ML20236T034

Submits Response to NRC RAI Re Improved TS Section 5.0 & Three Addl Questions in Section 3.8

ML20236T034
Person / Time
Site:	Byron, Braidwood
Issue date:	07/08/1998
From:	Tulon T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9807270382
Download: ML20236T034 (14)

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Commonwealth I:dison O>mgww e

firaidwood Generaung Station

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Route el,llox M4 liraceville. IL 60107-9619 Tel HI 5-45&2801 Comed July 8,1998 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C. 20555 - 0001

Subject:

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

Section 5.0 and Section 3.8 Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Numbers: 50-454 and 50-455 l

Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Numbers: 50-456 and 50-457

References:

G. Stanley and K. Graesser (Comed) letter to USNRC, " Conversion to the Improved Standard Technical Specifications," dated December 13,1996 The purpose of this letter is to transmit Comed's Response to the NRC's RAI for ITS Section 5.0 and three additional questions in Section 3.8. The responses to the RAI questions are contained in the Attachment, Response to NRC RAI For ITS Section 5.0.

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The RAI contains questions and comments stemming from the NRC's partial review of a

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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 were requested in order to adopt the improved Technical Specifications of NUREG-1431, Revision 1.

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Document Control Desk Page 2 July 8,1998

~ 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.

Please address any comments or questions regarding this matter to our Nuclear Licensing Department.

Sincerely, N

4 Timothy J. Tulon Site Vice President Braidwood Nuclear Generating Station

Attachment:

Response to NRC RAI For ITS Section 5.0 cc:

Regional Administrator-RIII Senior Resident inspector - Braidwood Senior Resident Inspector - Byron Office of Nuclear Facility Safety -IDNS nrc/98040tjt. doc l

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Beckner, William - NRR

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Attachment Byron / Braidwood Response to NRC RAI for ITS Section 5.0

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NRC RAI Number NRC Issued Date RAI Status

!O 3.8.1-24

,6/12/98 Open-Comed Action Required V

NRC Description of issue 3.8.1-24 ITS SR 3.8.18 as now proposed is allowed to be done in all modes and must be a manual transfer from normal to alternate / reserve. Is this a bumpered (make before break) transfer and can it be done in all modes?

Comed Response to issue Verification of the manual transfer of AC sources from the normal circuit to the reserve circuit is a make before break transfer. With the normal circuit still supplying the 4 kV ESF bus (e.g., circuit breaker 1412 closed), the emergency diesel generator is synchronized to the bus (circuit breaker 1413 closed). The reserve feed breaker on the same unit is closed (circuit breaker 1414) and the normal feed breaker is opened (circuit breaker 1412). Then the reserve feed breaker from the opposite unit is closed (circuit breaker 2414) and the diesel generator supply breaker is opened (circuit breaker 1413). Per the Byron and Braidwood Operating procedures, the transfer from normal to reserve power is applicable in MODES l-6.

i (Correction Note: ITS SR 3.8.18 should be ITS SR 3.8.1.8.)

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l NRC RAI Number NRC issued Date RAI Status 3.8.3-02 6/12/98 Open-Comed Action Required NRC Description of issue 3.8.3-2 P14 Thejustification that the diesels in use at Byron /Braidwood do not use much lube oil while in operation is not sufficient as other plants use similar diesels and have talopted the STS.

Comed Response to Issue

, l 7'T Experience has shown that the emergency diesel generators (EDGs) at Byron and Braidwood consume approximately $5

