Text

License Amendment Request to Revise Technical Specifications 3.7.9, Ultimate Heat Sink(Uhs)
	ML14328A800
Person / Time
Site:	Byron
Issue date:	11/24/2014
From:	Gullott D; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-14-285
	Download: ML14328A800 (19)
	v • d • e

4300 Winfield Road Warrenville. IL 60555 Exelon Generation

630 657 2000 Office RS-14-285

10 CFR 50.90 November 24, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

License Amendment Request to Revise Technical Specifications 3.7.9, "Ultimate Heat Sink (UHS)"

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2.

This proposed amendment would revise Condition I and Surveillance Requirement (SR) 3.7.9.3 associated with Technical Specifications (TS) Section 3.7.9, "Ultimate Heat Sink (UHS)," to reflect the current design basis flood level and ensure the operability of the service water (SX) makeup pumps to meet TS 3.7.9 Limiting Condition for Operation (LCO) requirement. The proposed change will correct a non-conservative TS which may not adequately verify the operability of the deep well pumps prior to the potential for the SX makeup pumps to be rendered inoperable by the high river level. This non-conservative condition is based on EGC's review of industry operating experience of an unanalyzed condition at another station. The review identified a discrepancy between the described Rock River combined event flood (CEF) level in the Updated Final Safety Report (UFSAR) and the Rock River flood level specified in TS 3.7.9, Condition I. In addition, SR 3.7.9.3 is revised to ensure the upper limit of the river water level is consistent with the proposed change to Condition I.

Administrative controls are currently in place to address this TS non-conservatism in accordance with NRC Administrative Letter (AL) 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," to assure that plant safety is maintained at Byron Station. Consistent with the guidance in AL 98-10, EGC is submitting the proposed change as a required license amendment request to resolve a non-conservative TS and is not a voluntary request to change the Byron Station's licensing basis. Therefore, this request is not subject to "forward fit" considerations as discussed in a letter from S. G. Burn (NRC, General Counsel) to E. C Ginsberg (NEI), dated July 14, 2010.

November 24, 2014 U.S. Nuclear Regulatory Commission Page 2 The attached request is subdivided as follows: provides a description and evaluation of the proposed change. provides the marked-up TS pages for Byron Station with the proposed change indicated. provides the marked-up TS Bases pages for Byron Station with the proposed change indicated. The TS Bases pages are provided for information only and do not require NRC approval.

The proposed change has been reviewed by the Byron Station Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), EGC is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State of Illinois official.

EGC requests approval of the proposed license amendment by November 24, 2015. Once approved, the amendment will be implemented within 90 days.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Ms. Dwi Murray at (630) 657-3695.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of November 2014.

Respectfully, David M. Gullott Manager Licensing Exelon Generation Company, LLC Attachments:

1.

Evaluation of Proposed Change

2.

Proposed Technical Specifications Changes for Byron Station, Units 1 and 2

3.

Proposed Technical Specifications Bases Changes for Byron Station, Units 1 and 2 cc:

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

bcc: NRC Project Manager, NRR Byron Station Site Vice President Byron Station Regulatory Assurance Manager Byron Station Director Licensing and Regulatory Affairs Manager Licensing, Byron Station Exelon Document Control Desk Licensing Commitment Tracking Coordinator Midwest G. Contrady (Byron)

C. Cote (Byron)

D. Sargent (Byron)

P. Kusumawati Murray (Cantera)

ATTACHMENT 1 Evaluation of Proposed Change

Subject:

License Amendment Request to Revise Technical Specifications 3.7.9, "Ultimate Heat Sink (UHS)"

1.0

SUMMARY

DESCRIPTION 2.0

DETAILED DESCRIPTION

==3.0

TECHNICAL EVALUATION==

==4.0

REGULATORY EVALUATION==

4.1

Applicable Regulatory Requirements/Criteria 4.2

Precedents 4.3

No Significant Hazards Consideration 4.4

Conclusions

==5.0

ENVIRONMENTAL CONSIDERATION==

6.0 REFERENCES

Page 1 of 10

ATTACHMENT 1 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2.

Exelon Generation Company, LLC, (EGC) proposes to revise Technical Specifications (TS)

Section 3.7.9, "Ultimate Heat Sink (UHS)," to reflect the current design basis flood level and ensure the operability of the service water (SX) makeup pumps to meet TS 3.7.9 Limiting Condition for Operation (LCO) requirement.

