ML20248M147
| ML20248M147 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 06/01/1998 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20248M148 | List: |
| References | |
| RTR-NUREG-1431 NUDOCS 9806150080 | |
| Download: ML20248M147 (21) | |
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Commonwealth lilison Company I *
, liraidwood Generating Mation
. , Route al, Ilox H4 lirareville, 11.60407-9619 Tel 81%153 2801 June 1,1998 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos. 50-454 cid 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 Commonwealth Edison's (Comed's) Response to the NRC's Request for Additional Information (RAI) for Improved Technical Specifications (ITS)
Section 3.8
References:
G. Stanley and K. Graesser (Comed) to NRC letter dated December 13,1996 1
1 The purpose of this letter is to transmit Comed's Response to the NRC's RAI for ITS l Section 3.8. 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 l Comed request (Reference 1) to amend the Current Tecimical 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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U.S. Nuclear Regulatory Commission June 1,1998 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.
L Per Comed's Response to RAI 3.8.4-05, a page was missing from the "Brwd ITS" tab in the ITS submittal (Braidwood Bases page B 3.8-58b, Revision C, dated 12/17/97).
Several copies of the missing page are included with this RAI Response.
, Please address any comments or questions regarding this matter to Dave Chrzanowski, Nuclear Licensing Department.
Sincerely, thy J. Tulon -
te Vice President
' Braidwood Nuclear Generating Station -
Attachment 1: Response to NRC RAI Report cc: Regional Administrator - Region III, NRC Braidwood Project Manager-NRR
- Byron Project Manager - NRR Senior Resident Inspector - Braidwood Station Senior Resident Inspector - Byron Station Office of Nuclear Facility Safety -IDNS pL.ntc\98035tjt. doc c______-___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ .
Attachment 1 l
" Response to NRC RAl" Report On the Comed ITS Submittal
Response to NRC RAI D:ted 04/29/98 ol-Jun-98 NRC RAI Number NRC issued Date RAI Status h) 3.8.1-01 NRC Description of lasue 4/29/98 Open - NRC Action Required j 3.8.1-1 <
DOC A2 The discussion in DOC A2 is not consistent with Insert 3.8-2D or with ITS 3.8.1 Condition G. Is the DOC or the LCO J and the Insert correct?
Comed Response to Issue ITS 3.8.1 Condition G will be revised, consistent with the clean copy and LCO markup, to state, "Two DGs inoperable, and one or more buses with one or more required qualified circuits inoperable OR One DG inoperable, one bus with two required qualified circuits inoperable, and the second bus with one or more required qualified circuits inoperable." This !
change will be prosided in our comprehensive ITS Section 3.8 closecut submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
NRC RAI Number NRC issued Date RAI Status 3.8.1 02 4/29/98 Open - NRC Action Required NRC Description of issue 3.8.1 2 j JFD BP45 g insert B 3.8-15 A is consistent with the ITS Bases discussion for ITS 3.8.1 Condition G. However, the inclusion of the two t, DG inoperable example is not helpful in explaining the condition because that example does not explain the level of equipment operability at which the Condition must be entered.
Comed Response to issue j
No change required per discussions with ITS Section 3.8 Resiewer (Jim Luchman) during May 7,1998 meeting with Comed and NRC.
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Resp:nse to NRC RAI D: tid 04/29/98 ol-Jun-98 l
l NRC RAI Number NRC Issued Date RAI Status O 3.8.1 03 4/29/98 Open - NRC Action Required V NRC Description of Issue l
3.8.1-3 I DOC LA4 The DOC states "This change is required to properly reflect the manufacturer's current recommendation . " and "the manufacturer is indifferent to the benefits of this type of start" What is the documented basis for these statements?
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! Comed Response to Issue 1 i
As specified in ITS SR 3.8.1.2 Note 3, "A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR." The statements in question from DOC 3.8-LA4 were meant to address this type ofidle stan. The manufacturer acknowledges the advantages of prelubed/ prewarmed starts, but is indifferent to the advantages of reduced speed (idle) starts. It is their contention that reduced fuel starts have the greatest value and reduced speed starts .
have minimal positive impact. To better clarify this, a portion of DOC 3.8-LA4 will be resised to state, " It should be noted that the phrase " recommended by the manufacturer" has been deleted from the CTS footnote. This change is required to properly reflect the manufacturer's current recommendation for Cooper-Bessemer diesel generators. No specific recommendation has been provided concerning modified reduced speed starts. This change in the footnote is j
considered to be an editorial correction to properly characterize the basis for the modified starts. " This change will be i provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.
NRC RAI Number NRC Issued Date RAI Status 3.8.1-04 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.1-4 1
DOC L8 ;
The discussion states ' . and eliminating an upper voltage criteria . " What voltage criteria are climinated? 1 Comed Response to issue !