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gallons oflubricating oil per year, or 82.5 gallons per fuel cycle (18 months). The tube oil reservoir contains approximately 1300 gallons of oil and is monitored once per shift, every 30 minutes during a diesel run, and before and after any planned l

starts. Spec F/L-2742 states that the guaranteed lube oil consumption is less than 0.00014 gal /kW-hr. (Spec F/L 2742 is the purchase spec that outlines the various parameters that the vendor certified the equipment to.) This corresponds to a consumption of 0.77 gph. There are 486 gallons oflube oil from the " fill" line until the EDG is inoperable. There are 354 gallons of tube oil from the low level alarm until the EDG is inoperable. This represents approximately 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of operating time from the low level alarm until the EDG is inoperable. Based on an average of 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> of run-time per i

cycle, the EDGs can operate over 2 cycles without adding oil concurrent with a loss of offsite' power and still meet the 7 day requirement [354 gal X 1 hr/0,77 gal = 459 hr; and (459 hr-168 hr) X 1 cycle /l 10 hr - 2.65 cycles). Using the loading schedu' ' Calculation DGDO9301 over the 7 day worst case LOCA scenerio, the consumption would be much lower than above ce the oil is drained and refilled to the " fill" line every outage, worst case would be operating for a cycle with the low les alami. inoperable and the Operators and System Engineer not performing their oil checks for the entire cycle.

. Based on the very low amount of oil consumption, and on the fact that a modification to Byron and Braidwood Stations would be required in order to adopt the NUREG Condition, Comed continues to pursue not adopting the proposed generic requirements of NUREG-1431 for LCO 3.8.3.

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NRC RAI Number NRC Issued Date RAI Status

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3.8.7-02 6/12/98 Open - Comed Action Required NRC Description ofIssue 3.8.7-2 The ITS Bases reference the FSAR when describing the operation of the inverters. What is left unexplained is whether an inverter that is capable of supplying power from only its AC or DC source would still be considered Operable. Is the auctioneering/ swapping necessary to call the inverter Operable?

Comed Response to issue The 480 VAC bus is the normal source of power to the inverter with the 125 VDC bus taking over automatically if the AC 1 input fails or drops below a certain value. The three phase,480V input is first transformed then rectified to a DC value slightly greater than the 125 VDC bus. A blocking diode in the feed from the 125 VDC bus will normally be reversed biased thus blocking the 125 VDC bus input. If the AC power supply fails or goes below a certain value the diode will conduct (become unblocked) and the 125 VDC bus will supply the inverter automatically. If the diode fails in such a manner that the inverter is unable to be energized from the DC bus, the inverter would be declared inoperable.

The third paragraph in the LCO Section of the Bases for ITS LCO 3.8.7 states, " OPERABLE inverters require the associated instrument bus to be powered by the inverter with output voltage within tolerances, and power input to the inverter from the associated 125 VDC battery. The power supply may be from an AC source via rectifier as long as the battery is connected as the uninterruptible power supply." With only the 125 VDC bus powering the inverter (and with the battery connected to the DC bus), the inverter would be considered operable. However, with only the 480 VAC bus powering the inverter, the inverter would be considered inoperable.

NRC RAI Number NRC Issued Date RAI Status 5.0-01 6/12/98 Open - NRC Action Required f'i NRC Description of issue b

5.0-01 CTS 6.2.2.b, Facility Staff, page 6-2 DOC A28 JFD C2 CTS 6.2.2.b is deleted. To paraphrasu C2, "..The requirements for control room manning in the CTS are consistent with and duplicative of the manning requirements delineated in 10 CFR 50.54 (m)(2)(iii)....this change is consistent with NUREG-1431 as modified by WOG-56 (BWOG-13) which was withdrawn." Comment: DOC A28 and JFD C2 should be revised because WOG-56 was withdrawn and therefore, is not applicable as a reference.

Comed Response to Issue CTS DOC 5.0-A28 will be revised to delete the reference to WOG-56. In addition, LCO JFD 5.0-C2 will be changed to a 'P' JFD and will be revis'ed to delete the reference to WOG-56. The change ~!< consistent witn TSTF-258 which is the traveler based on recommendations in the April 9,1997 letter from C. Grimes (NRC) to J. Davis (NEI). This change will be provided in our comprehensive ITS Section 5.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RA1 Comed continues to pursue this change.

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NRC RAI Number NRC issued Date RAI Status M

5.2-01.

