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{{Adams
#REDIRECT [[RS-11-136, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications (TS) 3.3.1]]
| number = ML11256A132
| issue date = 09/02/2011
| title = Braidwood, Units 1 & 2 and Byron, Units 1 & 2 - Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications (TS) 3.3.1
| author name = Gullott D M
| author affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000454, 05000455, 05000456, 05000457
| license number = NPF-037, NPF-066, NPF-072, NPF-077
| contact person =
| case reference number = RS-11-136, TAC ME5836, TAC ME5837, TAC ME5838, TAC ME5839
| document type = Letter, Technical Specifications
| page count = 60
| project = TAC:ME5836, TAC:ME5837, TAC:ME5838, TAC:ME5839
| stage = Response to RAI
}}
 
=Text=
{{#Wiki_filter:ExekrnExelon Generation Company, LLC4300 Winfield RoadWarrenville, IL 60555www.exeloncorp.com NuclearProprietary Information -Withhold From Public Disclosure Under 10 CFR 2.390RS-11-136September 2, 201110 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-001Braidwood Station, Units 1 and 2Facility Operating License Nos. NPF-72 and NPF-77NRC Docket Nos. STN 50-456 and STN 50-457Byron Station, Units 1 and 2Facility Operating License Nos. NPF-37 and NPF-66NRC Docket Nos. STN 50-454 and STN 50-455Subject:References:Response to Request for Additional Information Related to License AmendmentRequest to Revise Technical Specifications (TS) 3.3.1, "Reactor Trip System(RTS) Instrumentation," and TS 3.3.2, "Engineered Safety Feature ActuationSystem (ESFAS) Instrumentation," to Reflect Installation of Bypass Test Capability1. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. NuclearRegulatory Commission, "License Amendment Request To Revise TechnicalSpecifications (TS) 3.3.1, 'Reactor Trip System (RTS) Instrumentation,' andTS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS)Instrumentation,' To Reflect Installation of Bypass Test Capability," datedMarch 14, 20112. Letter from N. J. DiFrancesco (U. S. Nuclear Regulatory Commission) toM. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1and 2, Byron Stations, Unit Nos. 1 and 2 -Request for Additional InformationRegarding License Amendment Request to Revise Technical Specificationswith Bypass Test Capability (TAC Nos. ME5836, ME5837, ME5838, andME5839)," dated July 22, 2011In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment torevise Technical Specifications (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," andTS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," for BraidwoodStation, Units 1 and 2, and Byron Station, Units 1 and 2, to reflect the planned installation of thebypass test capability.The NRC requested additional information to complete the review of the proposed licenseamendment in Reference 2. In response to this request, EGC is providing the attachedinformation. Attachments 1 and 7 provide the requested responses.Attachments 7 and 9 contain Proprietary Information. Withhold From Public Disclosure Under 10 CFR 2.390.When separated from Attachment 7 and 9, this document is decontrolled.7400/
September 2, 2011U. S. Nuclear Regulatory CommissionPage 2Proprietary Information -Withhold From Public Disclosure Under 10 CFR 2.390As discussed with Mr. Nick DiFrancesco of the NRC on June 20, 2011, administrative errors wereintroduced into TS 3.3.1 during the implementation of Amendments 165 and 171 for theBraidwood and Byron Stations, respectively. Specifically, Table 3.3.1-1 currently referencesincorrect page numbers for Note 1 and Note 2. EGC is correcting these errors with the markupsof the TS page for Braidwood Station and Byron Station provided in Attachments 2 and 3,respectively.As discussed with the NRC during the July 13, 2011, conference call, implementation of thebypass test instrumentation modifications are scheduled to be completed during the BraidwoodUnit 1 spring 2012 refueling outage (Al R16), the Braidwood Unit 2 fall 2012 refueling outage(A2R1 6), the Byron Unit 1 fall 2012 refueling outage (B1 R1 8), and the Byron Unit 2 spring 2013refueling outage (B2R17). Following completion of implementation of the bypass testinstrumentation modifications at the four Braidwood and Byron units, the TS and correspondingBases will be revised as part of a separate, clean-up license amendment request to reflect theapplicable functions that have bypass test capability installed. Attachments 4 and 5 provide theadministrative clean-up markups of TS pages