CTS SR 4.8.1.1.2.f.2) requires the DG to reject the equivalent ofits single largest post-accident load with acceptance criteria of 4160 V plus or minus 420 V (3740 V - 4580 V) " transient" generator voltage. ITS SR 3.8.1.9 requires that, following load rejection, the " steady state" voltage be maintained 3950 V - 4580 V, but does not impose a transient voltage limit. Therefore, the transient voltage criteria were eliminated. For clarity, the last sentence in DOC 3.8-L8 will bc )
resised to state, "Therefore, meeting the frequency acceptance criteria and eliminating the transient voltage criteria l continues to provide adequate testing of the DG response." This change will be prosided in our comprehensive ITS l Section 3.8 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl. I l
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Response to NRC RAI Dated 04/29/98 o n-Jun-98 NRC RAI Number NRC Issued Date RAI Status 3.8.1-05 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.1-5 DOC Mll The CTS markup (CTS 4.8.1.1.2 .f.2 ) of the voltage values (-420, +210) results in values that are inconsistent with those in ITS 3.8.1.9.
Comed Response to Issue The Byron CTS markup for CTS SR 4.8.1.1.2.f.2 will be revised from -420/+210 to +420/-210. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
NRC RAI Number NRC Issued Date RAI Status 3.8.1-06 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.1-6 Bases JFD P36 The JFD does not appear to be applicable in the markup of the second paragraph of STS Bases page B 3.8-9.
Comed Response to Issue O- The Actions Section of the Bases for ITS LCO 3.8.1 will be revised to state, " Discovering one required DG inoperable coincident with one or more inoperable required redundant feature (s) results in starting the Completion Time for the Required Action. Four hours from . "
In addition, Bases JFD 3.8-P36 will be revised to include the following discussion, "The Actions Section of the Bases for ITS LCO 3.8.1 was revised to be consistent with ITS LCO 3.8.1 Required Action B.2 and current plant design. Plant specific design consists of two AF pumps. 'A' train AF includes a motor driven AF pump that relies on the 'A' DG for emergency power. 'B' train AF includes a stand-alone diesel-driven AF pump that does not depend on the 'B' DG. In the event the 'A' DG were to be declared inoperable, not only would the redundant feature (s) associated with the OPERABLE DG (i.e., the 'B' DG) be required to be evaluated for OPERABILITY, but so would the independent 'B' AF pump. Further, in the event the 'A' DG and the 'B' AF pump were to be declared inoperable, both AF pumps would be declared inoperable, and the appropriate Conditions ofITS LCO 3.7.5 would be entered."
This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
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Response to NRC RAI Dated 04/29/98 01-Jun-98 NRC RAI Number NRC Issued Date RAI Status O
(d 3.8.1-07 NRC Description of Issue 4/29/98 Open - NRC Action Required 3.8.1-7 Bases JFD B1 and Insert B 3.8-27A (Bases JFD P21)
The markup of the STS Bases for SR 3.8.1.3 climinates the discussion of power factors (STS B 3.8-13) and substitutes a discussion of DG operation from 0 to 1000 kVars. Use of Bases JFD B1 is not appropriate and if Bases JFD B3 was intended, justification of the O to 1000 kVars range should be provided as it does not appear in the CTS. Likewise, w hile Bases JFD P21 makes the case for discontinuing testing at rated power factor, it fails to provide any technical basis for the guidance provided in Insert B 3.8-27A.
Comed Response to Issue Bases JFD 3.8-B1 will be revised to Bases JFD 3.8-B3 for the Bases Markup for SR 3.8.1.3. In addition, a Bases 'P' JFD will be added for this change and will state, "As stated in the STS Bases for SR 3.6.1.3, there are no power factor requirements established by the SR. The substitution of operation between 0 and 1000 kVars in place of the power factor references is a plant specific limitation. This limitation ensures that in the event of a full load reject during testing, the resulting voltage transient will not exceed the vendor reconunended maximum value of 5000 V. While operating outside the stated kVar band, a full load reject may result in a voltage transient that exceeds 5000 V." For this reason Bases JFD 3.8-P21 (ITS SR 3.8.1.14) states that testing at rated power factor has been determined to be unjustified, potentially destructive testing due to exceeding the vendor recommendation for maximum generator voltage.
In addition, the following will be added to Bases JFD 3.8-P21, "The guidance from Insert B 3.8-27A ensures that the DG is tested at its rated power factor for a brief time to verify the generator, regulator, and exciter can achieve their design ratings. During testing, the DG is increased to rated power factor for a short period while at full load and then returned to
/O <1000 kVARs. This testing ensures the full functionality of the generator and voltage regulator / exciter and yet serves to
\ minimize exposure to the risks associated with a full load reject at rated power factor."
These changes will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl. (See RAI 3.8.1-23.)
