Text

Supplement to Information Supporting Request for License Amendment Regarding Ultimate Heat Sink
	ML111240290
Person / Time
Site:	Byron
Issue date:	05/04/2011
From:	Hansen J; Exelon Corp, Exelon Generation Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RS-11-070
	Download: ML111240290 (36)
	v • d • e

www exeloncorp corn Exelon Generation 4300 Winfield Road Warrenville, IL 60555 Exelon o Nuclear RS-1 1-070 10 CFR 50.90 May 4, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Byron Statbn, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50 -454 and STN 50-455

Subject:

Supplement to Information Supporting Request for License Amendment Regarding Ultimate Heat Sink

References:

1.

Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Regarding Ultimate Heat Sink,"

dated June 30, 2009 2.

Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additional Information Supporting Request for License Amendment Regarding Ultimate Heat Sink." dated January 25, 2010 3.

Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additional Information Supporting Request for License Amendment Regarding Ultimate Heat Sink," dated July 1, 2010 4.

Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additional Information Supporting Request for License Amendment Regarding Ultimate Heat Sink," dated November 8, 2010 5.

Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Regarding Ultimate Heat Sink," dated January 31. 2011 6.

Letter from J L Hansen (Exelon Generation Company LLC) to U S Nuclear Exelon Generation 4300 Winfield Road Warrenville.IL 60555 RS-11-070 May 4,2011 wwwexeloncorp.com Nuclear 10 CFR 50.90 U. S. Nuclear Regulatory Commission A TIN: Document Contro I Desk Washington, DC 20555-001 Byron StaflOn, Units 1 and 2 Facility Operating License Nos. NPF -37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Supplement to Information Supporting Request for License Amendment Regarding Ultimate Heat Sink References :

1. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Regarding Ultimate Heat Sink,"

dated June 30, 2009

2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additional Information Supporting Request for License Amendment Regarding Ultimate Heat Sink," dated January 25, 2010

3. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, IIAdditionallnformation Supporting Request for License Amendment Regarding Ultimate Heat Sink," dated July 1, 2010

4. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additionallnformation Supporting Request for License Amendment Regarding Ultimate Heat Sink,** dated November 8, 2010

5. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Regarding Ultimate Heat Sink,*j dated January 31, 2011

6. Letter from J. L. Hansen (Exelon Generation Company, LLC) to u. S. Nuclear Regulatory Commission, I*Additionallnformation Supporting Request for License Amendment Regarding Ultimate Heat Sink,** dated March 16, 2011

7. Letter from N. DiFrancesco (U. S. Nuclear Regulatory Commission) to Exelon Generation Company, LLC, "Summary of March 1, 2011, Meeting wlh Exelon Generation Company, LLC, to Discuss the Request for Additional I nformation Related to License Amendment Regarding the Ultimate Heat Sink (f AC Nos.

ME1669 and ME1670),** dated March 10,2011 Exelon Generation 4300 Winfield Road Warrenville.IL 60555 RS-11-070 May 4,2011 wwwexeloncorp.com Nuclear 10 CFR 50.90 U. S. Nuclear Regulatory Commission A TIN: Document Contro I Desk Washington, DC 20555-001 Byron StaflOn, Units 1 and 2 Facility Operating License Nos. NPF -37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Supplement to Information Supporting Request for License Amendment Regarding Ultimate Heat Sink References :

1. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Regarding Ultimate Heat Sink,"

dated June 30, 2009

2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additional Information Supporting Request for License Amendment Regarding Ultimate Heat Sink," dated January 25, 2010

3. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, IIAdditionallnformation Supporting Request for License Amendment Regarding Ultimate Heat Sink," dated July 1, 2010

4. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additionallnformation Supporting Request for License Amendment Regarding Ultimate Heat Sink,** dated November 8, 2010

5. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Regarding Ultimate Heat Sink,*j dated January 31, 2011

6. Letter from J. L. Hansen (Exelon Generation Company, LLC) to u. S. Nuclear Regulatory Commission, I*Additionallnformation Supporting Request for License Amendment Regarding Ultimate Heat Sink,** dated March 16, 2011

7. Letter from N. DiFrancesco (U. S. Nuclear Regulatory Commission) to Exelon Generation Company, LLC, "Summary of March 1, 2011, Meeting wlh Exelon Generation Company, LLC, to Discuss the Request for Additional I nformation Related to License Amendment Regarding the Ultimate Heat Sink (f AC Nos.

ME1669 and ME1670),** dated March 10,2011

May 4, 2011 U. S. Nuclear Regulatory Commission Page 2 In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment for Byron Station, Units 1 and 2, to revise Technical Specifications (TS) to add additional essential service water (SX) cooling tower fan requirements as a function of SX pump discharge temperature to reflect results of a revised analysis for the ultimate heat sink (UHS).

EGC supplemented Reference 1 by letters dated January 25, July 1, and November 8 of 2010; January 31 and March 16 of 2011 (References 2, 3, 4, 5 and 6).

As documented in Reference 7, EGC met with the U. S. Nuclear Regulatory Commission (NRC) on March 1, 2011, via teleconference to discuss the development of Byron TS 3.7.9, "Ultimate Head Sink (UHS)." Additional teleconferences were held on April 14, 15, and 19, 2011. EGC is providing this supplement to address feedback and clarifying questions provided during the various teleconferences.

The proposed TS changes provided in Attachment 2 supersede the changes previously provided to the NRC in References 1, 4, and 6. The proposed TS Bases changes provided in, which supersede the changes previously provided to the NRC in References 1 and 6, are provided for information only and do not require NRC approval.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50. 91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachments are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please contact Ms. Lisa A. Schofield at (630) 657-2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of May 2011 Respectfully May 4,2011 U. S. Nuclear Regulatory Commission Page 2 In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment for Byron Station, Units 1 and 2, to revise Technical Specifications (TS) to add additional essentlal service water (SX) cooling tower fan requirements as a function of SX pump discharge temperature to reflect results of a revised analysis for the ultimate heat sink (UHS).