for Braidwood Station and Byron Station,respectively, for that separate license amendment request.The regulatory commitment contained in this letter is summarized in Attachment 6.Attachment 7 provides the proprietary Westinghouse Electric Company LLC (Westinghouse)letter CAE-1 1-88 Revision 1 P-Attachment/CCE-1 1-83 Revision 1 P-Attachment, "Response toJuly 22, 2011, 'Braidwood Station, Units 1 and 2, Byron Stations, Unit Nos. 1 and 2 -Request forAdditional Information Regarding License Amendment Request to Revise TechnicalSpecifications with Bypass Test Capability (TAC Nos. ME5836, ME5837, ME5838, and ME5839)'(Proprietary)," dated August 26, 2011.As Attachment 7 contains information proprietary to Westinghouse, it is supported by an affidavitsigned by Westinghouse, the owner of the information. The affidavit sets forth the basis on whichthe information may be withheld from public disclosure by the NRC and addresses with specificitythe considerations listed in paragraph (b)(4) of 10 CFR 2.390, "Public inspections, exemptions,requests for withholding." Accordingly, it is requested that the information that is proprietary toWestinghouse be withheld from public disclosure in accordance with 10 CFR 2.390.A Non-Proprietary version of the information contained in Attachment 7 is provided inAttachment 8. Attachment 8 also provides the Westinghouse Application for WithholdingProprietary Information from Public Disclosure CAW-1 1-3237, accompanying Affidavit, ProprietaryInformation Notice, and Copyright Notice.Correspondence with respect to the copyright or proprietary aspects of the items listed above orthe supporting Westinghouse affidavit should reference CAW-1 1-3237 and should be addressedto J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC,Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Attachments 7 and 9 contain Proprietary Information. Withhold From Public Disclosure Under 10 CFR 2.390.When separated from Attachment 7 and 9, this document is decontrolled.
September 2, 2011U. S. Nuclear Regulatory CommissionPage 3Proprietary Information -Withhold From Public Disclosure Under 10 CFR 2.390Attachment 9 provides proprietary Westinghouse schematic diagrams supporting the requestedresponse to Question 1. As Attachment 9 contains information proprietary to Westinghouse, it issupported by an affidavit signed by Westinghouse, the owner of the information. The affidavitsets forth the basis on which the information may be withheld from public disclosure by the NRCand addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390.Accordingly, it is requested that the information that is proprietary to Westinghouse be withheldfrom public disclosure in accordance with 10 CFR 2.390. Attachment 9 has been classified asProprietary in its entirety; therefore, a Non-Proprietary version of Attachment 9 is not beingprovided.Correspondence with respect to the copyright or proprietary aspects of the items listed above orthe supporting Westinghouse affidavit should reference CAW-1 1-3238 and should be addressedto J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC,Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Attachment 10 provides the Westinghouse Application for Withholding Proprietary Informationfrom Public Disclosure CAW-1 1-3238, accompanying Affidavit, Proprietary Information Notice,and Copyright Notice.Attachment 11 provides pictures of the NIS Bypass Panel and 7300 Bypass Protection System.EGC has reviewed the information supporting a finding of no significant hazards considerationand the environmental consideration that were previously provided to the NRC in Attachment 1 ofReference 1. The additional information provided in this submittal does not affect the bases forconcluding that the proposed license amendment does not involve a significant hazardsconsideration. In addition, the additional information provided in this submittal does not affect thebases for concluding that neither an environmental impact statement nor an environmentalassessment 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 Illinoisofficial.Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at(630) 657-2815.I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd dayof September 2011.Respectfully,David M. GullottManager -LicensingExelon Generation Company, LLCAttachments 7 and 9 contain Proprietary Information. Withhold From Public Disclosure Under 10 CFR 2.390.When separated from Attachment 7 and 9, this document is decontrolled.