The proposed change would revise TS 3.7.9, Condition I and Surveillance Requirement (SR) 3.7.9.3 to correct a non-conservative TS which may not adequately verify the operability of the deep well pumps prior to the potential for the SX makeup pumps to be rendered inoperable by the high river level. This non-conservative TS is based on EGC's review of industry operating experience of an unanalyzed condition where another station's procedures for responding to external flooding conditions did not provide adequate guidance to mitigate a design basis flood event (Reference 1). The review identified a discrepancy between the described Rock River combined event flood (CEF) level in the Updated Final Safety Report (UFSAR) and the Rock River flood level specified in TS 3.7.9, Condition I.

UFSAR Sections 2.4.3.7, "Combined Event Flood on the Rock River," and 3.4.1.1, "Flood Sources," describe that the Byron river screen house (RSH) is designed for the CEF with a flood level of 698.68 feet above mean sea level (MSL). The CEF level was used to evaluate adequacy of the flood protection of the safety related SX makeup pumps which are located within the RSH. The current TS 3.7.9, Condition I utilizes a higher Rock River flood level of 702.0 feet MSL to initiate required actions. In the event of a maximum wave runup is superimposed on the current TS value of 702.0 feet; the required actions may not adequately verify the operability of the deep well pumps prior to the potential for the SX makeup pumps to be rendered inoperable by the high river water level.

In addition, SR 3.7.9.3 is revised to ensure the upper limit of the river water level is consistent with the proposed change to Condition I.

Administrative controls are currently in place to address this TS non-conservatism in accordance with NRC Administrative Letter (AL) 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," to assure that plant safety is maintained at Byron Station. When the Rock River water level is forecasted to exceed the design basis flood level of 698.68 feet MSL by the National Weather Service (NWS), the TS Required Actions of Condition I will be taken. Consistent with the guidance in AL 98-10, EGC is submitting the proposed change as a required license amendment request to resolve a non-conservative TS and is not a voluntary request to change the Byron Station's licensing basis.

Therefore, this request is not subject to "forward fit" considerations as discussed in a letter from S. G. Burn (NRC, General Counsel) to E. C Ginsberg (NEI), dated July 14, 2010.

Page 2 of 10

ATTACHMENT 1 Evaluation of Proposed Change 2.0

DETAILED DESCRIPTION The current TS 3.7.9, Condition I states the following:

I. Required Action of Condition H 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.

The proposed change will revise the second condition in TS 3.7.9, Condition I to state the following:

I. Required Action of Condition H not met.

OR Rock River water level forecast to exceed 698.68 ft MSL by the National Weather Service (NWS).

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

In addition, SR 3.7.9.3 is revised to ensure the upper limit of the river water level is consistent with the proposed change to Condition I. The current SR 3.7.9.3 states: "Verify river water level is > 670.6 ft MSL and 5 702.0 ft MSL." The proposed change will revise SR 3.7.9.3 to state:

"Verify river water level is > 670.6 ft MSL and 5 698.68 ft MSL." provides the marked-up IS pages for Byron Station with the proposed change. provides the marked-up TS Bases pages for Byron Station with the proposed change and is provided for information only.

==3.0

TECHNICAL EVALUATION==

=

Background===

The Ultimate Heat Sink (UHS) provides a heat sink for removing process and operating heat from safety related components during a transient or accident, as well as during normal operation. The UHS is a common system to Byron Station, Units 1 and 2, and consists of two essential service water mechanical draft cooling towers (SXCT) and a makeup system to the Page 3 of 10

ATTACHMENT 1 Evaluation of Proposed Change cooling towers. The normal makeup to the SXCT is provided by the non-safety, non-engineered safety feature, Circulating Water System. Two diesel-driven makeup pumps (SX makeup pumps) take suction from the Rock River to provide the safety related source of makeup to the UHS. The SX makeup pumps auto start on low level in their associated cooling tower basin.

The two diesel-driven SX makeup pumps are located in the river screen house (RSH) at a nominal floor elevation of 702 feet and are enclosed by a 4-foot high wall.

A backup makeup source is provided by two non-safety, seismically qualified, deep well pumps.

The deep wells provide a source of makeup water to the SXCT basins in the event of a flood more severe than the combined event flood (CEF) on the Rock River. Each deep well pump is powered from the essential safety feature (ESF) bus for the associated SXCT.

Since the backup deep wells are located approximately 200 feet above the river at plant grade elevation, they will not be affected by flooding on the Rock River that renders the SX makeup pumps inoperable. The backup deep well pump well heads are located in enclosures at grade elevation of approximately 873 feet for deep well pump No. 1 and 868 feet for deep well pump No. 2. The NRC concluded in Safety Evaluation Report (SER) dated August 7, 1989 (Reference 2) that the deep wells are seismically qualified and can be considered as part of the UHS system in the event of an earthquake.