EGC supplemented Reference 1 by letters dated January 25, July 1, and November 8 of 2010; January 31 and March 16 of 2011 (References 2,3,4,5 and 6).

As documented in Reference 7, EGC met with the U. S. Nuclear Regulatory Commission (NRC) on March 1,2011, via teleconference to discuss the development of Byron TS 3.7.9, "Ultimate Head Sink (UHS)." Additional teleconferences were held on April 14, 15, and 19,2011. EGC is providing this supplement to address feedback and clarifying questions provided during the various teleconferences.

The proposed TS changes provided in Attachment 2 supersede the changes previously provided to the NRC in References 1, 4, and 6. The proposed TS Bases changes provided in, which supersede the changes previously provided to the NRC in References 1 and 6, are provided for information only and do not require NRC approval.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachments are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please contact Ms. Lisa A. Schofield at (630) 657*2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of May 2011.

Respectfully, Je rey. Hansen Manager - Licensing Exelon Generation Company, LLC May 4,2011 U. S. Nuclear Regulatory Commission Page 2 In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment for Byron Station, Units 1 and 2, to revise Technical Specifications (TS) to add additional essentlal service water (SX) cooling tower fan requirements as a function of SX pump discharge temperature to reflect results of a revised analysis for the ultimate heat sink (UHS).

EGC supplemented Reference 1 by letters dated January 25, July 1, and November 8 of 2010; January 31 and March 16 of 2011 (References 2,3,4,5 and 6).

As documented in Reference 7, EGC met with the U. S. Nuclear Regulatory Commission (NRC) on March 1,2011, via teleconference to discuss the development of Byron TS 3.7.9, "Ultimate Head Sink (UHS)." Additional teleconferences were held on April 14, 15, and 19,2011. EGC is providing this supplement to address feedback and clarifying questions provided during the various teleconferences.

The proposed TS changes provided in Attachment 2 supersede the changes previously provided to the NRC in References 1, 4, and 6. The proposed TS Bases changes provided in, which supersede the changes previously provided to the NRC in References 1 and 6, are provided for information only and do not require NRC approval.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachments are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please contact Ms. Lisa A. Schofield at (630) 657*2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of May 2011.

Respectfully, Je rey. Hansen Manager - Licensing Exelon Generation Company, LLC

May 4, 2011 U. S. Nuclear Regulatory Commission Page 3 Attachments:

1. Additional Information to Support Request for License Amendment Regarding Ultimate Heat Sink

2. Markup of Technical Specifications Pages for Byron Station, Units 1 and 2

3. Markup of Technical Specifications Bases Pages for Byron Station, Units 1 and 2 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Byron Station NRR Project Manager, Byron Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Additional Information to Support Request for License Amendment Regarding Ultimate Heat Sink Page 1 of 2 By letter to the U. S. Nuclear Regulatory Commission (NRC) dated June 30, 2009, Exelon Generation Company, LLC, (EGC) requested a license amendment for Byron Station, Units 1 and 2, to revise Technical Specifications (TS) to add additional essential service water (SX) cooling tower fan requirements as a function of SX pump discharge temperature to reflect results of a revised analysis for the ultimate heat sink (UHS). EGC supplemented this request by letters dated January 25, July 1, and November 8 of 2010; January 31 and March 16 of 2011.

EGC met with the U. S. Nuclear Regulatory Commission (NRC) on March 1, 2011, via teleconference to discuss the development of Byron TS 3.7.9, "Ultimate Head Sink (UHS).

Additional teleconferences were held on April 14, 15, and 19, 2011. EGC is providing this supplement to address feedback and clarifying questions provided during the various teleconferences.

Development of Byron TS 3.7.9, "Ultimate Head Sink (UHS)," and Revision to Corresponding Bases The revised markup of TS 3.7.9 is provided in Attachment 2.

The proposed TS changes provided in Attachment 2 supersede the changes previously provided to the NRC in letters dated June 30, 2009; November 8, 2010; and March 16, 2011.

The revised markup of TS Bases 3.7.9 is provided in Attachment 3.

The proposed TS Bases changes, which are provided for information only and do not require NRC approval, will be made in accordance with the Byron TS Bases Control Program.

Frequency of Verification of SXCT Fan Requirements in SR 3.7.9.2 License Amendment 171 revised the TS for Byron in order to adopt NRC-approved TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b,"

(Reference 1) as approved by the NRC in a letter dated February 24, 2011 (Reference 2).

When implemented, TSTF-425 relocates most periodic frequencies of TS surveillances to a licensee controlled-program, the Surveillance Frequency Control Program (SFCP), and provides requirements for the new program in the Administrative Controls section of TS.

The frequency for Surveillance Requirement (SR) 3.7.9.2 is revised from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to "In accordance with the Surveillance Frequency Control Program." The Frequency may be based on factors such as operating experience, equipment reliability, or plant risk, and is controlled under the Surveillance Frequency Control Program. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is planned as the initial Surveillance Frequency of SR 3.7.9.2 in the Surveillance Frequency Control Program.

Similarly, the frequencies for SR 3.7.9.1, SR 3.7.9.3, SR 3.7.9.4, SR 3.7.9.5, SR 3.7.9.6, SR 3.7.9.7, and SR 3.7.9.8 are also revised to "In accordance with the Surveillance Frequency Control Program," in accordance with Amendment 171 approved by the NRC February 24, 2011.

ATTACHMENT 1 Additional Information to Support Request for License Amendment Regarding Ultimate Heat Sink Page 2 of 2 Verification of Outside Air Wet Bulb Temperature in SR 3.7.9.10 To address feedback and clarifying questions provided during the teleconference held on April 14, 15, and 19, 2011, SR 3.7.9.10, which was originally proposed in EGC letter dated June 30, 2009, has been restored to Byron TS 3.7.9.