September 2, 2011U. S. Nuclear Regulatory CommissionPage 4Proprietary Information -Withhold From Public Disclosure Under 10 CFR 2.390Attachments:1. Response to Request for Additional Information2. Markup of Technical Specifications Page for Braidwood Station, Units 1 and 23. Markup of Technical Specifications Page for Byron Station, Units 1 and 24. Administrative Clean-up Markup of Technical Specifications Pages for Braidwood Station,Units 1 and 25. Administrative Clean-up Markup of Technical Specifications Pages for Byron Station,Units 1 and 26. Summary of Regulatory Commitments7. Westinghouse letter CAE-1 1-88 Revision 1 P-Attachment/CCE-1 1-83 Revision 1P-Attachment, "Response to July 22, 2011, 'Braidwood Station, Units 1 and 2, ByronStations, Unit Nos. 1 and 2 -Request for Additional Information Regarding LicenseAmendment Request to Revise Technical Specifications with Bypass Test Capability (TACNos. ME5836, ME5837, ME5838, and ME5839)'" (PROPRIETARY INFORMATION)8. Westinghouse Affidavit and Non-Proprietary Version of Attachment 79. Supporting Information -Schematic Diagrams With and Without Bypass Circuitry(PROPRIETARY INFORMATION)10. Westinghouse Affidavit for Attachment 911. Supporting Information -Pictures of NIS Bypass Panel and 7300 Bypass Protection Systemcc: NRC Regional Administrator, Region IIINRC Senior Resident Inspector, Braidwood StationNRC Senior Resident Inspector, Byron StationNRC Project Manager, NRR -Braidwood and Byron StationIllinois Emergency Management Agency -Division of Nuclear SafetyAttachments 7 and 9 contain Proprietary Information. Withhold From Public Disclosure Under 10 CFR 2.390.When separated from Attachment 7 and 9, this document is decontrolled.
ATTACHMENT IResponse to Request for Additional InformationBy letter to the Nuclear Regulatory Commission (NRC) dated March 14, 2011 (Reference 1),Exelon Generation Company, LLC, (EGC) requested a license amendment to revise TechnicalSpecifications (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," and TS 3.3.2,"Engineered Safety Feature Actuation System (ESFAS) Instrumentation," for Braidwood Station,Units 1 and 2, and Byron Station, Units 1 and 2, to reflect the planned installation of the bypasstest capability.In a letter dated July 22, 2011 (Reference 2), the NRC requested that EGC provide additionalinformation in support of its review of the March 14, 2011, request.Reference: 1. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. NuclearRegulatory Commission, "License Amendment Request To Revise TechnicalSpecifications (TS) 3.3.1, 'Reactor Trip System (RTS) Instrumentation,' andTS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS)Instrumentation,' To Reflect Installation of Bypass Test Capability," datedMarch 14, 20112. Letter from N. J. DiFrancesco (U. S. Nuclear Regulatory Commission) toM. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1and 2, Byron Stations, Unit Nos. 1 and 2 -Request for Additional InformationRegarding License Amendment Request to Revise Technical Specificationswith Bypass Test Capability (TAC Nos. ME5836, ME5837, ME5838, andME5839)," dated July 22, 2011NRC Question 1:Provide the schematic diagrams with and without bypass circuitry to illustrate the reactor tripfunctions with and without bypass capability and the pictures of the Nuclear InstrumentationSystem Bypass Panel and 7300 Bypass Protection System including the bypass keylockswitches, toggle switches, and indications.Response to Question 1:Schematic diagrams to illustrate the reactor trip functions with and without bypass circuitry areprovided in Attachment 9 to this submittal.Pictures of the NIS Bypass Panel and 7300 Bypass Protection System are provided inAttachment 11 to this submittal.NRC Question 2:The submittal Westinghouse report WCAP-1 7349-P Revision 1, Section 4.2.2, states that adiscussion of the Bypass Test Instrument (BTI) adherence to Institute of Electrical andElectronics Engineers (IEEE) Standard 379-1972 is found in Section 4.3. However, nodescription of analysis is provided. Please provide the analysis conducted in accordance withIEEE Standard 379-1972.Page 1 of 4 ATTACHMENT IResponse to Request for Additional