2 L5 [113]

[Pl]--- - X - X ltems in bracket are added because both are tied to the L5 change.

57

Response to NRC RAI Dated 03/09/98 16-A pr-98 30 3.4

[3.4.12] - P3 8 - - - - - X - WOG-087 31 3.4

[3.4.1] - P3 - - - - - X. WOG-099 32 3.4 13.4.12] - P21 - - - - - X - WOG-100 33 3.4

[3.4.11] - Pl4 - - - - - X - WOG-102 34 3.4

[3.4.16]- Pi P45 - - - - - X - Editorial-12 Comed Response to issue See table for Comed Response to RAI 3.4-01.

l l

I i

l i

i

(

I 58

)

1

n 3.4 01 See table below

/\\

Proposed changes based on STS genenc change proposals that are still pending or that have been rejected, as indicated in the table, should be withdrawn. For each apphcable hne item, either adopt the STS or mairtain the CTS requirements. See separate correspondence regarding kne items for beyond scope changes (reasons 4 and 5) that should have been addressed separately by the licensing project manager and NRR technical staff as appropriate. Line items considered closed are indicated by shading.

Reasons for exempting change from review:

1.

Cover letter 12 13-96. Attachment #3 Existing and Future Licensing Amendments to be incorporated into ITS.

2.

Cover letter 12-13-96, Attachment #4 Pending and Proposed ISTS Change Travelers 3.

Comed letter 2 24-97, Attachment #1, Generic Changes versus CTS DOCS 4.

Cover letter 12-13-96, Attachment #5 Beyond Scope Change (changes that are different than both CTS and ITS).

5.

Cover letter 12 13 96, Attachment #6 Beyond Scope Brocketed Changes 6 Comed letter 2 24-97, Attachment #2, Plant Specific Change Justifications Which are Now in the Generic STS Change Process 7.

Other Reason as identified in comments to this table and/or with the prior approval of the NRC Technical Monitor as referenced.

Byron /Braidwood Units 1 and 2

Beyond Contractor Review Scope (BCRSl" Table Section 3.4, Reactor Coolant System T

Reasons for a

ITS Exemption of Review b

Reference D

J Comed Response to 1

0 F

Comment (if required)

RAl 3.4-01 e

C D

L "i

1 2

3 4

5 6

7

)

O N

o 1

5.5.9 X

Comed Amendment proposal Comed well submit an ITS 5.6.9 dated 819 Note, ITS Revision to incorporate CTS Section 5.0, DOC A24 adds the SG License Amendment Requests 3.0 volt enteria to CTS 4.4.5 for the which have been issued af ter SG Tube Surveillance Program.

the ITS submittal date of 12/13/96. The following CTS 3.4 LCOs are affected:

3.4.1.2 and 3.4.1.4.1, (Amend. 87), 3.4.5 ( Amends.

82 & 92), 3.4.8 ( Amend. 92),

3.4.9.1, 3.4.9.2, 3.4.9.3.

and 3.4.10 ( Amend. 89).

2 3.4.16 X

TSTF-3 R1, Not incorporated TSTF-3 R1 rejected. Comed did not incorporate. Line item should be closed.

3 3.4.2 L36 C1 X

X TSTF-26 approved 9/16/96 TSTF-26 approved. Comed BC1 incorporated. Line item closed.

4 3.4.2 M9 C2 X

X TSTF-27 R1; superceded by Rev. 2 TSTF-27 R3 pending NRC BC2 which is pending resolution. TSTF 27 R1/R2 superceded. Comed continues to pursue this channe.

\\wJ

)

l

)

T

' Reasons for

(/

a ITS Exemption of Review b

Reference D

J Comed Response to I

O F

Comment (if required)

RAI 3.4-01 e

C D

L i

1 2

3 4

5 6

7 n

e N

o 5

3.4.16 C3 X

TSTF 28 approved 9/16/96 TSTF-28 approved. Comed BC3 incorporated. Line item closed.

6 Bases for BC4 X

TSTF-54, Comed states replaces TSTF-54 R1 approved.

3.4.13

" identified" with " unidentified".