The current TS 3.7.9, Condition I utilizes a value of 702.0 feet MSL for the Rock River water level. This TS value indicates that the Required Actions to verify adequate initial basin level and OPERABILTY of the deep well pumps would not occur until the Rock River water level was forecasted to exceed 702.0 feet. This current value is non-conservative since it is 3.32 feet above the CEF level of 698.68 feet MSL used in the design of the ASH. The CEF level was used to evaluate the adequacy of flood protection for the safety related SX makeup pumps which are located within the ASH.

Superimposing the maximum wave runup value of 4.71 feet on the current TS value of 702.0 feet would result in the maximum wave's elevation of 706.71 feet, which exceeds the 4-foot high wall enclosing the safety-related equipment at the ASH. This condition could cause flood damage to SX makeup pumps and render them inoperable. Therefore, the current TS 3.7.9, Condition I statement may not verify OPERABILTY of the deep well pumps to provide makeup capability to the UHS system prior to the potential for the SX makeup pumps to be rendered inoperable by the high river water level above CEF level of 698.68 feet.

Corrective actions were implemented at Byron Station to address this TS non-conservatism, which included procedure revisions to perform required actions associated with TS 3.7.9, Condition I when Rock River water level is forecasted to exceed the design basis flood level of 698.68 feet MSL by the NWS. The current procedures accurately reflect the UFSAR and Byron Station SER design basis flood level for Rock River and provide additional margin of protection for the SX makeup pumps from flooding that would render them inoperable.

Page 4 of 10

ATTACHMENT 1 Evaluation of Proposed Change Technical Analysis The water surface elevations of the Rock River near the station corresponding to the probable maximum flood (PMF), combined event flood (CEF), standard project flood (SPF), and flood of record (FOR) considered in the Byron Station design are as follows:

Flood Conditions Elevation (ft.)

Probable Maximum Flood (PMF) 708.3 Combined Event Flood (CEF) 698.7 Standard Project Flood (SPF) 695.6 Flood of Record (FOR) 683.6 UFSAR Sections 2.4.3.7 and 3.4.1.1 describe that the RSH is the only structure that could be affected by flooding on the Rock River and is designed for the CEF. The CEF stage for the Rock River at the RSH is 698.68 feet MSL. The significant and maximum wave effects of a coincident 40-mph overland wind were superimposed on the combined flood water level at the RSH. The wave runups, including setups, were calculated based on a water condition and are 2.77 feet and 4.71 feet for the significant and maximum waves, respectively. Superimposing the runup values on the CEF level at the RSH results in a wave runup elevation of 701.45 feet for significant waves and elevation 703.39 feet for maximum waves.

To prevent damage to the safety related SX makeup pump equipment due to flood and/or maximum wave runup, the floor elevation is established at 702 feet and a 4 foot high concrete wall encloses the area where the SX makeup pump equipment is located. The SX makeup pump diesel engine, pump gear drive, and battery posts are mounted above the floor at approximate elevations of 703.7 feet, 704 feet, and 703.6 feet, respectively. Under flood conditions, the lower engine battery post is the limiting component, which is located at the approximate elevation of 703.6 feet. The enclosure floor contains drain lines that are open to the river and an unsealed 6-inch diameter pipe in a 10-inch diameter floor penetration. These floor openings could allow flood water to enter the enclosure.

The 4 foot high concrete enclosure wall protects the SX makeup pump components from the direct impact of the wave activity. The wave action could also force some flood water into the enclosure up through the drain lines or the annulus between the 6-inch pipe and the 10-inch sleeve in the unsealed floor penetration. The significant wave run up would not impact the SX makeup pump operation since the wave action inside the RSH is mitigated by the exterior walls and the associated wave run up elevation of 701.45 feet is below the floor elevation of 702 feet.

Maximum wave run up may force water through the floor drains and/or pipe penetration and temporarily spread water onto the enclosure floor to a water height less than 703.39 feet.

Therefore, the water would remain below the lower engine battery post elevation of 703.6 feet.

Byron Station SER, NUREG-0876, Section 2.4.3, "Flooding Potential," accepted the use of CEF and earthquake design basis for design of the RSH during the construction-permit (CP) review stage since it is less than the PMF and allows some credit for the onsite wells as a makeup source for the SXCT basins. It was concluded during the CP review stage that the combined occurrence of a more severe flood and an earthquake severe enough to damage the onsite wells need not be considered. The NRC further concluded that the considerations of water-induced loads for the RSH that would result from various combinations of river flows and Page 5 of 10

ATTACHMENT 1 Evaluation of Proposed Change associated wind waves and seismic events, and associated hydrostatic and hydrodynamic forces are within acceptable limits and meet the requirements of GDC 2.