InformationResponse to Question 2:The response to NRC Question 2 is provided in Attachment 7 to this submittal as the responseto RAI Question #2.NRC Question 3:Does this BTI involve any digital component or it is all analog?Response to Question 3:New BTI installation hardware is all analog with no digital (microprocessor/programmable)equipment. However, full implementation installation, with enhanced indication, interfaces withsome pre-existing digital systems such as the sequence of events recorder (SER). The SER isa digital system which receives input from BTI to provide enhanced indication. The BTIequipment supplies contact closure to the SER input that provides a printout of which loop isplaced into bypass. BTI equipment that performs the channel bypass function is all analog.NRC Question 4:If the BTI involves digital components, describe in detail how the BTI will conform to theIEEE Standard 603-1991.Response to Question 4:As the BTI equipment that performs the channel bypass function is all analog, this question isnot applicable to the Braidwood and Byron bypass test instrumentation modifications.NRC Question 5:If the BTI involves only analog systems, supplement the evaluation to describe how the designconforms to the following clauses of the IEEE Standard 279-1971:4.6 Channel Independence4.7.3 Single Random FailureResponse to Question 5:The response to NRC Question 5 is provided in Attachment 7 to this submittal as the responseto RAI Question #5.Page 2 of 4 ATTACHMENT 1Response to Request for Additional InformationNRC Question 6:In Attachment 2 and 3 of your application dated March 14, 2011, Inserts A and B add thefollowing NOTES to the Technical Specifications (TSs):Insert A1. For functions with installed bypass test capability, one channel may be bypassed forup to 12 hours for surveillance testing and setpoint adjustment.2. For functions with no installed bypass test capability, the inoperable channel may bebypassed for up to 12 hours for surveillance testing and setpoint adjustment of otherchannels.Insert B1. For Functions with installed bypass test capability, one channel may be bypassed forup to 12 hours for surveillance testing.2. For functions with no installed bypass test capability, the inoperable channel may bebypassed for up to 12 hours for surveillance testing of other channels.Based on review of Table 3.3.1-1 and your application, it appears that Insert A/B Note 2 is notapplicable to TS 3.3.1 Conditions D and E as all the applicable functions will have bypass testcapability installed. Please remove Note 2 if not applicable to the Conditions that will containfunctions with installed bypass.Based on review of Table 3.3.2-1 and your application it appears that Insert A/B Note 2 is notapplicable to TS 3.3.2 Conditions D and K as all the applicable functions will have bypass testcapability installed. Please remove Note 2 if not applicable to the Conditions that will containfunctions with installed bypass.For TS 3.3.1 Condition K, please explicitly define which functions Note 2 applies to theproposed design (e.g., Functions 12 and 13).The NRC staff notes that the allowance for channel bypass is addressed in NUREG-1431,Revision 3, Standard Technical Specification [STS] -Westinghouse Plants," and the content ofyour notes differ. Please justify deviating from the NRC staff position contained in the STSlanguage or consider revising to incorporate STS wording.Response to Question 6:As described in Reference 1, EGC requested approval of the proposed license amendment byMarch 14, 2012. Once approved, the amendment will implemented within 60 days. Hardwarechanges necessary to the Nuclear Instrumentation System (NIS) and 7300 process protectionsystem to facilitate testing in bypass will be implemented in accordance with 10 CFR 50.59.Page 3 of 4 ATTACHMENT IResponse to Request for Additional InformationImplementation- of the bypass test instrumentation modifications are scheduled to be completedduring the Braidwood Unit 1 spring 2012 refueling outage (Al R16), the Braidwood Unit 2 fall2012 refueling outage (A2R16), the Byron Unit 1 fall 2012 refueling outage (B1 R1 8), and theByron Unit 2 spring 2013 refueling