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Response to NRC RAI Dated 04/29/98 ol-Jun-98 NRC RAI Number NRC issued Date RAI Status O 3.8.1-08 4/29/98 Open - NRC Action Required NRC Description of issue 3.8.1-8 ITS 3.8.1 Changing of"o!Tsite" circuit to " qualified" circuit appears to be a problem without the carryover of the CTS qualification of"Each units System Auxiliary Transformer bank energized from an independent transmission circuit." The ITS LCO Bases state that a qualified circuit is as defined in the FSAR yet, the discussion then goes on to state in tabular form what the two qualified circuits arc. The problem with that discussion is that there is no assurance of the SATs being energized from independent transmission circuits. In fact, the ITS 3.8.1 Bases Background states, in part ".. switchyard are maintained in accordance with the UFS AR and are not (emphasis added) governed by the requirements of Technical Specifications." Both the words of the STS and those of the CTS assure that independence will be maintained while the ITS does not. (Note: Qualified circuit has also been substituted into other places in the ITS).
Comed Response to Issue The second sentence in Insert B 3.8-1 A will be revised to state, "From the switchyard, two electrically and physically separated lines (i.e., independent transmission circuits) provide AC power through their associated System Auxiliary Transformer . " This change will be provided in our comprehensive ITS Section 3.8 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.
j NRC RAI Number NRC issued Date RAI Status 3.8.1 09 4/29/98 Open - NRC Action Required
, NRC Description of issue
( 3.8.1-9 L
DOC L2 i The DOC states "This backup source of power is not credited in any design basis event and is not needed to preclude any new or different accident." That statement does not adequately explain why, if that is the case, the requirment still ended up in the CTS. Was it included for any extended action time or other consideration elsewhere in the CTS?
Comed Response to Issue The requirement to have the opposite unit's diesel generator capable of crosstic is a design strength that was recognized in the Auxiliary Feedwater Reliability Analysis that was performed during the initial licensing of Byron and Braidwood.
This provides a unit's motor driven AF pump with the capability of being powered from any of two offsite power sources or the division-specific diesel generator of either unit. This crosstic ability provides the circuit path to align the second required offsite powe'r source to the ESF busses. As stated, this ability is not credited in the Chapter 15 analyses because i manual actions are required to c s mplete the crosstic. (See RAI 3.8.1-14.) ;
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Response to NRC RAI Dated 04/29/98 o n-Jun-98 NRC RAI Number NkC hmed Date RAI Status
') 3.8.1 10 4/29/98 Open - NRC Action Required NRC Description of issue 3.8.1 10 DOC L3 This DOC explains the two relaxations but provides no basis for why either is acceptable.
Comed Response to issue DOC 3.8-L3 will be revised to state, "With one DG inoperable, CTS LCO 3.8.1.1, Action c, requires all features that depend on the Operable DG to be Operable. If this requirement can not be met, the CTS Action requires a shutdown be commenced within 2 houis. ITS LCO 3.8.1 Required Action B.2 provides two relaxations:
- 1. Rather than a plant shutdown requirement, the ITS requires that the feature (s) supported by the inoperable DG be declared inoperable ifits redundant counterpart is inoperable. This provides for actions appropriate to the actual inoperabilities, which may avoid an immediate shutdown. For example, if the "B" DG is inoperable in conjunction with the "A" hydrogen recombiner, CTS Actions would require a shutdown to commence within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, while ITS would allow entering Actions for both hydrogen recombiners inoperable thereby providing for the complete 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the DG to Operable status. Not requiring a unit shutdown is acceptable since Required Action B.2 is intended to provide assurance that a loss of ofTsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related trains. Redundant required feature failures consirt ofinoperable features associated with a train, redundant to the train that has an inoperable DG. !n this condition, the remaining OPERABLE DG is adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost, however, function may not have been lost.
- 2. ITS allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (versus 2 homs) to commence the specified action. This extension provides additional time to restore either the inoperable DG or the inoperable feature, and is considered a reasonable time to effect repairs prior to requiring a forced shutdown of the unit. This extension is acceptable since it takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hout Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period."
This change will be prwided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence 1 with the Comed Responses to the ITS Section 3.8 RAl.
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i Response to NRC RAI D:ted 04/29/98 01-J x-98
!- NRC RAI Number NRC Ipued Date RAI Status 3.8.1-11 4/29/98 Open - NRC Action Rcquired d NRC Description of issue l
3.8.1-11 ITS SR 3.8.1.3 Note I in the ITS, the use of the manufacturer's recommendations 's permissive. Ilowever, in CTS 4.8.1.1.2.a.5 the test must be done in accordance with the manufacturer's recommendations. There is no discussion supporting this less restrictive change.