SR 3.7.9.10 verifies the outside air wet bulb temperature is 76°F. The SR is modified by a Note indicating that the SR is only required to be performed when any electrical division is not capable of providing power to at least one OPERABLE SXCT fan. If there are two inoperable cooling tower fans, both of which are powered by the same electrical division, and the outside air wet bulb temperature exceeds 76°F, then a single failure could make all cooling tower cells inoperable on one tower. In this potential configuration, the outside air wet bulb temperature restriction of 76°F prevents exceeding the design SX system temperature of 100°F.

Procedural guidance is planned for Operations on how to accelerate monitoring of wet bulb temperature when current and forecasted seasonal conditions may challenge the wet bulb temperature limit.

References

1)

TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b," March 18, 2009 (ADAMS Accession No. ML090850642).

2)

Letter from N. J. DiFrancesco (U. S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), "Byron Station, Unit Nos. 1 and 2 - Issuance of Amendments Regarding Technical Specification Change for the Relocation of Specific Surveillance Frequency Requirements Based on TSTF-425 (TAC Nos. ME3368 and ME3369)," dated February 24, 2011 (ADAMS Accession No. ML110060811).

ATTACHMENT 2 Markup of Technical Specifications Pages for Byron Station, Units 1 and 2 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATIONS PAGES 3.7.9-1 3.7.9-2 3.7.9-3 3.7.9-4 3.7.9-5 3.7.9-6 INSERTS

UHS 3.7.9 BYRON UNITS 1 & 2 3.7.9 1 Amendment 106 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required cooling tower fan inoperable.

A.1 Verify remaining required OPERABLE cooling tower fans are capable of being powered by an OPERABLE emergency power source.

AND A.2 Restore required cooling tower fan to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours B. One or more basin level(s) < 60%.

B.1 Restore both basin levels to 60%.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (continued)

Replace with INSERT A E

E.1 OPERABLE and the required SX cooling tower (SXCT) fans shall be OPERABLE and operating as specified in Table 3.7.9-1 or Table 3.7.9-2.

UHS 3.7.9 BYRON UNITS 1 & 2 3.7.9 2 Amendment 141 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One Essential Service Water (SX) makeup pump inoperable.

C.1 Verify basin level for each tower is 90%.

AND C.2 Verify OPERABILITY of associated makeup source.

AND C.3 Restore SX makeup pump to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 7 days if both units are in MODE 1, 2, 3, or 4

AND 14 days if one unit is in MODE 5, 6 or defueled (continued)

F F.1 F.2 F.3 Once per

UHS 3.7.9 BYRON UNITS 1 & 2 3.7.9 3 Amendment 141 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two SX makeup pumps inoperable.

D.1 Verify basin level for each tower is 90%.

AND D.2 Verify OPERABILITY of at least one makeup source.

AND D.3 Verify OPERABILITY of second makeup source.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours E. Rock River water level 670.6 ft Mean Sea Level (MSL).

E.1 Verify Rock River water level is

> 664.7 ft MSL and flow 700 cubic feet per second (cfs).

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter (continued)

G.1 G.2 G.3 G

H H.1 Once per Once per

UHS 3.7.9 BYRON UNITS 1 & 2 3.7.9 4 Amendment 141 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action E not met.

OR Rock River water level forecast to exceed 702.0 ft MSL by the National Weather Service (NWS).

OR Tornado Watch issued by the NWS that includes the Byron site.

F.1 Verify basin level for each tower is 90%.

AND F.2 Verify OPERABILITY of at least one deep well pump.

AND F.3 Verify OPERABILITY of both deep well pumps.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours G. Required Action and associated Completion Time of Condition A, B, C, D, or F not met.

OR UHS inoperable for reasons other than Condition A, B, C, D, E, or F.

G.1 Be in MODE 3.

AND G.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours I

I.1 I.2 I.3 of Condition H A, B, C, D, E, F, G, H, or I.

J J.1 J.2 Once per A, B, C, E, F, G, or I

UHS 3.7.9 BYRON UNITS 1 & 2 3.7.9 5 Amendment 106 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level in each cooling tower basin is 60%.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.7.9.2 Verify essential service water pump discharge water temperature is:

a.

80°F;

b.

90°F, with all required cooling tower fans running on high speed; or

c.

96°F, with 7 cooling tower fans running on high speed.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.7.9.3 Verify river water level is > 670.6 ft MSL and 702.0 ft MSL.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.7.9.4 Operate each required cooling tower fan on high speed for 15 minutes.

31 days SR 3.7.9.5 Verify each SX makeup manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in the open position, is in the correct position.

31 days SR 3.7.9.6 Verify that each SX makeup pump starts on a simulated or actual low basin level signal and operates for 30 minutes.

31 days (continued)

Verify SXCT fan requirements in Table 3.7.9-1 or Table 3.7.9-2 are met.

In accordance with the Surveillance Frequency Control Program SXCT SXCT

UHS 3.7.9 BYRON UNITS 1 & 2 3.7.9 6 Amendment 106 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.9.7 Verify each diesel driven SX makeup pump fuel oil day tank level 47%.

31 days SR 3.7.9.8 Cycle each testable valve in the SX makeup pump flow path through at least one complete cycle of full travel.

18 months SR 3.7.9.9 Verify fuel oil properties are tested in accordance with and maintained within the limits of the Diesel Fuel Oil Testing Program.

In accordance with the Diesel Fuel Oil Testing Program In accordance with the Surveillance Frequency Control Program INSERT B (SR 3.7.9.10)

Add INSERT C (Table 3.7.9-1) as a new page

ATTACHMENT 2 Markup of Technical Specifications Pages for Byron Station, Units 1 and 2 Page 1 of 4 INSERT A A. One or more OPERABLE SXCT fan(s) not running in required high speed as required by Table 3.7.9-1 or Table 3.7.9-2.

A.1 Initiate actions to operate OPERABLE SXCT fan(s) in high speed.

Immediately B. One required SXCT fan inoperable.