6/12/98 Open - NRC Action Required NRC Description of Issue

'5.2-01 ITS 5.2.2, Facility Staff, page 5.0.3 CTS 6.2.2.c and Footnote *, page 6-2 DOC A2 (Not Used)

The CTS markup for this material contains changes and references DOC A2 for the discussion. However, DOC A2 is listed as not used. Comment:. Revise the submittal to provide the DOC for these proposed changes.

Comed Response to issue Comed will revise the CTS Markup by replacing DOC 5.0-A2 with DOC 5.0-LA28. DOC LA28 includes a discussion that includes CTS 6.2.2 for replacing plant specific management position titles with generic titles. As stated in DJC LA28, this approach is consistent with Generic Letter 88-06 which recommended, as a line item improvement, the relocation of corporate and unit organization charts to licensee controlled documents. This change will be provided in our comprehensive ITS Section 5.0 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAI. Comed continues to pursue this change.

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NRC RAI Number NRC issued Date RAI Status 5.4-01 6/12/98 Open-NRC Action Required NRC Description of Issue 5.4-01 ITS 5.4.1.d. Procedures, page 5.0-5 CTS 6.8.1, Procedures, pages 6-16

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STS 5.4.1.e, Procedures, page 5.0-6 V

STS 5.4.1.e requires that written procedures shall be established, implemented, and maintained that cover all programs specified in Specification 5.5. This requirement has been adopted in corresponding ITS 5.4.1.d. However, the markup of corresponding CTS 6.8.1 does not show this requirement and nojustification is prcvided. Comment: Revise the CTS markup to show the addition of this material to the ITS and providejustification.

. Comed Response to issue An 'A' DOC has been written and states, " CTS 6.8.1 and 6.8.4 reqeire that written procedures and programs, respec tively, shall be established, implemented, and maintained. Consistent with STS 5.4.1.e, written procedures shall be established, implemented, and maintained covering all programs specified in Specification 5.5. Since this is standard practice and does

. not add or delete any requirements, this change is considered to be an administrative change, and is consistent with NUREG-1431." This change will be provided in our comprehensive ITS Section 5.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAI.

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NRC RAI Number NRC Issued Date RAI Status 5.5-01 6/12/98 Open-NRC Action Required NRC Description ofissue 5.5-01 ITS 5.5.1, Offsite Dose Calculation Manual CTS 6.8.4.e.5, Procedures and Programs, page 6-19 DOC A37 JFD C8 CTS 6.8.4.e.5 states, Determination of cumulative [ strikeout on] and projected [strikout 0f1] dose contributions from radioactive efiluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM. [ strikeout on] at least every 31 days. [strikout off] [ redline on) Determination of projected dose

. contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days, [ redline of1]"

DOC A37 states, that this change is "... consistent with NUREG-1431, as modified by WOG-72.. " This change editorially clarifies projected dose distributions to be performed every 31 days and cumulative dose distributions for the quarter and current calendar year to be performed in accordance with the ODCM. "This change is consistent with current interpretation and is considered administrative." C8 states, this change is consent with NUREG-1431 as modified by WOG-72, which is pending. Comment; The change to CTS 6.8.4.e.5 is not reflected in ITS 5.5.1, Offsite Dose Calculation Manual," therefore, the staff concludes that this change will not be included in the ITS unless WOG-72 becomes a TSTF change and is approved by the NRC.

- Comed Response to issue -

Comed will adopt the STS wording for ITS 5.5.4.e and will delete CTS DOC 5.0-A37, LCO JFD 5.0-C8, and associated markups. This change will be provided in our comprehensive ITS Section 5.0 closeout submittal revision upon NRC's

- concurrence with the Comed Responses to the ITS Section 5.0 RAI.

l NRC RAI Number NRC Issued Date RAI Status 5.5-02 6/12/98 Open-NRC Action Required NRC Description ofIssue 5.5-02 ITS 5.5.9.d, SG Tube Surveillance Program, page 5.0-12 CTS 4 A.S.3, Reactor Cculant System, page 3/4 4-15 The introductory serace for CTS 4.4.5.3 states that the "... required inservice inspections of steam generator tubes shall be j

performed at the following frequencies." Corresponding ITS 5.5.9.d contains an additional parenthetical phrase

" ~..(dependant upon inspection rest.lts classification)...". Nojustification has been provided for this proposed change.

