RS-19-081, Supplement to Application for Technical Specifications Change to Add LCO 3.0.9 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process

Supplement to Application for Technical Specifications Change to Add LCO 3.0.9 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process

ML19221B562
Person / Time
Site:	Byron, Braidwood
Issue date:	08/09/2019
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-19-081
Download: ML19221B562 (10)

Text

{{#Wiki_filter:.. Exelon Generati on RS-19-081 10 CFR 50.90 August 9, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Supplement to Application for Technical Specifications Change to Add LCO 3.0.9 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process

References:

1. Letter from D. M. Gullatt (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Application for Technical Specificati ons Change to Add LCO 3.0.9 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process," dated January 31 , 2019

2. TSTF-372-A, Revision 4, "Addition of LCO 3.0.8, lnoperability of Snubbers, "

dated April 27, 2004

3. Notice of Availability of Model Application Concernin g Technical Specification Improvement to Modify Requirements Regarding the Additi on of Limiting Condition for Operation 3.0.8 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process, dated May 4, 2005 (70 FR 23252)

In Reference 1, Exelon Generati on Company, LLC (EGC) submitted a request for an amendment to the Technical Specifications (TS) for Braidwood Station, Units 1 and 2, and Byron Station , Units 1 and 2. The proposed amendment would modify TS requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.9. The change is consistent with the Nuclear Regulatory Commission (NRC) approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler, TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers" (Reference 2). The availability of this TS improvement was announced in the Federal Register on May 4, 2005 (70 FR 23252) as part of the consolidated line item improvement process (CLllP) (Reference 3).

U.S. Nuclear Regulatory Commission August 9, 2019 Page 2 As discussed with Mr. Joel S. Wiebe of the NRC on August 6, 2019, it was identified that there is an error with the inserted text provided for the TS for the new Braidwood Station and Byron Station LCO 3.0.9. Specifically, the word "support" should instead be "supported", as indicated in the following excerpt (correction indicated in bold-type text): LCO 3.0.9 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and: In addition, other minor, typographical errors were corrected in the inserted text for the TS pages. Attachments 1 and 2 provide the existing TS pages, including the updated insert, for Braidwood Station and Byron Station, respectively, marked up to show the proposed change. EGC has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the conclusion that the proposed license amendment does not involve a significant hazards consideration. This additional information also does not affect the conclusion that neither an environmental assessment need be prepared in support of the proposed amendment. In accordance with 10 CFR 50.91 , "Notice for public comment; State consultation," paragraph (b), EGC is providing a copy of this letter to the State of Illinois. Should you have any questions concerning this submittal, please contact Ms. Lisa Simpson at (630) 657-2815. I declare under penalty of perjury that the foregoi ng is true and correct. Executed on the 9th day of August 2019. Res ectfully, Patrick R. Simpson Sr. Manager - Licensing Exelon Generation Company, LLC Attachments:

1. Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2

2. Proposed Technical Specifications Changes fo r Byron Station , Units 1 and 2 cc: NRC Regional Administrator - Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Project Manager, NRR - Braidwood and Byron Stations Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 Mark-up of Technical Specifications Pages 3.0 - 1 3.0-4 UPDATED INSERT 1

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 ttR4- LCO 3.0.7. - - - - - - - ---; ,-y t' r\= f anc[ LC ~) 3-.Q. 9~ ~ ,____ _ _ _ __ LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Ti me(s), completion of the Required Action(s) is not required unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MO DE 3 wi th in 7 hours;

b. MO DE 4 within 13 hours; and

c. MODE 5 vvithin 37 hours.

Excepti ons to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS , completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4. BRAIDWOOD - UNITS 1 &2 3.0 - 1 Amendment -98

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.7 Exception LCOs allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Exception LCOs is optional. When an Exception LCO is desired to be met but is not met, the ACTIONS of the Exception LCO shall be met. When an Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications. LCO 3.0.8 LCOs, including associated ACTIONs, shall apply to each unit individually, unless otherwise indicated. Whenever the LCO refers to a system or component t hat is shared by both units, the ACTIONs will apply to both units simultaneously.

-~

t-{LJP-

    =                       :=r=- 1= =_~=

D=A=T-=E=D=__ l=N=_=. =R= ] ======================= BRAIDWOOD - UNITS 1 &2 3.0 - 4 Amendment -+/-9 UPDATED INSERT 1 LCO 3.0.9 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

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 3.0 - 1 3.0-4 UPDATED INSERT 1

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.l LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 a-oo-LCO 3.0.7.

---

! , i--.a\ i\'- r:-ancTLc iJ 3-.o-

                                                                 .9. -* ,___ _ _ _ __
                       .-!                      ~~------*--*-*-**---

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by t he associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as appl icabl e , in:

a. MO DE 3 01ithi n 7 hours ;

b. MODE 4 wi th in 13 hours; and

c. MODE 5 within 37 hours.

Except i ons to this Specification are stated in the individual Spec ifications. Where corrective measures are compl eted that permit operation in accordance with the LCO or ACTIONS , completion of the act ions required by LCO 3.0.3 is not required. LCO 3.0.3 is only appli cable i n MODES 1, 2, 3, and 4. BYRON - UNITS 1 &2 3.0 - 1 Amendment -We*

LCO Appli cabi l ity 3.D 3.D LCO Applicabili ty LCO 3.D. 7 Exception LCOs allow specified Technical Speci f i cation (TS) requirements t o be changed t o permit performance of special t ests and operations. Unles s otherwi se specified, all other TS requirements remain unchanged. Compli ance with Exception LCDs i s opti onal. When an Excepti on LCD i s desired to be met but i s not met, the ACTIONS of the Excepti on LCD shall be met. When an Exception LCD i s not desired to be met, entry into a MODE or other specifi ed conditi on in the Applica bility shall be made i n accordance with the other applicable Speci fi cati ons . LCD 3.0 .8 LCOs , incl uding associated ACTIONs , shall apply to each uni t individuall y, unless otherwise indicated. Whenever the LCO refers to a syst em or component t hat i s shared by both units, the ACTIONs will appl y to both units simultaneously. f---~====================== L__ {iJP-f5AfE6 IN S-ERT1--J BYRON - UN ITS 1 &2 3.D - 4 Amendment +/-9-8

UPDATED INSERT 1 LCO 3.0.9 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours.

At the end of the specified period the required snubbers must be able to perform their associated support function(s) , or the affected supported system LCO(s) shall be declared not met.}}