B.1 Verify OPERABLE SXCT fans are capable of being powered by an OPERABLE emergency power source.

AND B.2 Restore required SXCT fan to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours C. Outside air wet bulb temperature > 76F.

AND Any electrical division not capable of providing power to at least one OPERABLE SXCT fan.

C.1 Verify OPERABLE SXCT fans are capable of being powered by an OPERABLE emergency power source.

AND C.2 Restore SXCT fan configuration such that each electrical division is capable of providing power to at least one OPERABLE SXCT fan.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours D. SX pump discharge water temperature

> 96F.

D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours

ATTACHMENT 2 Markup of Technical Specifications Pages for Byron Station, Units 1 and 2 Page 2 of 4 INSERT B SR 3.7.9.10

NOTE------------------

Only required to be performed when any electrical division is not capable of providing power to at least one OPERABLE SXCT fan.

Verify outside air wet bulb temperature is 76F.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

ATTACHMENT 2 Markup of Technical Specifications Pages for Byron Station, Units 1 and 2 Page 3 of 4 INSERT C Table 3.7.9-1 (page 1 of 1)

SXCT Fan Requirements with SX Trains on Both Units Crosstied

NOTE--------------------------------------------

When outside air wet bulb temperature is > 76F, then each electrical division must be capable of providing power to at least one OPERABLE SXCT fan.

SX PUMP DISCHARGE WATER TEMPERATURE REGION REQUIREMENTS

< 77F 6 SXCT fans are required to be OPERABLE

> 77°F and < 82°F Either 6 required OPERABLE SXCT fans running in high speed, or 7 SXCT fans are required to be OPERABLE

> 82°F and < 84°F 6 required OPERABLE SXCT fans running in high speed

> 84°F and < 91°F 7 required OPERABLE SXCT fans running in high speed

> 91°F and < 96°F 8 required OPERABLE SXCT fans running in high speed Add INSERT D (Table 3.7.9-2) as a new page

ATTACHMENT 2 Markup of Technical Specifications Pages for Byron Station, Units 1 and 2 Page 4 of 4 INSERT D Table 3.7.9-2 (page 1 of 1)

SXCT Fan Requirements with SX Trains on Either Unit Split SX PUMP DISCHARGE WATER TEMPERATURE REGION REQUIREMENTS

< 82F 8 SXCT fans are required to be OPERABLE

> 82°F and < 96°F 8 required OPERABLE SXCT fans running in high speed

ATTACHMENT 3 Markup of Technical Specifications Bases Pages for Byron Station, Units 1 and 2 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATIONS BASES PAGES (NOTE: TS Bases pages are provided for information only.)

B 3.7.9-1 B 3.7.9-2 B 3.7.9-3 B 3.7.9-4 B 3.7.9-5 B 3.7.9-6 B 3.7.9-7 B 3.7.9-8 B 3.7.9-9 B 3.7.9-10 B 3.7.9-11 B 3.7.9-12 B 3.7.9-13 B 3.7.9-14 B 3.7.9-15 B 3.7.9-16 INSERTS

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 1 Revision 0 B 3.7 PLANT SYSTEMS B 3.7.9 Ultimate Heat Sink (UHS)

BASES BACKGROUND The UHS provides a heat sink for processing and operating heat from safety related components during a transient or accident, as well as during normal operation. This is done by utilizing the Essential Service Water (SX) System and the Component Cooling Water (CC) System.

In addition, the UHS is the safety related source of Auxiliary Feedwater (AF) in case the Condensate Storage Tank is unavailable.

The UHS is a common system and consists of two, four cell, mechanical draft cooling towers (0A and 0B) and a makeup system. Each tower has four fans (with two speeds - high and low), which are manually actuated. Two of the Tower 0A fans are powered from Unit 1, Division 11 and two fans are powered from Unit 2, Division 21. Similarly two Tower 0B fans are powered from Unit 1, Division 12 and two fans are powered from Unit 2, Division 22.

The normal makeup to the towers is provided by the non-safety related, non-engineered safety feature, Circulating Water System. Two safety related diesel-driven makeup pumps, which take suction from the Rock River, provide makeup to each of the towers (one pump per tower).

Level switches are provided to automatically start the pump on low level in the associated tower basin. In addition, a deep well pump, powered from the engineered safety feature bus associated with each tower is capable of providing makeup to either basin. The deep well pumps do not include automatic start capability. The two tower basins communicate at approximately the 64% basin level.

Each makeup source is capable of supplying sufficient makeup water to maintain adequate basin inventory. Makeup is required to compensate for AF supply, as well as drift, evaporation and blowdown losses, resulting from design basis Loss Of Coolant Accident (LOCA) conditions in one unit concurrent with the safe shutdown of the other unit.

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 2 Revision 0 BASES BACKGROUND (continued)

Additional information on the design and operation of the system, along with a list of components served, can be found in UFSAR, Section 9.2.5 (Ref. 1).

APPLICABLE The UHS is the sink for heat removed from the reactor core SAFETY ANALYSES following all accidents and anticipated operational occurrences in which the unit is cooled down and placed on Residual Heat Removal (RHR) operation as well as the sink for heat removed from containment via the reactor containment fan coolers. The UHS performance requirements are that the design basis temperatures of safety related equipment served by SX, either directly or indirectly are not exceeded. The UHS maximum post accident heat load occurs near the time the unit switches from injection to recirculation and the containment cooling systems and residual heat removal systems are required to remove core decay heat. The status of both units must be considered in the UHS analyses, because the UHS is a common system. The design basis accident analyses for the UHS is based on design basis LOCA/loss of offsite power conditions on one unit concurrent with the safe shutdown from maximum power of the other unit. References 2, 3, and 6 provide details of the UHS design basis analyses. The analyses include worst expected meteorological conditions, conservative uncertainties when calculating decay heat, and worst case single active failures.