Comment: Revise the submittal with justification for the proposed change or conform to the CTS.

Comed Response to issue

' Comed will revise the CTS Markup to add the parenthetical phrase,"(dependent upon inspection results classification)." In

~ ddition, an 'A' DOC has been written and states, " CTS 4.4.5.3 has been revised to state, "The above required inservice a

inspections of steam' generator tubes (dependent upon inspection results classification) shall be performed at the following

. frequencies." Since testing frequencies and sample selections are currently changed based on inspection results and criteria, the addition of the parenthetical phrase is considered to be an administrative change providing clarification and does not alter

- the intent of CTS." This change will be provided in our comprehensive ITS Section 5.0 closeom submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAl.

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NRC RAI Number NRC lssued Date RAI Status

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5.5,03 6/12/98 Open - NRC Action Required l

NRC Description ofIssue 5.5-03 ITS 5.5.9.b Note, SG Tube Sample Section Inspection, page 5.0-12

CTS 4.4.5.2 Footnote *, Steam Generators, page 4/4 4-13 The note for CTS 4.4.5.2 refers to tube repair per Specification 4.4.5.4.a.10. The corresponding note for ITS 5.5.9.b refers to Specification 5.5.9.e. The complete ITS reference is Specification 5.5.9.e.10, page 5.0 - 20. Comment: Revise the submitta! to provide the complete reference.

Comed Response to Issue CnmEd will revise the ITS submittal to provide the complete reference to 5.5.9.e.10 for CTS SR 4.4.5.2. This change will be provided in our comprehensive ITS Section 5.0 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAl.

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NRC RAI Number NRC Issued Date RAI Status 5.5-04 6/12/98 Open - NRC Action Required NRC Description ofIssue

'5.5-04 ITS 5.5.9.d.4.1, inspection Frequencies, page 5.0-17

' CTS 4.4.5.3.c.1, Reactor Coolant System, page 3/4 4-15 '

. CTS 4.4.5.3.c. I refers to Specification 3.4.6.2.c. Corresponding ITS 5.5.9.d.4.i refers to LCO 3.4.13, "RCS Operational Leakage." The complete reference is "LCO 3.4.13.d, "RCS Operational Leakage." Comment: Revise the submittal to (O

provide the complete reference.

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Comed Response to issue Comed will revise the ITS submittal to provide the reference to "LCO 3.4.13.d" and "LCO 3.4.13.e" in place of

~ Specification 3.4.6.2c" for CTS SR 4.4.5.3.c.l. This change will be provided in our comprehensive ITS Section 5.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAl.

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NRC RAI Number NRC Issued Date RAI Status 5.5-05 6/12/98 Open - NRC Action Required NRC Descript!an of Issue 5.5-05 ITS 5.5.11.c, Ventilation Filter Testing Program (VFTP), page 5.0-29J

. CTS 4.7.6.c.2, d, h(2), and j, Plant Systems, page 3/4 7 17 CTS 4.7.7.b.2, Plant Systems, page 3/4 7-19 CTS 4.7.7.c, Plant Systems, page 3/4 7-20 CTS 4.9.12.c, Refueling Operations, page 3/4 9-15 These surveillance address methyl iodide penetration testing. The CTS surveillance specify that the tests be performed at a L

specific temperature and relative humidity. The corresponding program description in the ITS specifies that these tests be performed at or below a specific temperature and at or above a specific relative humidity. The CTS markup shows neither L

the changes nor the justification. Comment: Revise the submittal to identify these changes and provide justification.