Comed will incorporate R1, Should adopt Revision 1 which was Line item should be closed.

approved 4/10/97 7

3.4.15 X

TSTF-60, Not incorporated - Comed TSTF-60 approved. Comed states contradicts Condition D for did not incorporate, and entering LCO 3.0.3 Approved beheves that moving "LCO 9/17/96; Comed should adopt, 3.0.4 is not applicable" from a Required Actions Note (RA A and RA B) to an ACTIONS Note is unjustifiable, in the event the unit is in MODE 5 A

with no Leakage Detection t

~

monitors operable, TSTF-60 would allow the unit to apply the Note to Condition 0 with a RA to " Enter LCO 3.0.3" Immediately upon entering MODE 4 the unit would be in LCO 3.0.3. This is not an acceptable allowance.

Without the Note moved to an ACTIONS Note, with the unit in MODE 5 with no Leakage Detection monitors operable, Condition D would prevent entering MODE 4 until at least one Leakage Detection monitor is operable.

Furthermore, a review of ITS revealed that such a Note is not apphed as an ACTIONS Note with any other LCO that has a Required Action of "E nter LCO 3.0.3.*

8 3.4 C11 X

TSTF-61, approved 9/17/96; Comed TSTF 61 approved. Comed 13.4.1 3]

should adopt.

incorporated in ongenal submittal. Line item should be closed OU i

D (v)

T

' Reasons for a

ITS Exemption of Review b

Reference D

J Comed Response to 1

O F

Comment (if required)

RAI 3,4-01 e

C D

L i

1 2

3 4

5 6

7 n

e N

o 9

3.4.5 L3 C10 X

X X

TSTF-87 R1, Comed specifies RA is TSTF-87 R2 approved.

3.4.9 L12 P37

" Initiate action to place" rather than Comed willincorporate R2.

L23 IP36]

" Place.." on "Immediate frequency" Line item should be closed.

L26 BC10 (Per C. Harbuck P36 is BCRS from typo in JFD C101 revision 2 Comed continues to pursue approved 10/3/97; Comed should the change associated with adopt Revision 2 LCO JFD 3.4-P37. It is customary throughout ITS to use the phrase

Initiate action to.

or " Suspend. " with Completion Times designated as "Immediately." In addition,

Initiate action to place the Rod Control System in a condition incapable of rod withdrawal

is consistent with ITS LCO 3.3.1 Required Actions 1.1 and S 1 which state, " Initiate action to fully insert all rods" with a Completion Time of "Immediately."

1 3.4.9 A13 C5 X

X TSTF-93, TSTF-93 R3 approved.

O BCS Comed willincorporate R3.

Line item should be closed.

1 3.4.9 X

TSTF-94, Not incorporated - Comed TSTF-94 R1 approved. This 1

provides brackets for words that TSTF merely added brackets were incorporated into CTS. Comed around existing words in the should adopt Rev.1 which was LCO. Since Comed retained approved 9/30/97, all of the LCO Words, there is no justifiable reason to add brackets and then remove the brackets. The technical portion of TSTF-94 R1 was already incorporated in the submittal. Line item should be closed.

1 3.4.1 LA18 C6 X

X TSTF-105 was rejected.

TSTF 105 R1 pending NRC 2

BC6 resolution. TSTF-105 RO rejected. Comed will withdraw TSTF-105 RO. Line item should be closed.

1 3.4.19 P30 X

X TSTF-108, Not incorporated -Comed TSTF-108 R1 pending. Not 3

BP35 states LCO 3.4.19 is for NTOL applicable to ITS Section 3.4.

plants. Per C Harbuck this is not Line item closed.

BCRS (U

1 J

'1 l

1

.b T

' Reasons for a

ITS Exemption of Review b

Reference D

J Comed Response to l

l O

F Comment hf required)

RAI 3.4 01 e

C D

L i

1 2

3 4

5 6

7 n

e N

o 1

3.4.11 LB C12 X

X TSTF 113 R1, still pending TSTF-113 R4 pending NRC 4

BC13 resolution. TSTF-113 R1/R2/R3 rejected. Comed will withdraw TSTF-113.

Line item should be closed.

1 3.4.7 BC11 X

TSTF-114, approved 12/31/96 TSTF-114 approved. Comed 5

BP3 incorporated. Line item closed.