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 3 Revision 0 BASES APPLICABLE SAFETY ANALYSES (continued)

The design basis analyses assume two cooling tower cells (i.e., two fans or water distribution to two tower cells) are out of service. In addition, the analyses assume that at least six fans are running on high speed if the average temperature as measured at the SX pump discharge is 80°F; that with the fans running the SX pump discharge temperature is 96°F; and must not exceed 90°F with 6 OPERABLE fans running on high speed. The UHS maximum design temperature is 100°F. The UHS design basis analyses assume an initial temperature of < 96°F with at least 6 fans running or < 80°F with no fans running. For the 96°F cases, heat transfer is credited immediately following the event because the fans will auto-reenergize with the respective diesel generator output breaker auto-closure. The calculated peak basin temperature is < 100°F. For the 80°F cases heat transfer is not credited until operator action opens riser valves and starts the fans. These calculations also show that the 100°F design temperature is not exceeded.

The analyses assume an initial basin level of 60% in both cooling tower basins, which corresponds to approximately 306,000 gallons in each basin. The analyses consider the AF System requirements, whose safety related source of water is the SX System.

The UHS is designed in accordance with Regulatory Guide 1.27 (Ref. 4), which requires a 30 day supply of cooling water in the UHS. The UHS requires makeup to the basins to meet this requirement. The safety related source of makeup is the two diesel driven SX makeup pumps which take suction from the Rock River. The diesel driven SX makeup pumps auto start on low level in their associated tower basin. The SX makeup system is designed to withstand all design basis natural phenomena events and combination of events except for seismic events during low Rock River flow or level (loss of SX makeup pump suction), tornado, and river flood.

Therefore, constraints on river level and flow are imposed, and if the weather is conducive to tornadoes or high river levels, plant procedures dictate proactive actions.

Replace with INSERT E

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 4 Revision 0 BASES APPLICABLE SAFETY ANALYSES (continued)

A backup makeup source is provided by deep well pumps. The deep well system is designed for seismic, tornado, and river flood events. Each deep well pump is powered from the engineered safety feature bus for the associated tower. The deep well pumps do not include automatic start capability.

To compensate for the possible time delay in providing makeup associated with a manual start of the deep well pumps, the minimum acceptable volume of water maintained in each basin is raised (90% level) and the level is verified every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The UHS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The UHS is required to be OPERABLE and is considered OPERABLE if it has available a sufficient volume of water at or below the maximum temperature that would allow the SX System to operate for at least 30 days following the design basis event without the loss of Net Positive Suction Head (NPSH), and without exceeding the maximum design temperature of the equipment served by the SX System.

To meet this condition the UHS temperature as measured at the discharge of the SX pump: 1) must not exceed 96°F, with

> 6 OPERABLE fans running in high speed; 2) must not exceed 90°F with 6 OPERABLE fans running on high speed; or 3) must not exceed 80°F otherwise. Therefore, at least 6 fans (high speed) and associated tower cells must be OPERABLE. In addition, each basin level must be 60%. The fan operation, basin level and SX pump discharge temperature constraints assure that adequate thermal capacity is available in the SX water inventory to absorb the initial heat input from the design basis event.

Two diesel powered SX makeup pumps must also be OPERABLE.

SX makeup pump OPERABILITY includes, auto start capability on low basin level, and sufficient river level (> 664.7 ft Mean Sea Level (MSL)) and flow combinations.

Replace with INSERT F

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 5 Revision 0 BASES APPLICABILITY In MODES 1, 2, 3, and 4, the UHS is required to support the OPERABILITY of the equipment serviced by the UHS and required to be OPERABLE in these MODES.

In MODE 5 or 6, the OPERABILITY requirements of the UHS are determined by the systems it supports.

ACTIONS A.1 and A.2 If one required fan is inoperable (i.e., only 5 fans OPERABLE), action must be taken to restore the inoperable cooling tower fan to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Required Action A.1 requires the remaining required OPERABLE cooling tower fans be capable of being powered by an OPERABLE emergency power source. This action assures availability of electric power to the remaining required fans in the unlikely event of a loss of offsite power. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is reasonable based on the fact this is an administrative check of the OPERABILITY of the emergency power sources.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the low probability of an accident occurring during the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months that one cooling tower fan is inoperable, the number of available systems, and the time required to reasonably complete the Required Action.

INSERT G B.1 and B.2 B.1 INSERT H SXCT SXCT required SXCT

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 6 Revision 0 BASES ACTIONS (continued)

B.1 If one or more cooling tower basin level is < 60%, the assumptions of the design basis analyses are not met, and action must be taken to restore both basin levels within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time is reasonable based on the low probability of an accident occurring during the 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months that the basin level is < 60%, the number of systems available to replenish basin level, and the time required to reasonably complete the Required Actions.

C.1, C.2, and C.3 When one SX makeup pump is inoperable, action must be taken to verify a 90% cooling tower basin level in both basins within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and verify OPERABILITY of an associated makeup source within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The increased basin level must be verified every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter, and the inoperable SX makeup pump must be restored to OPERABLE status within 7 days or 14 days depending on plant conditions.

In this Condition, the remaining OPERABLE makeup sources are adequate to perform the UHS makeup function. However, the overall reliability is reduced because failure of the OPERABLE makeup source(s) could result in a loss of the makeup function.

F.1, F.2, and F.3 E.1

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 7 Revision 0 BASES ACTIONS (continued)

Required Action C.1 requires verification that both basin levels are 90%, and Required Action C.2 verifies the OPERABILITY of an associated makeup source (pump and flow path). The increased basin level and its verification every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provide assurance of enough inventory in the basins to allow sufficient time to manually start makeup sources, consistent with the assumptions of the design basis analyses. An associated makeup source is a source (i.e.,

ESF powered deep well pump of the same train or the SX makeup pump capable of manual start) which provides makeup to the same basin served by the inoperable SX makeup pump.