outage (B2R17). During this timeframe of phasedmodifications, Required Action Note 1 and/or Note 2 may be applicable to TS 3.3.1Conditions D and E and to TS 3.3.2 Conditions D and K. After the final modification is completefor Braidwood and Byron, Note 2 will no longer be applicable to TS 3.3.1 Conditions D and Eand to TS 3.3.2 Conditions D and K as all applicable functions will have bypass test capabilityinstalled.For TS 3.3.1 Condition K, the following functions in the RTS instrumentation will be modified tohave installed bypass capability and permit testing in bypass:" Function 8.a Pressurizer Pressure -Low* Function 9 Pressurizer Water Level -High" Function 10 Reactor Coolant Flow -LowFunction 12 (Undervoltage RCPs) and Function 13 (Underfrequency RCPs) will not be modifiedto have installed bypass capability.Following completion of implementation of the bypass test instrumentation modifications at thefour Braidwood and Byron units, the TS and corresponding Bases will be revised as part of aseparate, clean-up license amendment. Specifically, TS 3.3.1, Conditions D and E, TS 3.3.2,Conditions D and K, and the corresponding Bases pages will be revised to reflect the applicablefunctions that have bypass test capability installed. TS 3.3.1, Condition K, and thecorresponding Bases pages will be revised to reflect the specific functions that have bypass testcapability installed and the specific functions that do not have bypass test capability installed.As discussed with the NRC during the July 13, 2011, conference call, the following one-timecommitment is being made:EGC commits to submit a follow-up license amendment request to revise the RequiredAction Notes in the Braidwood and Byron Technical Specifications (TS) 3.3.1, "ReactorTrip System (RTS) Instrumentation," and TS 3.3.2, "Engineered Safety FeatureActuation System (ESFAS) Instrumentation," to delete Note 2 for the Conditions forwhich all applicable functions have bypass test capability installed and revise TS 3.3.1,Condition K, as appropriate.This license amendment request will be submitted within one year following completion of theimplementation of the bypass test instrumentation modifications at the four Braidwood andByron units (Reference Summary of Regulatory Commitments in Attachment 6).Attachments 4 and 5 provide the administrative clean-up markups of TS pages for BraidwoodStation and Byron Station, respectively. With the exception of the TS 3.3.1, Condition K, theproposed changes to the Required Action Notes are consistent with wording in StandardTechnical Specifications (NUREG-1431, Revision 3) for plants with installed bypass testcapability.Page 4 of 4 ATTACHMENT 2Markup of Technical Specifications Page for Braidwood Station, Units I and 2Braidwood Station, Units I and 2Facility Operating License Nos. NPF-72 and NPF-77REVISED TECHNICAL SPECIFICATIONS PAGE3.3.1-15 RTS Instrumentation3.3.1Table 3.3.1-1 (page 2 of 6)Reactor Trip System InstrumentationAPPLICABLE MODES OROTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLEFUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE6. Overtemlperature AT 1,2 4 E SR 3.3.1.1 Refer toSR 3.3.1.3 Note 1 44I&sect;eSR 3.3.1.6SR 3.3.1.7SR 3.3.1.10SR 3.3.1.157. Overpower AT 1,2 4 E SR 3.3.1.1 Refer toSR 3.3.1.7 Note 2 4-P&#xfd;eeSR 3.3.1.10 -3.-i4--i4SR 3.3.1.158. Pressurizer Pressurea. Low 1 e)4 K SR 3.3.1.1 _ 1875 psigSR 3.3.1.7SR 3.3.1.10SR 3.3.1.15b. High 1,2 4 E SR 3.3.1.1 < 2393 psigSR 3.3.1.7SR 3.3.1.10SR 3.3.1.159. Pressurizer Water 1 3 K SR 3.3.1.1 < 93.5% ofLevel-High SR 3.3.1.7 instrumentSR 3.3.1.10 span10. Reactor Coolant 1(e) 3 K SR 3.3.1.1 > 89.3% ofFlow-Low (per loop) SR 3.3.1.7 loop minimunSR 3.3.1.10 measured flowSR 3.3.1.1511. Reactor Coolant Puw 10 4 R SR 3.3.1.13 NA(RCP) Breaker Position(per train)(continued)(e) Above the P-7 (Low Power Reactor Trips Block) interlock.BRAIDWOOD -UNITS 1 & 23.3.1 -15Amendment 165.1166 ATTACHMENT 3Markup of Technical Specifications Page for Byron Station, Units I and 2Byron Station, Units I and 2Facility Operating License Nos. NPF-37 and NPF-66REVISED TECHNICAL SPECIFICATIONS PAGE3.3.1-15 RTS Instrumentation3.3.1Table 3.3.1-1 (page 2 of 6)Reactor Trip System InstrinentationAPPLICABLE MODES OROTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLEFUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE6. Overteperature AT 1,2 4 E SR 3.3.1.1 Refer toSR 3.3.1.3 Note 1 +PageSR 3.3.1.6 3.