I-Comed Response to issue The LCO Markup for STS 5.5.ll.c will be revised to delete the "less than or equal to" for the temperature restriction and the

" greater than or equal to" for the relative humidity. ITS 5.5.ll.c will read, ". at a temperature of 30'C and a relative

/D humidity specified below.... " This change will be provided in our comprehensive ITS Section 5.0 closeout submittal C./

revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAI.

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R:sponse to NRC RAI Dated 06/12/98 17-Jul-98

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NRC RAI Number NRC Issued Date RAI Status 5.5 6/12/98 Open - NRC Action Required NRC Description of Issue..

5.5-06 ITS 5.5.13.c, Diesel Fuel Oil Testing Program, page 5.0-16 CTS 4.1.1.2.e, Electrical Power Systems, page 3/4 8-4 DOC LA15

JFD P7

STS 5.5.13.c specifies that the diesel fuel oil shall be tested for total particulate concentration in accordance with ASTM D-2276, Method A-2 or A-3. CTS 4.1.1.2.e references Method A. ITS 5.5.13.d states, ".. Total particulate concentration of the i

fuel oil is 10 mg/l when tested every 31 days in accordance with ASTM D-2276.", but does not include the reference to Method A-2 or A-3. Comment: P7 states "The details of the method to be used shall be specified in the " Diesel Fuel Oil Testing Program." ITS 5.5.13.c states, ". particulate concentration of the fuel oil is < 10 mg/l when tested every 31 days m i

accordance with a ASTM D-2276..." but does not specify Method A.2 or A.3. Providejustification for not specifying -

- Method A.2 or A.3.

Comed Response to Issue Comed will revise ITS 5.5.13.c (not 5.5.13.d), Diesel Fuel Oil Testing Program, to comply with the CTS by specifically stating that the fuel oil will be tested in accordance with ASTM D-2276 Method A. This change will be provided in our comprehensive ITS Section 5.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAI.

NRC RAI Number NRC issued Date RAI Status 5.5-07 6/12/98 Open-NRC Action Required G

NRC Description ofIssue 5.5-07 ITS 5.5.16, Containment Leakage Rate Testing Program, page 5.0-35 CTS, Operations Mode, item 1.20.a Pa, page 1-4 The definition for Pa provided by CTS 1.20.a states, "..l.20.a Pa shall be the maximum calculated primary containment pressure (44.4 psig) for the design basis loss of coolant accident." Corresponding ITS 5.5.16 contains this CTS sentence and adds an additional sentence, ".. The containment design pressure is 50 psig." Nojustification was provided for this

, proposed change to the CTS. Comment: Revise the submittal with justification for this proposed change or confmm to the CTS.

' Comed Response to Issue Comed will revise the ITS submittal to conform to the CTS by deleting the sentence, "The containment design pressure is 50 psig." This change will be provided in our comprehensive ITS Section 5.0 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAl.

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5.5-08 6/12/98 Open - NRC Action Required

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NRC Description of Issue 5.5-08 ITS 5.5.17 Battery inspectio'n Program CTS 4.8.2.1.2 and Table 4.8-2 DOC LA25 JFD C6

. CTS 4.8.2.1.2 and Table 4.8-2 contain requirements for battery inspections. DOC LA25 states, "..This information is to be relocated to the Battery inspection Program and the ITS contains a more generic program description. The requirements ofITS 5.5.17, Battery inspection Program, and SR 3.8.6.1 ofITS 3.8.6 require certain battery inspections and tests to be performed in accordance with the Battery Inspection Program and ITS 5.5.17 provides the programmatic requirements for battery inspections. The 1

relocation of this information maintains consistency with NUREG-1431, as modified by TSTF-115)." TSTF-115 was withdrawn by NEl. Comment: TSTF-ll5 was withdrawn by NEI and replaced by TSTFs 198 through 202 and none of these TSTFs have been approved by NRC. Otherjustification must be provided or return to CTS without a Battery inspection Program.

Comed Response to issue No change. Comed submitted ITS Revision C by letter dated February 26,1998. ITS Revision C deleted ITS 5.5.17, Battery inspection Program, and placed the battery requirements in ITS Section 3.8, thereby conforming to NUREG-1431.