1 3.4.13 L21 CB X

X TSTF 116, superceded by TSTF-116 R2 pending NRC 6

3.4.15 L22 P23 Rev 1 which is pending resolution. TSTF 116 L24 BC8 RO/R1 superceded by revision.

BP23 Comed continues to pursue this change.

1 Bases BC14 X

TSTF-151 (WOG-61), Owners TSTF-151 R1 pending NRC 7

3.4.11 Groups asked to modify as resolution. TSTF 151 RO suggested by TSB - waiting for superceded by revision.

response Comed continues to pursue this change.

1 3.4.5 A31 C14 X

X TSTF-153 (WOG-63) approved TSTF-153 approved. Comed 8

13.4.61 BC18 4/11/97 incorporated. Line item 13.4.7) closed.

13.4.81 1

3.4.1 A22 C7 X

X WOG-21 WOG-21 withdrawn in RAI 9

BC7 3.4-01. Line stem should be closed.

2 3.4 L16 C9 X

X X

WOG-51 R1, WOG-51 R1 withdrawn in 0

13.4.121 P11 C9 states generic change is modified RAI 3.4.101. Line item P21 by plant specific changes P11and should be closed.

BC9 P21 [P19 is tied to P111 and IP17 is BP11 tied to C9l BP19 BP21 (P171 iP19) 2 3.4 L27 C13 X

X WOG-60 WOG-60 R1 approved by 1

13.4.111 BC15 TSTF. Comed continues to pursue this change.

2 3.4 BC17 X

WOG-68 WOG-6B was approved as 2

(3.4.9)

TSTF-162. Comed incorporated. Line item shnutd be closed ks

1

' Reasons for a

ITS Exemption of Review b

Reference D

J Comed Response to i

0 F

Comment (if required)

RAI 3.4-01 e

C D

L 1

2 3

4 6

6 7

n e

N o

_=

2 3.4 CIS X

WOG-81 WOG-81 withdrawn in RAls 3

13.4.2) 3.1.5-02, 3.4-01, 3.5-01, 13.4.1 6]

3.7.10-03, 3.7.11 02, 3.7.13-06, 3.9.4-06, and 3.9.7-05. Line item should be closed.

2 Bases for BC16 X

Editorial-1 See Comed response to RAI 4

Section 3.9-02.

3.4 (All speci-fications) 2 SR MIS P3 X

See Comed response to RAI 5

3.4.1.4 BYS 5.0.

Note p

2 3.4.3 L28 P44 X

See Comed response to RAI 6

BYS 6.0.

2 3.4.18 L18 P31 X

X ltems in bracket are added because Beyond Scope Change #7.

7 (A28]

[BP36 both are tied to the P31 change.

Comed continues to pursue I

this change.

2 SR L14 P4 X

See Comed responn to RAI 8

3.4.18.2 BYS 8.0.

2 SRs L5 1B3]

X X

ltems in bracket are added because Beyond Scope Bracketed 9

3.4.5.2 (P1) both are tied to the L5 change.

Change #2.

Comed 3.4.6.2 continues to pursue this 3.4.7.2 change.

3 3.4 P3B X

WOG-087 WOG-87 R2 under Owner's 0

13.4.1 2]

Group consideration. ComEi!

did not incorporate.

(Correction Note: WOG-87 proposes changes to NUREG LCO 3.4.11, not 3 4.12.

l WOG-87 should not cross-reference ITS LCO 3.4.12 or LCO JFD P-38.)

3 3.4 P3 X

WOG-099 WOG-99 approved by TS1F.

1 13.4.11 Comed continues to pursue this change.

3 3.4 P21 X

WOG-100 WOG-100 R1 approved by 2

13.4.1 21 TSTF. Comed continues to pursue this change.

3 3.4 P14 X

WOG-102 WOG-102 approved as TSTF-3 13.4.11]

247. Comed continues to nursue this chance.

I

)

4 I

l f

D i

Reasons for V

a ITS b

Reference D

J mEo Response to I

O F

Comment hf required)

RAI 3.4-01 C

D L

i 1

2 3

4 5

6 7

n e

N o

m 3

3.4 P1 X

Editorial-12 Comed incorporated with 4

13.4.1 61 P46 minor editorial changes in Conditions A end B.

w_a I

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i l

l O

J

ML20217E966

Text

Subject:

References:

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