An SX makeup pump that is inoperable due solely to the inability to auto start on low basin level may be considered an OPERABLE associated makeup source. OPERABILITY of the same train deep well pump includes capability to start and provide sufficient flow to the associated basin.

The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to verify 90% basin level and OPERABILITY of an associated makeup source is reasonable based on the low probability of a design basis accident occurring during this time period and the ability of the remaining SX makeup pump to perform the required makeup function. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months periodic verification of 90% basin level is consistent with the assumptions of the design basis analyses.

F.1 F.2

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 8 Revision 48 BASES ACTIONS (continued)

Required Action C.3 requires the SX makeup pump to be restored to OPERABLE status within 7 days or 14 days respectively. The 7 day limit is applicable if both Unit 1 and Unit 2 are in MODE 1, 2, 3, or 4. The 14 day limit is only applicable if either Unit 1 or Unit 2 is in MODE 5, MODE 6, or defueled. This Required Action serves to provide up to 7 days to restore a SX makeup pump when both units are operating, and up to 14 days when one unit is operating and the other is shutdown. The 14 day allowance provides adequate time to perform pump inspection and extended maintenance when one unit is in an outage. Without this allowance, a dual-unit outage would be required to perform maintenance that requires more than 7 days to complete. The extended Completion Time when one unit is in shutdown is also based on the reduction in the quantity of heat that would have to be removed by the UHS when one unit is in a shutdown condition, a reduction in the amount of water that may be required to satisfy AF demands, and the availability of the other makeup water sources. Although the 14 day Completion Time was justified based on the need to perform extended maintenance, its use and application is not restricted to these activities because the effects of SX makeup pump inoperability are unrelated to the cause of the inoperability.

F.3

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 9 Revision 0 BASES ACTIONS (continued)

D.1, D.2, and D.3 When both SX makeup pumps are inoperable, action must be taken to verify a 90% cooling tower basin level in both basins within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify OPERABILITY of at least one makeup source (pump and flow path) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and verify OPERABILITY of a second makeup source serving the other tower basin within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The increased basin level must be verified every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter.

In this Condition, the UHS makeup function may not be met.

Required Actions D.1 and D.2 require verification of the OPERABILITY of at least one makeup source and verification that both basin levels are 90%. The increased basin level and its verification every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allows sufficient time to manually start makeup sources, consistent with the assumptions of the design basis analyses. An SX makeup pump which is inoperable solely due to the inability to auto start on low basin level may be considered an OPERABLE makeup source. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is reasonable based on the low probability of an accident occurring during the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and the time required to reasonably complete the Required Actions.

Required Action D.3 requires verification of the OPERABILITY of a second makeup source within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With the plant only having one OPERABLE makeup source, the UHS makeup function can be performed; however the overall reliability is reduced. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the low probability of an accident occurring during this time period and the available makeup capability.

G.1, G.2, and G.3 G.1 and G.2 G.3

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 10 Revision 48 BASES ACTIONS (continued)

E.1 With the Rock River water level 670.6 ft Mean Sea Level (MSL), action must be taken to assure that adequate level and flow remain available from the Rock River intake to the SX makeup pumps to permit their operation. When the water level in the river falls below this limit, within one hour, and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, the water level in the river must be verified to be greater than 664.7 ft MSL and the flow rate in the river must be verified to be greater than or equal to 700 cubic feet per second (CFS). 700 cfs assures adequate inventory is available for the pumps to maintain the level in the UHS basins. 664.7 ft is the minimum design operating level of the SX makeup pumps.

Assuring adequate inventory and a level greater than the minimum operating level provides assurance that the pumps can perform their function if required. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time for initial performance of this Required Action is reasonable based on the low probability of an accident occurring during the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and the time required to reasonably complete the Required Actions. The continued performance of this verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable based on the availability of other makeup sources and the low likelihood of an accident and a rapid unexpected decrease in the river level.

H.1

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 11 Revision 0 BASES ACTIONS (continued)

F.1, F.2, and F.3 The SX makeup pumps provide the safety-related makeup capability to the UHS, however when Condition F applies, the pumps may not be capable of performing the required function. With water level or flow in the Rock River outside of the limits specified, the pumps may not have adequate NPSH or inventory to supply the required makeup to the UHS if an accident occurs. If water level is forecast to exceed 702 ft MSL on the Rock River, the SX makeup pumps may be subjected to flooding that would render them inoperable. Similarly, if a Tornado Watch exists that includes the Byron site, the pumps may not be capable of performing their required function because the river screen house that contains the pumps is not designed to protect them from a tornado.

In these conditions, alternative makeup capability to the UHS must be available and the inventory in the UHS basin must be large enough to permit manual initiation of the alternative source. The deep well pumps supply the alternative makeup capability to the UHS. To assure adequate inventory in the UHS to permit a delay in makeup for manual initiation of the deep well pumps, the level in each tower basin must be verified to be greater than or equal to 90% within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time for initial performance of this Required Action is reasonable based on the low probability of an accident occurring during the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and the time required to reasonably complete the Required Actions. The continued performance of this verification every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable based on the low likelihood of an accident and the maximum expected decrease in level in the UHS basin.

In addition, at least one deep well pump must be verified OPERABLE within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This assures that if an accident occurs, adequate makeup capability to the UHS is available.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time for initial performance of this Required Action is reasonable based on the low probability of an accident occurring during the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and the time required to reasonably complete the Required Actions.

I.1, I.2, and I.3 I

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 12 Revision 0 BASES ACTIONS (continued)

Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , both deep well pumps must be verified to be OPERABLE if Condition F continues to apply. This Required Action is consistent with the need to assure reliable and redundant supplies are available to provide makeup to the UHS. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the low probability of an accident occurring during the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months coincident with a failure of the OPERABLE deep well pump.