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NRC RAI Number NRC issued Date RAI Status 5.6-01 6/12/98 Open-NRC Action Required

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'1RC Description of Issue

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5.6-01 ITS 5.6.2, Annual Radiological Environmental Operating Report, page 5.0-39 CTS 6.9.1.6, Radiological Environmental Operating Report, page 6-22 DOC A9(Not used)

DOC L6 CTS 6.9.l.6 requires in part that the Annual Radiological Environmental Operating Report be submitted by May 1 of each

. year. Corresponding ITS 5.6.2 specifies May 15. The CTS markup references DOC A9 for this change. DOC A9 was "Not Used." DOC L6 is the correct reference. Comment: Revise the submittal with the correct justification reference.

Comed Response to Issue Comed will revise the CTS Markup for CTS 6.9.1.6 to replace CTS DOC 5.0-A9 with DOC 5.0-L6. This change will be provided in our comprehensive ITS Section 5.0 closeout submittal revision upon NRC's concurrence with the Comed ~

Responses to the ITS Section 5.0 RAI.

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NRC Description of issue '-

,,s 5.6 ITS 5.6.2, Annual Ra' diological Environmental Operating Report, page 5.0-39 CTS 6.9.1.6, Radiological Environmental Operating Report, page 6-22 STS 5.6.2 Note, Annual Radiological Environmental Operating Report, page 5.0-18 DOC A9(not Used)

' STS 5.6.2 contains a Note that states in part that a single submittal of the Annual

' Radiological Environmental Operating Report may be made for the facility. This Note has been adopted in corresponding ITS 5.6.2. However, the markup for corresponding CTS 6.9.1.6 indicates DOC A9. DOC A9 was "Not Used". Comment: Revise the submittal to (1) include the change of date from May I to May 15 with justiCcation. ' And (2) revise the submittal to address the addition of this Note to the CTS and providejustification.

Comed Response to Issue No change. Regarding NRC Comment 1: The change of date from May I to May 15 is discussed in RAI 5.6-01. Comed will revise the CTS Markup for CTS 6.9.1.6 to replace CTS DOC 5.0-A9 with DOC 5.0-L6 Regarding NRC Comment 2:

The addition of the Note to ITS 5.6.1 isjustified by CTS DOC 5.0-A10 and is annotated on CTS Markup page 6-21 as INSERT 6-21 A. Comed continues to pursue this change.

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-m NRC RAI Number NRC Issued Date RAI Status 5.6-03 6/12/98-Open - NRC Action Required NRC Description ofIssue 5.6-03

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ITS 5.63, Radioactive Effluent Release Report, page 5.0-40 C

CTS 6.9.1.7, Radioactive Effluent Release Report, page 6-22 JFD C4, NUREG-1431, as modified by TSTF-152 (approved?)

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ITS 5.6.3 refers in part to the Radioactive Effluent Release Report covering the operation of the facility "during the previous year " The phrase "during the previous year" is not contained in corresponding STS 5.6.3. The markup for corresponding

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CTS 6.9.l.7 shows this phrase being deleted without an accompanyingjustification. Comment: JFD C4, states, "..These changes are consistent with NUREG -1431, as modified by TSTF-152." TSTF-152 was approved which states, "..The Radioactive Effluent Release Report covering the operation of the unit in the previous year shall be submitted prior to May I of each year in accordance with 10 CFR 5036a." Revise the submittal to eliminate the inconsistencies between ITS 5.6.3 E and the markup for CTS 6.9.1.7.

I Comed Response to issue Comed will revise the CTS Markup for CTS 6.9.l.7 to retain the CTS words "during the previous year" to eliminate the inconsistency between the CTS Markup and the LCO Markup. This change will be provided in our comprehensive ITS Section 5.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAl.