Comed Response to Issue Comed will revise the CTS markup to include a less restrictive 'L' DOC w hich will state, " CTS SR 4.8.1.1.2.a.5) requires "verif 3ing the generator is synchronir.ed, loaded to greater than or equal to 5500 kW IN ACCORDANCE WITH TliE MANUFACTURER'S RECOMMENDATIONS . ." ITS 3.8.1.3 Note I states, "DG loadings MAY INCLUDE GRADUAL LOADING AS RECOMMENDED BY THE MANUFACTURER " There may be occasions where the manufacturer's recommendations may not be strictly complied with, but the DG is still verified operable. Prudent operations may necessitate an engineering evaluation of the data to ensure the slight alteration is acceptable and the manufacturer may be contacted for :; confirmation. This is considered to be a less restrictive change since literal compliance with the CTS would require that the DG loading for this SR only be done as recommended by the manufacturer. This change is consistent with NUREG-1431." This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
NRC RAI Number NRC Issued Date RAI Status 3.8.1-12 4/29/98 Open - NRC Action Required
(/'~%'")NRC 3.8.1 12 Description oi .ssue DOC LA6 The acceptable load range vr. lues (greater than or equal to 4950 KW and less than or equal to 6050 KW) are not consistent l with the CTS footnote 6050 (+0, -150) or the values in ITS SR 3.8.1.14. The ITS SR values are consistent with the ITS SR Bases which in turn make the Bases inconsistent with LA6. What are the correct numbers?
Comed Response to Issue The second sentence in DOC 3. (-LA6 will be resised to state, "ITS simply states an acceptable load range (i.e., greater l than or equal to 5775 kW and less than er equal to 6050 kW); relocating the remaining discussion to the ITS Bases." This I change will be prosided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI, i
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Response to NRC RAI Dated 04/29/98 OI-Ju>98 NRC RAI Number NRC Issued Date RAI Status (A
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) 3.8.1-13 4/29/98 Open - NRC Action Required NRC Description of lasue 3.8.1-13 DOC L10 The DOC states "No analyzed event credits the use of the cross connect for DG operation . " That does not explain why it still ended up in the CTS.
Comed Response to Issue No change. CTS 4.8.1.1.2.f.11) requires verification that the fuel transfer pump transfers fuel from cach fuel storage tank to the day tank of each dicsci via the installed cross-connection lines. The cross-connection capability only provides alternate means of ensuring that dicsci fuel oil from the storage tank can be supplied to each day tank. The only function the CTS SR provides is a verification that the cross-connection and associated transfer pump can transfer fuel oil to the day tanks. Comed does not take any credit for the use of the cross-connection capability. This SR was in the original Westinghouse STS, NUREG-0452, and therefore incorporated into the original CTS. Comed does not take credit for the cross-connection in any safety analysis or accident mitigation factors. Since this SR does not meet the NRC Criteria 10 CFR 50.36(c)(2)(ii), it was not incorporated into ITS. Comed continues to pursue this change.
NRC RAI Number NRC Issued Date , RAI Status 3.8.1 14 4/29/98 Open - NRC Action Required NRC Description of Issue
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DOC LA10 The DOC states "This capability is not a credited function for any assumed design basis event . ." Again this does not l explain why it still ended up in the CTS. '
Comed Response to Issue The surveillance in question provide a verification of t'.e ability to crosstic the unit's ESF buses. This pathway is the one relied upon to provide the unit with its backup offsite power source. Because the CTS LCO requires the ability to power an ESF bus from two offsite sources, the surveillance in question was required to demonstrate this ability. As stated, the Chapter 15 analyses do assume this ability. (See RAI 3.8.1-09.)
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Response to NRC RAI D:ted 04/29/98 01-J a 98 NRC RAI Number NRC lasued Date RAI Status
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3.8.1 15 4/29/98 Open - NRC Action Required v NRC Description of Issue 3.8.1-15 DOC L15 Is this change considered less restrictive because in the CTS loss of power would require a 2 square inch vent while the ITS allows the RilR suction relief or other paths that do not rely on power to be used? If that is the case, isn't that just letting the LTOP TS control? If so, w hy isn't tids an administrative change?
C ,mEd Response to issue
~ This change is classified as less restrictive because the CTS requires the unit to be depressurized through a two square inch vent upon loss of the required AC source regardless of the availability of the LTOP features. Byron and Braidwood can provide for LTOP using any combination of pressurizer PORVs (2) or Rii Suction Relief Valves (2), or by depressurizing through a 2 square inch vent. The proposed ITS will not require the depressurization if LTOP is available. This constitutes a relaxation and has therefore been classified as less restrictive. (Correction Note: This RAI penains to ITS LCO 3.8.2, not ITS LCO 3.8.1.)
NRC RAI Number NRC issued Date RAI Status 3.8.1-16 .4/29/98 Open - NRC Action Required NRC Description of issue 3.8.1-16 ITS LCO 3.8.1 and Insert 3.8-9B
%) ITS LCO 3.8.1 states the DGs are capable of supplying "the . . System." Insert 3.8 9B makes ITS LCO 3.8.2 state two DGs capable of supplying "one division of... subsystems." STS LCO 3.8.1 states two DGs ' capable of supplying the I onsite IE , subsystems." In order to make it clear that each DG supplies subsystems (consistent with the STS and LCO 3.8.2) ITS 3.8.1 should read " two DGs each capable of supplying one division of... the Class IE power distribution ,
system."
Comed Response to issue No change. Comed has conformed to the NUREG for ITS LCO 3.8.1. The details of the onsite Class IE AC Electric )
Power Distribution System are delineated in the LCO Section of the Bases for ITS LCO 3.8.1, stating " separate and j independent DGs for each division . " Comed continues to pursue this change. !