G.1 and G.2 If the UHS cannot be restored to OPERABLE status within the associated Completion Times or the associated Required Actions are not met of Condition A, B, C, D, or F, or if the UHS is inoperable for reasons other than Condition A, B, C, D, E, or F, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.7.9.1 REQUIREMENTS This SR verifies adequate basin level to provide time to manually establish makeup while providing auxiliary feedwater if required. The specified level also ensures that sufficient NPSH is available to operate the SX pumps.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. This SR verifies that the UHS cooling tower basin water level is 60%.

A, B, C, E, F, G, or I A, B, C, D, E, F, G, H, or I J.1 and J.2 I

The Frequency may be based on factors such as operating experience, equipment reliability, or plant risk, and is controlled under the Surveillance Frequency Control Program.

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 13 Revision 0 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.9.2 This SR verifies that the UHS is capable of supporting the SX System. In turn, availability of the UHS ensures the ability of the SX System to cool the CC System to at least its maximum design temperature with the maximum accident or normal design heat loads for 30 days following a Design Basis Accident and cool the other components served directly by the SX System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. This SR verifies that the essential service water pump discharge water temperature is 80°F; 90°F if all required cooling tower fans are running on high speed; or 96°F if 7 OPERABLE cooling tower fans are running on high speed.

SR 3.7.9.3 This SR verifies the SX makeup pumps are OPERABLE by ensuring river water level and flow are sufficient for proper operation of the SX makeup pumps in case of the Design Basis Accident (DBA). If the river water level is

> 670.6 ft MSL and 702.0 ft MSL, proper operation is assured. If the water level is > 702.0 ft MSL, the pumps may become flooded and not be available. If the river level is 670.6 ft MSL, proper operation of the pumps during a DBA is possible. However, the river level must be

> 664.7 ft MSL and river flow must be 700 cfs. The frequency of SR 3.7.9.3 is based on the potential for changes in river level on a daily basis.

SR 3.7.9.4 Starting from the control room and operating each required cooling tower fan on high speed for 15 minutes (if not already operating in high speed) ensures that all fans are OPERABLE and that all associated controls are functioning properly. It also ensures that fan or motor failure, or excessive vibration, can be detected for corrective action.

The 31 day Frequency is based on operating experience, the known reliability of the fan units, the redundancy available, and the low probability of significant degradation of the UHS cooling tower fans occurring between surveillances.

The Frequency may be based on factors such as operating experience, equipment reliability, or plant risk, and is controlled under the Surveillance Frequency Control Program.

This SR specifically verifies that the SX pump discharge water temperature, SXCT fan OPERABILITY, and operational mode is in accordance with the LCO. The Frequency may be based on factors such as operating experience, equipment reliability, or plant risk, and is controlled under the Surveillance Frequency Control Program.

SXCT SXCT

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 14 Revision 56 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.9.5 Verifying the correct alignment for manual, power operated, and automatic valves in the SX makeup flow path provides assurance that the proper flow paths exist for SX makeup operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to being locked, sealed, or secured. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.9.6 This SR verifies that each SX makeup pump starts and operates on an actual or simulated low basin level signal for 30 minutes. The 31 day frequency is based on operating experience and the low probability of significant degradation of the SX makeup pump occurring between performances of the surveillance.

SR 3.7.9.7 This SR provides verification that the level of fuel oil in the day tank is at or above the level that provides approximately a 3 day supply of fuel for the pumps. This is enough time to arrange for addition of more fuel if needed.

The level is expressed as a percent of the usable volume of the tank. The 47% indicated level ensures that there is at least 864 gallons of usable fuel to each diesel powered essential service water makeup pump, with an allowance for instrumentation tolerances.

The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators will be aware of any large uses of fuel oil during this period.

The Frequency may be based on factors such as operating experience, equipment reliability, or plant risk, and is controlled under the Surveillance Frequency Control Program.

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 15 Revision 51 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.9.8 This SR requires that each testable valve in the SX makeup system flow path be cycled through at least one complete cycle of travel every 18 months. This SR applies to the flow path from the SX makeup pumps to the UHS basins. The SR provides assurance that if a flow path is required, it can be aligned properly.

The 18 month Frequency is based on the low probability of an undetected failure, and is consistent with testing required by the IST program.

SR 3.7.9.9 The tests of fuel oil are a means of assuring it has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion.

The tests, limits, and applicable ASTM Standards are listed in the Diesel Fuel Oil Testing Program in Specification 5.5.13.

Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

Particulate concentrations should be determined in accordance with ASTM D5452 (Ref. 5). This method involves a determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing.

Fuel Oil to the Essential Service Water Makeup Pump Day Tanks is supplied from the outside fuel oil storage tanks.

These tanks are also subject to the requirements of the Diesel Fuel Oil Testing Program, as described in Specification 5.5.13.

The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

INSERT I (SR 3.7.9.10)

The Frequency may be based on factors such as operating experience, equipment reliability, or plant risk, and is controlled under the Surveillance Frequency Control Program.

UHS B 3.7.9 BYRON UNITS 1 & 2 B 3.7.9 16 Revision 21 BASES REFERENCES

1.

UFSAR, Section 9.2.5.

2.

Commonwealth Edison letter to Dr. Thomas E Murley dated January 9, 1992.

3.

Commonwealth Edison letter to Dr. Thomas E Murley dated March 31, 1992.

4.

Regulatory Guide 1.27.

5.

ASTM Standards, D5452.

6.

Commonwealth Edison letter to USNRC Document Control Desk dated May 6, 1997.

ATTACHMENT 3 Markup of Technical Specifications Bases Pages for Byron Station, Units 1 and 2 Page 1 of 3 INSERT E The UHS maximum basin design temperature is 100°F. To ensure this limit is not exceeded, the SX Cooling Tower (SXCT) fan requirements vary with increasing SX pump discharge water temperature. These requirements involve an increasing number of required SXCT fans to be OPERABLE and whether those fans are required to be running in high speed. The design analysis for determining these requirements was based on the worst-case three-hour outside air wet bulb temperature of 82°F. For example, with SX trains cross tied on both units, if SX pump discharge water temperature is < 77°F, then only six of the eight SXCT fans are required to be OPERABLE and none are required to be running in high speed. If the SX pump discharge water temperature is > 91°F and < 96°F, then all eight SXCT fans are required to be OPERABLE and all are required to be running in high speed. Detailed limits are included in the LCO section.