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' NRC RAI Number NRC Issued Date RAI Status L[O 5.6-04 6/12/98 Open - NRC Action Required NRC Description ofIssue 5.6-04 ITS 5.6.9.d.5, Steum Generator (SG) Tube Inspection Report, page 5.0-45 ITS 5.6.9.d.6, Steam Generator (SG) Tube Inspection Report, page 5.0-45 CTS 3.4.5, Steam generators DOC A24 1

On 8/19/97, the licensee requested an amendment to revise CTS 3.4.5, Steam Generator, with an insert (3.4.17c). The revised CTS would include:

5.6.9.d.5 "If cracking is observed in the tube support plates."

5.6.9.d.6 "If any tube which previously passed a 0.610 inch diameter bobbin coil eddy current probe currently fails to pass a 0.610 inch diameter bobbin coil eddy current probe."

i These changes to the Byron /Braidwood CTS are contingent upon the s/19/96 amendment being approved by NRC.

Comment: The amendment was approved, but it is only applicable until Braidwood I shuts down in September 1998.

Comed Response to Issue

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Comed will revise the ITS submittal to replace affected pages in Sections 3.4 and 5.0 (CTS Markups) as a result of the l

issuance of Amendment 92 for Braidwood and Amendment 101 for Byron. This change will be provided in our -

I comprehensive ITS Section 5.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 5.0 RAl.

j NRC RAI Number NRC issued Date RAI Status

'5.6-05 6/12/98 Open - NRC Action Required.

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('N NRC Description ofissue 5.6-05' I

5.6, Reporting Requirements TSTF-37, R.1 affects NUREG-1431. TSTF-37, R.1 deletes STS 5.6.7, EDG Failure Report and the deletion of this report in turn alTects numbering of 5.6.8, PAM Report; 5.6.9, Tendon Surveillance Report; and 5.6.10, Steam Generator Tube inspector Report.

l Sections 3.3.3 Post Accident Monitoring (PAM) Instruction j

3.8.1 AC Sources - Operability Comment: TSTF-37, R.i is still pending (5/27/98). No DOC or.iFD is identified with the use of TSTF-37, R.I. Unless TSTF-37, R.1 is approved,5.6.7, EDG Failure Report, should be included in Byron /Braidwood 1 TS.

Comed Response to Issue The changes associated with TSTF-37 are consistent with our current licensing basis. The diesel generator reporting requirements were deleted from CTS by Amendment 71 (Braidwood) and Amendment 79 (Byron). Therefore, since this i:

change is current licensing basis, this change is not contingent upon the NRC approval of TSTF-37. Comed continues to pursue this change.

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NRC RAI Number NRC Issued Date RAI Status 5.7-01 6/12/98 Open - NRC Action Required NRC Description ofIssue 5.7 5.7,liigh Radiation Area L2'

'P11 CTS 6.12 (L2) and NUREG 3.7 (Pi l) make use of the same quote, "..which provides high radiation area access control alternatives pursuant to 10 CFR 20.203(c)(2)(revised to Section 10 CFR 20.1601(c)), has been significantly revised as a result of the change to 10 CFR 20, the guidance provided in Regulatory Guide 8.38, " Control of Access to liigh and Very liigh Radiation Areas in Nuclear Power Plants," and current industry techno ogy in controlling access to high radiation l

areas. The changes include additional requirements for groups entering high radiation areas, clarification of the need for communication and control of workers in high radiation areas, clarification of definition of high radiation areas, and the clarification that an equivalent document to a Radiation Work Permit is acceptable. This change provides acceptable alternate methods for controlling access to high radiation areas. As a result, this change will not decrease the ability to provide control of exposures from external sources in restricted. These changes are consistent with recently approved Amendment requests for other Commonwealth Edison stations." Comment: lias an amendment been submit'ed for Byron /Braidwood in this area ofIligh Radiation?

1 Comed Response to issue A CTS License Amendment Request (LAR) was not submitted for Byron and Braidwood. Ilowever, per telecons with Section 5.0 NRC Reviewer, Jim Wiggington, ITS Revision D (to ITS Section 5.7, liigh Radiation Area) was submitted to the NRC by Comed letter dated February 24,1998.

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