-3.4i--SR 3.3.1.7SR 3.3.1.10SR 3.3.1.157. Overpower AT 1,2 4 E SR 3.3.1.1 Refer toSR 3.3.1.7 Note 2 +PageSR 3.3.1.10SR 3.3.1.158. Pressurizer Pressurea. Low 4 K SR 3.3.1.1 > 1875 psigSR 3.3.1.7SR 3.3.1.10SR 3.3.1.15b. High 1,2 4 E SR 3.3.1.1 2393 psigSR 3.3.1.7SR 3.3.1.10SR 3.3.1.159. Pressurizer Water 1) 3 K SR 3.3.1.1 < 93.5% ofLevel- High SR 3.3.1.7 instrumentSR 3.3.1.10 span10. Reactor Coolant 1W 3 K SR 3.3.1.1 > 89.3% ofFlow-Low (per loop) SR 3.3.1.7 loop miniwmuSR 3.3.1.10 weasured flowSR 3.3.1.1511. Reactor Coolant PTmp Im 4 R SR 3.3.1.13 NA(RCP) Breaker Position(per train)(continued)(e) Above the P-7 (Low Power Reactor Trips Block) interlock.BYRON -UNITS 1 & 23.3.1 -15Amendment 1&#xfd;1.1171 ATTACHMENT 4Administrative Clean-up Markup of Technical Specifications Pages for Braidwood Station,Units 1 and 2Braidwood Station, Units I and 2Facility Operating License Nos. NPF-72 and NPF-77REVISED TECHNICAL SPECIFICATIONS PAGES3.3.1-23.3.1-33.3.1-43.3.2-23.3.2-5INSERT I Administrative Clean-up Markup of Technical Specifications Pages for Braidwood Station, Units 1 and 2 IRTS Instrumentation3.3.1ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEC. One channel or train ------------NOTE---------inoperable. While this LCO is not met forFunction 18, 19, or 20 inMODE 5, making the RodControl System capable of rodwithdrawal is not permitted.C.1 Restore channel or 48 hourstrain to OPERABLEstatus.ORC.2.1 Initiate action to 48 hoursfully insert allrods.ANDC.2.2 Place the Rod Control 49 hoursSystem in a conditionincapable of rodwithdrawal.D. One Power Range -----------NOTE----------Neutron Flux-High The in..perable han.el m.ay bechannel inoperable. by passe fer up to 12 fer surveillance testing andsctpeint adjustmfent of otherOne channel may bebypassed for up to12 hours for D.1 Place channel in 72 hourssurveillance testing trip.and setpointadjustment. ORD.2 Be in MODE 3. 78 hours(continued)BRAIDWOOD -UNITS 1 & 23.3.1 -2Amendment 449 Administrative Clean-up Markup of Technical Specifications Pages for Braidwood Station, Units 1 and 2RTS Instrumentation3.3.1ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEE. One channel -NOTE----------inoperable. T-he in .p...le l hannel may bebypRa csed feor up to 12 houro_____________ for Survillne sting ofOne channel may be ,other ehannel s.bypassed for up to12 hours for E.1 Place channel in 72 hourssurveillance testing. trip.ORE.2 Be in MODE 3. 78 hoursF. One Intermediate Range F.1 Reduce THERMAL POWER 2 hoursNeutron Flux channel to < P-6.inoperable.ORF.2 Increase THERMAL 2 hoursPOWER to > P-10.G. Two Intermediate Range G.1 Suspend operations ImmediatelyNeutron Flux channels involving positiveinoperable. reactivity additions.ANDG.2 Reduce THERMAL POWER 2 hoursto < P-6.H. One Source Range H.1 Suspend operations ImmediatelyNeutron Flux channel involving positiveinoperable. reactivity additions.(continued)BRAIDWOOD -UNITS 1 & 23.3.1 -3Amendment 4-48 I Administrative Clean-up Markup of Technical Specifications Pages for Braidwood Station, Units I and 2 IRTS Instrumentation3.3.1ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEI. Two Source Range 1.1 Open Reactor Trip ImmediatelyNeutron Flux channels Breakers (RTBs).inoperable.J. One Source Range J.1 Restore channel to 48 hoursNeutron Flux channel OPERABLE status.inoperable.ORJ.2.1 Initiate action to 48 hoursfully insert allrods.ANDJ.2.2 Place the Rod Control 49 hoursSystem in a conditionincapable of rodwithdrawal.K. One channel -NOTE I-J--]inoperable. The inoperable .hannel m.. ay bebypa szed for up t- 12 hepsfor surveillanlee testinlg ofReplace w ith --- -- --- -- --- ---.INSERT IK.1 Place channel in 72 hourstrip.ORK.2 Reduce THERMAL POWER 78 hoursto < P-7.(continued)BRAIDWOOD -UNITS 1 & 23.3.1 -4Amendment 449 Administrative Clean-up Markup of Technical Specifications Pages for Braidwood Station, Units 1 and 2ESFAS Instrumentation3.3.2ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEC. One train inoperable. C.1 --------NOTE------One train may bebypassed for up to4 hours forsurveillance testingprovided the othertrain is OPERABLE.Restore train to 24 hoursOPERABLE status.ORC.2.1 Be in MODE 3. 