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Response to NRC RAI D:ted 04/29/98 01.lun-98 NRC RAI Number NRC Issued Date RAI Status 3.8.1-17 4/29/98 Open - NRC Action Required l
NRC Descrig. tion'of Issue l 3.8.1 17 JFD P25 l CTS requires the dicsci to start from " ambient" and the STS requires from " standby" conditions for SRs 3.8.1.2,11,12, l 19, and 20. It is correct as stated that as the terms are used, they mean the same. However, using neither term in the ITS i
would allow any of the above tests to be run in a situation where the diesel was already at or about full operating temperatures. The STS language should be adopted to ensure that these tests are done only from true standby / ambient conditions.
Comed Response to issue No change. As part of CTS Amendment #71 (Braidwood) and Amendment #79 (Byron), Braidwood and Byron Stations committed to performing testing based upon recommendations of Reg Guide (RG) 1.9, Revision 3. Appendix A of the CTS amendment included proposed exceptions to RG 1.9 Revision 3. The RG 1.9 exceptions associated with positions C.2.2.1 (ITS SR 3.8.1.2 and SR 3.8.1.7), C.12.4 (ITS SR 3.8.1.11) and C.2.2.6 (ITS SR 3.8.1.19) address taking exception to " starting from standby conditions". This appendix was reviewed and approved by the NRC as part of the CTS j Amendments. Resiew of RG 1.9 testing requirements shows no specific prerequisite to start the engine from standby for position C.2.2.14 (ITS SR 3.8.1.20). Comed continues to pursue this change.
NRC RAI Number NRC Issued Date RAI Status 3.8.1-18 4/29/98 Open - NRC Action Required NRC Description ofIssue
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,) 3.8.1 18 Insert to Bases for ITS SR 3.8.1.16 The bases discussion has been modified to state the SR is in general conformance with the recomme.ndations of Reg Guide 1.9 paragraph 2.2.11. How is this reflected in the discussion of Reg Gufde 1.9 contained in FSAR Appendix A7 That discussion does not appear to contain any qualifications with respect to this testing.
Comed Response to Issue The Surveillance Requirements Section of the Bases for ITS LCO 3.8.1 for ITS SR 3.8.l.16 will be revised to conform to the STS. "In general conformance with the recommendations of.. " will be resised to "As required by , " This change will be provided in our comprehensive ITS Section 3.8 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI. (See RAI 3.8.4-01.)
NRC RAI Number NRC issued Date RAI Status 3.8.1-19 4/29/98 Open - NRC Action Required NRC Description ofissue 3.8.1-19 l
DOC L28 and JFD P22 j l
Identified as Beyond Scope Item #11 Comed Response to Issue 7 No change required. Beyond Scope item #11 was accepted per discussions with NRC Staff during May 7,1998 meeting (h- with Comed and NRC.
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Respons2 to NRC RAI Dated 04/29/98 o n-Ja-98 l NRC RAI Number NRC !ssued Date RAI Status 3.8.1 20 4/29/98 Open - NRC Action Required NHC Description of Issue 3.8.1-20 DOCS L26 and L29, and JFDs P21 and P23 Identified as Beyond Scope item #12 Comed Response to Issue No Comed Response required at this time. The subject RAI is currently under resiew by the NRC as a Beyond Scope issue that has not yet received final NRC disposition. In addition, the proposed change is included in WOG-89. Comed will address any questions generated as a result of the NRC resiew for the subject RAI w hen they are received.
NRC RAI Number NRC lasued Date RAI Status 3.8.1-21 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.1-21 DOC L24 and JFD P23 Identified as Beyond Scope item #13 Comed Response to Issue 7 No Comed Response required at this time. The subject ' Al is currently under resiew by the NRC as a Beyond Scope issue
- that has not yet received final NRC disposition. Comed will address any questions generated as a result of the NRC
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(_/ resiew for the subject RAI when thq are received.
NRC RAI Number NRC lssued Date RAI Status 3.8.1-22 4/29/V8 Open - NRC Action Required NRC Description of lasue 3.8.1-22 JFD P9 This JFD is applicabic .o LCOs 3.8.2 and 3.8.7, it is unclear why it is used in the markup of STS 3.8.1 (Page 3.8-4).
Comed Response to Issue The Note will be resised to adopt the STS wording. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl. Note: This 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, 3.8.1,3 8.2, and 3.8.7. (Sce RAls 3.4.14-02,3.6.2-02,3.7,7-04, and 3.7.8-06.)
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L Respons? to NRC RAI Dat:d 04/29/98 ol-Jux-98
[ 3.8.1-23 4/29/98 Open - NRC Action Required
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l NRC Description of Issue 3.8.1-23 Bases for ITS SR 3.8.1.3 Given that the second paragraph of the Bases says that there are no power factor requirements and that the DG is normally operated between 0 and 1000 kVars, wouldn't it be better to modify the discussion in the last paragraph to remove the power factor discussion or change it to kVars discussion?