Furthermore, Byron Station SER, NUREG-0876, Section 3.4.1, "Flood Protection," states:

"The essential service water makeup pumps at the river screenhouse, which provide ultimate heat sink (UHS) makeup during long-term reactor cooldown, are mounted at an elevation of 702 ft and enclosed by a 4-ft high concrete fire wall. The PMF level would, therefore, be 2.3 ft over the fire wall and the essential service water makeup pumps would be flooded. As backup to the essential service water makeup pumps, non safety-related wells are provided. The wells and well pumps are above the PMF level, are powered from the essential (Class 1E) power sources, and thus are capable of supplying makeup to the UHS in the event of the loss of the essential service water makeup pumps coincident with a loss of offsite power as a result of the PMF. The staff concludes that the above design is acceptable."

Based on NUREG-0876 sections described above, the RSH and the safety related SX makeup pumps have been designed and licensed to operate for the CEF river level of 698.68 feet. The RSH structure and the SX makeup pumps may be adversely affected by a higher river level since superimposing the maximum wave runup value on the current TS value of 702.0 feet would result in the maximum wave's elevation of 706.71 feet. This elevation exceeds the 4-foot high wall enclosing the safety-related equipment at the RSH structure causing damage to the SX makeup pumps. For postulated floods larger than the CEF, the deep well pumps are designed to provide makeup capability to the UHS.

The proposed change to TS 3.7.9, Condition I, to revise the Rock River water level to 698.68 feet for initiating required actions associated with Condition I provides additional margin of protection for the SX makeup pumps from flooding that would render them inoperable.

Superimposing the maximum wave's runup value on the proposed Rock River water level of 698.68 feet would result in the maximum wave's elevation of 703.39 feet at the RSH, which is below the height of the wall protecting the safety-related SX makeup pump equipment from wave runup. The maximum wave run up may force water through the floor drains and/or pipe penetration and temporarily spread water onto the enclosure floor, however, the water height would remain below the lower engine battery post elevation.

==4.0

REGULATORY EVALUATION==

4.1

Applicable Regulatory Requirements/Criteria The following NRC requirements and guidance documents are applicable to the review of the proposed changes.

10 CFR 50, Appendix A, General Design Criterion (GDC) 2, "Design bases for protection against natural phenomena," requires that the safety related portion of the ultimate heat sink system be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. Furthermore, GDC 2 requires that appropriate consideration of the most severe Page 6 of 10

ATTACHMENT 1 Evaluation of Proposed Change of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data have been accumulated are reflected in the design bases for the system.

10 CFR 50, Appendix A, General Design Criterion (GDC) 44, "Cooling water," requires that an ultimate heat sink be provided to transfer the combined heat load from structures, systems, and components important to safety under normal operating and accident conditions. Furthermore, GDC 44 requires that redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities of the ultimate heat sink system be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available), the system safety function can be accomplished, assuming a single failure.

10 CFR 50.36(c)(2), "Limiting conditions for operation," paragraph (i) defines the limiting conditions for operation as the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. Furthermore, Criterion 3 of 10 CFR 50.36(c)(2)(ii) requires that a TS LCO must be established for a structure, system, or component that is part of the primary success path and functions to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

10 CFR 50.36(c)(3), "Surveillance requirements," requires that TSs include SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The proposed change to TS 3.7.9, Condition I and SR 3.7.9.3 to reflect the current design basis flood level will ensure the operability of the SX makeup pumps and UHS system to meet TS 3.7.9 LCO requirement. The proposed change is consistent with and in compliance with the above regulatory requirements and criteria. Therefore, the proposed change will assure safe operation by continuing to meet applicable regulations and requirements.

4.2

Precedents EGC is not aware of any precedents for license amendment requests to revise TS 3.7.9 for protecting the safety related makeup pumps from postulated floods and verifying the operability of the makeup pumps to provide makeup capability to the UHS system.

4.3

No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit," Exelon Generation Company, LLC, (EGO) requests an amendment to Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2. The proposed change will revise Technical Specifications (TS) Section 3.7.9, "Ultimate Heat Sink (UHS),"

Condition I and associated Surveillance Requirement (SR) 3.7.9.3 to reflect the current design Page 7 of 10

ATTACHMENT 1 Evaluation of Proposed Change basis flood level and ensure the operability of the service water (SX) makeup pumps to meet TS 3.7.9 Limiting Condition for Operation (LCO) requirement.