When SXCT fans are required to be running in high speed, the heat transfer is credited immediately following the event because SXCT fans will automatically reenergize with the respective diesel generator output breaker auto-closure. When fans are not required to be running in high speed heat transfer is not credited until operator action opens riser valves and starts the SXCT fans.

The SX pump discharge water temperature limits are based on a design assumption that in the event of a LOCA, under the most severe design basis weather conditions, and a single breaker failure results in the loss of two SXCT fans, the Operators will shed heat load by securing up to two of the four Reactor Containment Fan Coolers (RCFCs) on the LOCA unit within 21.6 minutes. Only one of the two trains of RCFCs is required to operate for post accident containment heat removal. Also, Operators on the non-accident unit will have to monitor and manage the cooldown rate such that SX discharge temperature limits are not exceeded.

The safety analysis evaluated conditions when two SXCT fans are inoperable on the same electrical division. In this scenario, a postulated breaker failure associated with the power to the other two SXCT fans in the same tower could result in a configuration with no SXCT fans available on one tower and four OPERABLE SXCT fans on the second tower. In this configuration, the overall SXCT performance is less than when SXCT fans are available on both towers. To support design basis accident heat removal in this configuration the outside air wet bulb temperature must be 76ºF.

ATTACHMENT 3 Markup of Technical Specifications Bases Pages for Byron Station, Units 1 and 2 Page 2 of 3 INSERT F To meet the SX supply design temperature under postulated accident conditions a minimum number of SXCT fans are required to be OPERABLE to remove the postulated accident heat load. The number of SXCT fans required is dependent on whether SX is operated with SX trains on both units crosstied or SX trains or either unit split. Split train operation is defined as both the supply and the return sides of an SX train are separated from the other SX train.

Crosstied train operations is defined as either or both the supply and the return sides of an SX train are not separated from the other SX train, Table 3.7.9-1 contains the SXCT fan requirements corresponding to the SX pump discharge water temperature regions when SX trains on both units are crosstied, and Table 3.7.9-2 contains the SXCT fan requirements corresponding to the SX pump discharge water temperature regions when SX trains are split on either unit.

A SXCT fan is considered OPERABLE when it has a structurally sound cooling cell, a water distribution system, and the capability of running in high speed for 30 days. The number and configuration of SXCT fan requirements vary with increasing SX pump discharge water temperature.

Table 3.7.9-1 is modified by a Note indicating when outside air wet bulb temperature is > 76ºF, then each electrical division (i.e., Divisions 11, 12, 21 and 22) must be capable of providing power to at least one OPERABLE SXCT fan.

INSERT G A.1 If there is less than the number of SXCT fans running in required high speed as required by Table 3.7.9-1 or Table 3.7.9-2, then actions must be initiated to operate all the required OPERABLE SXCT fans in high speed. This action ensures the 100°F design temperature limit will not be exceeded during a design basis accident. The immediate Completion Time is reasonable since an OPERABLE SXCT fan must be capable of running in high speed and the fan can be placed in this condition from the Main Control Room.

ATTACHMENT 3 Markup of Technical Specifications Bases Pages for Byron Station, Units 1 and 2 Page 3 of 3 INSERT H C.1 and C.2 These Required Actions are applicable when SX is operating in a crosstied configuration on both Units. When outside air wet bulb temperature is > 76ºF and any electrical division is not capable of providing power to at least one SXCT fan, then a postulated worst case single failure could result in no OPERABLE SXCT fans one tower and four SXCT fans on the second tower.

In this potential configuration, design basis SX temperatures could be exceeded. The Required Action is to reconfigure the SXCT fans to eliminate this vulnerability. Required Action C.1 requires the OPERABLE SXCT fans to be capable of being powered by an OPERABLE emergency power source. This action assures availability of electrical power to the SXCT fans in the unlikely event of a loss of offsite power.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the low probability of an accident occurring during the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months timeframe in addition to a single failure disabling two SXCT fans on the same tower that initially had two inoperable fans.

D.1 and D.2 If the SX pump discharge temperature exceeds 96°F, then the UHS SXCT fans cannot prevent the design SX system temperature limit of 100°F from being exceeded during a design basis accident. Consequently, in this condition, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging plant systems.

INSERT I SR 3.7.9.10 This SR verifies the outside air wet bulb temperature is 76°F. The SR is modified by a Note indicating that the SR is only required to be performed when any electrical division is not capable of providing power to at least one OPERABLE SXCT fan. If there are two inoperable SXCT fans, both of which are powered by the same electrical division, and the outside air wet bulb temperature exceeds 76°F, then a single failure could make all SXCT cells inoperable on one tower. In this potential configuration, the outside air wet bulb temperature must be restricted to being 76°F in order to keep from exceeding the design SX system temperature of 100°F. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is reasonable based on the expected outside air wet bulb temperature during the seasonal timeframes this configuration would be intentionally entered for maintenance activities. However, should this configuration occur during seasonal conditions where outside air wet bulb temperature may exceed 76°F, then monitoring intervals should take into account the proximity to the limit and forecasted conditions.

v t e Letter Sequence Supplement
TAC:ME1669, (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request Acceptance... Supplement Administration Meeting Questions 16 December 2010 11 December 2009 18 May 2010 18 August 2010 2 November 2010 28 December 2010 14 February 2011 10 March 2011 Answers 31 January 2011 Results Approval, Approval Other:
MONTHYEAR2010-05-18 [Table View]

RS-11-070, Supplement to Information Supporting Request for License Amendment Regarding Ultimate Heat Sink

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RS-11-070, Supplement to Information Supporting Request for License Amendment Regarding Ultimate Heat Sink

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