Comed Response to Issue The fourth paragraph in the Suntillance Section of the Be arrITS LCO 3.8.1 for SR 3.8.1.3 will be revised to state, "
Note 2 states that momentary transients, (e.g., changing bus loads) do not invalidate this test. Similatly, momentary kVar i
transients outside the specified range do not invalidate this test. " This change will be provided in our comprehensive
! ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI. (See RAI 3.8.1-07.)
NRC RAI Number NRC Inued Date RAI Status 3.8.2-01 4/29/98 Open - NRC Action Required l NRC Description of Inue 3.8.2-1 DOC A14
_(O~) The intent ofITS Conditions A and B should be to return the inoperable battery charger to operable status and once returned to that status break the cross-tie with the other unit and begin to use that charger. As proposed in DOC A14, if the charger could be operable sooner than the required Completion Time the cross-tic would not have to be broken for up to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />. That may not have been the intent but giving the cross-tie a separate Completion Time certainly makes that reading a reasonable one.
Comed Response to issue No change. ITS LCO Condition A applies to a unit in MODES 1-4 with an inoperable battery charger. Condition B applies to a unit in MODES 1-4 crosstied to the opposite unit in MODES 1-4 with an inoperable battery charger. In either case, Condition A or Condition B, assuming that the battery charger is restored to OPERABLE status sooner than the required Completion Time of 74 E.ua, in order to avoid a unit shutdown per Condition F, the LCO would have to be met (i.e., at least one unit crosstic breaker per division open). This would require the unit to restore the battery charger and open the crosstie breaker within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and exit Condition A. Comed continues to pursue this change. (Correction
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l Note: This RAI pertains to ITS LCO 3.8.4, not ITS LCO 3.8.2.)
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Responsa to NRC RAI Dated 04/29/98 01 Ja98 i NRC RAI Number NRC lasued Date RAI Status
,v gO 3.8.2 412 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.22 JFD C10 Staff has not seen or resiewed changes proposed by WOG-81.
Comed Response to Issue WOG-81 will be withdrawn in its entirety throughout the ITS submittal. The submitt2 will be resised to adopt the STS presentation in the Applicability Section. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal resisjon upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl. (See RAls 3.1.54)2, 3.4 01, 3.5-01, 3.7.10-03, 3.7. I l-02, 3.7.13-06, 3.9.4-06, and 3.9.7-05.)
NRC RAI Number NRC Issued Date RAI Status 3.8.2-03 4/29/98 Open - NRC Action Required NRC Description ofIssue 3.8.2 3 JFD P21 and Bases JFD P26 i
The LCOs and Bases for STSs 3.8.2,3.8.8, and 3.8.10 have been modified by adding a note stating "LCO 1.0.3 is not applicabic". If this is a generic issue a generic change should be proposed for the NRC to consider. On a plant specific q basis it is beyond the scope of the conversion.
/ Comed Response to Issue in Comed's original submittal, ITS Revision A, the proposed change was classified as a generic change (LCO JFD 3.8-C5 and Bases JFD 3.8-C3) based on TSTF-36, Revision 2. However, in ITS Revision C, which withdrew TSTF-115 from the submittal, the proposed change was made plant specific (LCO JFD 3.8-P11 and Bases JFD 3.8-P26). Comed will withdraw the plant specific change for ITS LCOs 3.8.2,3.8.8, and 3.8.10. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
NRC RAI Number NRC Issued Date RAI Status 3.8.3-01 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.3 -l JFD Cl Staff approval of TSTF-2 Rev 1 is pending.
Comed Response to Issue No Comed Response required at this time.
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4 Response to NRC RAI Dated 04/29/98 01-Jan-98 NRC RAI Number NRC Issued Date RAI Status
/ 3.8.4-01 4/29/98 Open - NRC Action Required
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NRC Description of Issue I l
3.8.4 1 ITS 3.8.4 Bases Background in the Background discussion, the word " generally" has been added u hen discussing conformance with Reg Guide 1.6 and IEEE 308. Byron & Braidwood FSAR Section 8.1 and FSAR Appendix A do not appear to contain any exceptions to either of the standards with respect to DC electrical power. What requires the insertion of the " generally" qualifier?
Comed Response to Issue The Background Section of the Bases for ITS LCO 3.8.4 will be resised to conform to the STS by deleting the word
" generally" in the first paragraph. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI. (See RAI 3.8.1-18.)