The proposed change will correct a non-conservative TS which may not adequately verify the operability of the deep well pumps prior to the potential for the SX makeup pumps to be rendered inoperable by the high river level. This conclusion is based on the review of industry operating experience of an unanalyzed condition where another station's procedures for responding to external flooding conditions did not provide adequate guidance to mitigate a design basis flood event. The review identified a discrepancy between the described Rock River combined event flood level in the Updated Final Safety Report (UFSAR) and the Rock River flood level specified in TS 3.7.9, Condition I. In addition, SR 3.7.9.3 is revised to ensure the upper limit of the river water level is consistent with the proposed change to Condition I.

Administrative controls are currently in place to address this TS non-conservatism in accordance with NRC Administrative Letter (AL) 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," to assure that plant safety is maintained at Byron Station. This license amendment request is submitted in accordance with the guidance in AL 98-10.

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92(c),

"Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes to revise TS 3.7.9, Condition I and SR 3.7.9.3 will ensure the operability of the SX makeup pumps to meet TS 3.7.9 LCO requirement. The proposed change does not result in any physical changes to safety related structures, systems, or components. The probability of a flood at the river screen house (RSH) is unchanged.

Since the UHS itself is not an accident initiator, the proposed change does not impact the initiators or assumptions of analyzed accidents, nor do they impact the mitigation of accidents or transient events. Consequently, the proposed change does not increase the probability of occurrence for any accident previously evaluated.

The proposed change will ensure that actions to verify operability of the deep well pumps will be taken prior to the potential for the SX makeup pumps to be adversely affected by the combined event flood high river level. Therefore, the UHS will be capable of performing its functions to mitigate accidents by serving as the heat sink for safety related equipment.

Thus, the proposed change does not increase the consequences of any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 8 of 10

ATTACHMENT 1 Evaluation of Proposed Change

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change to revise TS 3.7.9, Condition I and SR 3.7.9.3 does not change the design function or operation of the SX makeup pumps. The proposed change does not change or introduce the possibility of any new or different type of equipment, modes of system operation, failure mechanisms, malfunctions, or accident initiators. The proposed change to lower the river level value at which action is taken to verify basin levels and deep well pumps are ready to perform the UHS makeup function in the place of the SX makeup pumps will not affect the operation or function of the UHS or the deep well pumps.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change to revise TS 3.7.9, Condition I and SR 3.7.9.3 reestablishes the margin between the design bases combined event flood level and TS 3.7.9, Condition I action level for high river level. The proposed change will ensure the operability of the SX makeup pumps to meet TS 3.7.9 LCO and do not affect the ability of the SX makeup pumps to provide the safety related source makeup to the UHS.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGO concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.4

Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

==5.0

ENVIRONMENTAL CONSIDERATION==

EGO has evaluated the proposed amendment for environmental considerations. The review has resulted in the determination that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, Page 9 of 10

ATTACHMENT 1 Evaluation of Proposed Change the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Institute of Nuclear Power Operations (INPO) Plant Event # 47658, "Unanalyzed Condition Guidance not Adequate to Mitigate a Design Basis Flood."

2. Letter from L. N. Olshan (U.S. NRC) to T. J. Kovach (Commonwealth Edison Company),

"Seismic Qualification of Byron Deep Wells," dated August 7, 1989.

3. Byron Station, Units 1 and 2 Safety Evaluation Report (SER), NUREG-0876, dated February 1982.

4. NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," dated December 29, 1998.

Page 10 of 10

ATTACHMENT 2 Proposed Technical Specifications Changes for Byron Station, Units 1 and 2 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 Mark-up of Technical Specifications Pages 3.7.9 - 4 3.7.9 - 5

UHS 3.7.9 ACTIONS (continued) 698.68 CONDITION REQUIRED ACTION COMPLETION TIME H.

Rock River water level 670.6 ft Mean Sea Level

(MSL).

H.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 Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter I.

Required Action of Condition H not met, OR Rock River water level forecast to exceed

--\\

Once 1.1

Verify basin level for each tower is 90%.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND per 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 702.0 ft MSL by the National

Weather Service (NWS).

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

1.2

Verify OPERABILITY of at least one deep well

pump.

AND 1.3

Verify OPERABILITY of both deep well

pumps.

J.

Required Action and associated Completion Time of Condition A, B,

C,

E,

F,

G,

or

I not met.

OR UHS inoperable for reasons other than Condition A,

B,

C,

D, E,

F,

G,

H,

or

I.

3.1

Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours 3.2

Be in MODE 5.

BYRON UNITS 1 & 2

3.7.9 4

Amendment 173

UHS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level

in each SXCT basin is 60%.