NRC RAI Number NRC Issued Date RAI Status 3.8.4-02 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.4-2 Bases JFD P30 in the ITS Bases the phrase "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" is deleted. While 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> may not be appropriate for Byron & Braidwood, m Sections 5 and 6 ofIEEE 308 require that the battery charger time be within a time consistent with the design basis and that the battery charging available. Therefore, the charging time for Byron & Braidwood should be available and should be put in place of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Comed Response to Issue Comed agrees. The Background Section of the Bases for ITS LCO 3.8.4 will be resised to conform to the STS. In addition, JFD 3.8-P30 will be deleted. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAI.
i NRC RAI Number NRC issued Date RAI Status l 3.8.4-03 4/29/98 Open-NRC Action Required NRC Description ofIssue 3.8.4-3 Insert 3.8.24 A Why is ITS Condition B "that has an inoperable battery charger . " and Condition C "with an inoperable source . "7 Comed Response to issue ITS LCO 3.8.4 Condition B pertains to an inoperable " battery charger" while Condition C pertains to an inoperable
" battery." Refer to the Actions Section of the Bases for ITS LCO 3.8.4.
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Response to NRC RAI Dated 04/29/98 ol-Jun-98 NRC RAI Number NRC Issued Date RAI Status O
V 3.8.4-04 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.4-4 ITS SR 3.8.4.7 (Byron only) & JFD P28 and Bases JFD P35 l
The STS state that a modified discharge test can be substituted for a senice test but not with a discharge performance test as specified in the ITS SR. Further, JFD P28 states (quoting IEEE 450) "a inodified performance discharge test can be used in lieu of a service test at anytime" This imphes that if a performance discharge test can be used (w hich would be contrary to the STS Bases) it could only be used on some limited basis and not the unlimited basis proposed. Finally, use of the performance discharge test in place of the senice test appears contrary to the Reg Guide 1.129 discussion in the Byron & Braidwood FSAR Appendix A. Further explanation andjustification is needed.
Comed Response to issue Comed will resise Byron ITS SR 3.8.4.7 Note 1 to perform the modified discharge test instead of the performance discharge test in lieu of the senice test. This is consistent with the STS and Braidwood ITS. Performance of the modified discharge test in lieu of the senice test is Current Licensing Basis in CTS, an acceptable practice in the industry, and is also acceptable per the IEEE-450. The modified discharge test encompasses the senice test u hereas the performance discharge test does not encompass the entire senice test. In addition, the Byron Bases will be resised to be consistent with the subject change. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
NRC RAI Number NRC Issued Date RAI Status 3.8.4-05 4/29/98 Open - NRC Action Required b
V N RC Description of issue 3.8.4-5 ITS 3.8.4 Bases References (Braidwood)
It appears that there should be an additional page following B3.8-58a containing the section references.
Comed Response to issue Comed agrees. In the "Bnvd ITS" tab of the submittal, B.3.8-58b is missing for the References Section of the Bases for !
ITS LCO 3.8.4. Copies of this page are included with this RAI Response.
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Response to NRC RAI D2ted 04/29/98 01-Ju -98 l
i NRC RAI Number NRC Issued Date RAI Status 3.8.4-06 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.4-6 ITS 3.8.4 Bases References (Byron) lEEE 450 -1995 is the version of the standard in the Reference section and is the referenced standard for the discussion of frequency and acceptance criteria for a number of the ITS 3.8.4 (and 3.8.6) SRs. Ilowever, the Byron UFSAR states that the frequencies of battery tests are established in accordance with IEEE 450 -1975 (as modified by the proposed 1978 revision). Do the references to different version of the standard create any inconsistencies in application of the SRs and/or are there othe. instances in which the ITS updates standards from those in the FSAR?
Comed Response to issue No change. Byron submitted a License Amendment Request (LAR)in March of 1997 and received a Safety Evaluation Report (SER) dated November 25,1997 addressing the replacement of the original 125 VDC Gould batteries with C&D batteries. The SER noted the change in the referenced standard to IEEE 450-1995 and the change was addressed in an RAI response dated August 7,1997. Replacement of the Gould batteries with the C&D batteries on both units has occurred during the last two refiscling outages in November of 1997 and April of 1998. The Byron UFSAR will be revised to address proper reference ofIEEE 450-1995.
NRC RAI Number NRC Issued Date RAI Status l 3.8.4-07 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.4-7
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Bases JFD P18 l STS 3.8.4.6 recommends that specific battery ratings be provided in the SR. However, consistent with CTS SR 4.8.2.1.2.c.4, the wording "a load equal to manufacturer's rating" is adopted in the ITS (JFD P16). Consistent with that change, it is proposed that the ITS Bases contain the same wording. If the Bases merely repeat the words of the TS, how is a basis for the TS being provided? Why isn't a specific value (vchich can be modified in accordance with the Bases control program) provided in the Bases?
Comed Response to issue The Surveillance Requirements Section of the Bases for ITS LCO 3.8.4 for SR 3.8.4.6 will be revised to state, "This SR requires that cach battery charger be capable of supplying 400 amps and 125 V for greater than or equal to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. These requirements are based on the (design capacity) of the chargers (Ref. 4)." In addition, Bases JFD 3.8-P18 will be deleted.
This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
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- 3.8.5-01 4/29/98 Open - NRC Action Required l
' V NRC Description of Issue 3.8.5-1 JFD C9 TSTF 204 has not yet been approved by the NRC.
Comed Response to Issue No Comed Response required at this time.
NRC RAI Number NRC Issued Date RAI Status 3.8.6-01 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.6-1 Bases JFD P46 TSTF 203 has not yet been approved by the NRC.
Comed Response to Issue No change. In Comed's original submittal, ITS Resision A, the proposed change was classified as a generic change (Bases JFD 3.8-C6), liowever, in ITS Resision C, which withdrew TSTF-115 from the submittal, the proposed change was made plant specific (Bases JFD 3.8-P46), but stated that this change is consistent with TSTF-203. TSTF-203 is O pending NRC approval. The purpose of the clumge was to correct an error in the NUREG that omitted a Bases discussion i addressing the ACTIONS Note in NUREG LCO 3.8.6. Comed continues to pursue this change.
NRC RAI Number NRC Issued Date RAI Status 3.8.6-02 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.6-2 DOC L19 The DOC states that ITS SR 3.8.6.3 requires "this same verification . " when referring to CTS SR 4.8.2.1.2.b.3. However, the CTS requires that the average temperature of all connected cells be checked, while the ITS requires only the average i temperature of representative cells be checked. This less restrictive change has not been justified. j Comed Response to Issue Comed agrees and will revise DOC 3.8-L19 to state " CTS SR 4.8 2.1.2.b.3) requires that once every 92 days and within 7 !
days after a battery discharge, the average electrolyte temperature of all connected cells is verified to be above 600F. ITS i
' SR 3.8.6.3 requires that once every 92 days the average electrolyte temperature of representative cells is verified to be l
600F. Deletion of the SR after a battery discharge is acceptable because a large discharge of the battery will tend to heat !
the battery electrolyte, not reduce the temperature. Therefore, the requirement to measure electrolyte temperature afler a i discharge is not necessary. In addition, CTS requires the average electrolyte temperature for all connected cells be verified. ITS requires the average electrolyte temperature of the representative cells be verified. Changing the SR to representative cells is consistent with IEEE-450 testing requirements and terminology. Based on the above, both of these changes are considered to be less restrictive, however since the changes are consistent with an approved NRC and industry p
standard, there is no impact on safety." This change will be provided in our comprehensive ITS Section 3.8 closcout submittal resision upon NRC's concurrence with the Comed Responses to the ITS Section 3.8 RAl.
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Resp:nse to NRC RAI D:ted 04/29/98 ol-Jux-98 NRC RAI Number NRC issued Date RAI Status
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3.8.7 01 4/29/98 Open - NRC Action Required (v% )-
NRC Description of Issue 3.8.7 1 JFD Pls and Bases JFD P43 i
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TSTF 202 has not yet been approved by tlic NRC.
Comed Response to issue No Comed Response required at this time, in ITS Revision C, which withdrew TSTF-115 from the submittal, the
. proposed change was made plant specific (DOC 3.8-L23, LCO JFD 3.8-P18, and Bases JFD 3.8-P43), but stated that this change is consistent with TSTF-202. TSTF-202 is pending NRC approval. The purpose of the change was to incorporate the guidance ofIEEE-450 (1995) for maintenance and testing oflead-acid batteries. The recommendations of the standard provide guidance for the optimization oflife and performance of the batteries in use for emergency applications at nuclear power plants. IEEE-450 indicates that the subject surveillance should be performed "at least monthly." Typically, the battery cell parameters of electrolyte level, float voltage, and specific gravity (or charging current) change slowly and a monthly Frequency provides an adequate assurance of safety. Additionally, battery terminal voltage is typically monitored and the monthly inspections are supplemented with an abnormal condition alarm. Therefore, monthly Surveillance are sufficient to assure the appropriate operation of this equipment. Comed continues to pursue this change.
NRC RAI Number NRC lssued Date RAI Status 3.8.9-01 4/29/98 Open - NRC Action Required NRC Description of Issue p
t 3 3.8.9-1 JFD C4 How was the editorial comment provided to the NRC7 Comed Response to Issue This and other minor editorial comments throughout the STS were discussed and approved by the NRC during various meetings with Excel Ser ices Corp., NEI, and the NRC. The subject editorial change revised STS 3.8.9 Condition B and Required Action B.1 to change "AC vital bus" to "AC vital bus electrical power distribution subsystem." The insertion of the phrase, " electrical power distribution subsystem" makes the Conditions consistent with the LCO. In discussions with the NRC, it appears that this was an editorial omission.
1 NRC RAI Number NRC Issued Date RAI Ftatus 3.8.9-02 4/29/98 Open - NRC Action Required NRC Description of Issue 3.8.9-2 DOC L18 On a generic basis the change proposed here was rejected when the staff considered TSTF 16. If arguing for it on a plant specific basis it is beyond the conversion scope.
Comed Response to issue Comed will revise our submittal to conform with the requirements of CTS and the NUREG. This change will be provided in our comprehensive ITS Section 3.8 closcout submittal revision upon NRC's concurrence with the Comed Responses to q) the ITS Section 3.8 RAl.
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