30 hoursANDC.2.2 Be in MODE 5. 60 hoursD. One channel D.1 --------NOTE------inoperable. T-he- :...epa.ed for up to12 heps-few-....i. llanoc testingof ether ehanncls.One channel may bebypassed for up to Place channel in 72 hours12 hours for trip.surveillance testing. ORD.2.1 Be in MODE 3. 78 hoursANDD.2.2 Be in MODE 4. 84 hours(continued)BRAIDWOOD -UNITS 1 & 23.3.2 -2Amendment 4-49 Administrative Clean-up Markup of Technical Specifications Pages for Braidwood Station, Units 1 and 2ESFAS Instrumentation3.3.2ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEI. One channel 1.1 -------- Ninoperable. The inoperablechannel may bebypassed for up to12 hours forsurveillance testingof other channels.Place channel in 72 hourstrip.OR1.2 Be in MODE 3. 78 hoursJ. One or more trains J.1 Declare associated Immediatelyinoperable. auxiliary feedwaterpump inoperable.K. One channel K.1 --------NOTE------inoperable. Th i..ep.e.ab1lehn- Ilmyb. IIly.by pa for up toOne channel may be' of ethcr ehannels.bypassed for up to12 hours for Place channel in 72 hourssurveillance testing. trip.ORK.2.1 Be in MODE 3. 78 hoursANDK.2.2 Be in MODE 5. 108 hours(continued)BRAIDWOOD -UNITS 1 & 23.3.2 -5Amendment 4-4&
Braidwood Station, Units 1 and 2Facility Operating License Nos. NPF-72 and NPF-77NRC Docket Nos. STN 50-456 and STN 50-457INSERT 11. For Functions with installed bypass test capability (Functions 8a, 9, 10), onechannel may be bypassed for up to 12 hours for surveillance testing.2. For Functions with no installed bypass test capability (Functions 12 and 13), theinoperable channel may be bypassed for up to 12 hours for surveillance testingof other channels.Page 1 of I ATTACHMENT 5Administrative Clean-up Markup of Technical Specifications Pages for Byron Station,Units 1 and 2Byron Station, Units I and 2Facility Operating License Nos. NPF-37 and NPF-66REVISED TECHNICAL SPECIFICATIONS PAGES3.3.1-23.3.1-33.3.1-43.3.2-23.3.2-5INSERT lAdministrative Clean-up of Technical Specifications Pages for Byron Station, Units I and 2RTS Instrumentation3.3.1ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEC. One channel or train ------------NOTE---------inoperable. While this LCO is not met forFunction 18, 19, or 20 inMODE 5, making the RodControl System capable of rodwithdrawal is not permitted.C.1 Restore channel or 48 hourstrain to OPERABLEstatus.ORC.2.1 Initiate action to 48 hoursfully insert allrods.ANDC.2.2 Place the Rod Control 49 hoursSystem in a conditionincapable of rodwithdrawal.D. One Power Range -----------NOTE----------Neutron Flux-High The in.p.rable l hann, o- l may bechannel inoperable. bj-asd f.r up to 12 huprsfor 1uvilno otn ane-dseotpcint. adjustmcint of ether__ hannol4s-.One channel may be __ ------------I-I-----I---.bypassed for up to12bhours for D.1 Place channel in 72 hours12 hous fortrip.surveillance testingand setpoint ORadjustment. D.2 Be in MODE 3. 78 hours(continued)BYRON -UNITS 1 & 23.3.1 -2Amendment 4&#xfd;53 lAdministrative Clean-up of Technical Specifications Pages for Byron Station, Units I and 2IRTS Instrumentation3.3.1ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEE. One channel NOTE----------inoperable. Th innpo.able -hann...1lay bebpa ..... for up to 12 hour3for' 5zu-rvcillance testing ofOne channel may bebypassed for up to E.1 Place channel in 72 hours12 hours for trip.surveillance testing. ORE.2 Be in MODE 3. 78 hoursF. One Intermediate Range F.1 Reduce THERMAL POWER 2 hoursNeutron Flux channel to < P-6.inoperable.ORF.2 Increase THERMAL 2 hoursPOWER to > P-10.G. Two Intermediate Range G.1 Suspend operations ImmediatelyNeutron Flux channels involving positiveinoperable. reactivity additions.ANDG.2 Reduce THERMAL POWER 2 hoursto < P-6.H. One Source Range H.1 Suspend operations ImmediatelyNeutron Flux channel involving positiveinoperable. reactivity additions.(continued)BYRON -UNITS 1 & 23.3.1 -3Amendment 4F,-i3 lAdministrative Clean-up of Technical Specifications Pages for Byron Station, Units 1 and 2RTS Instrumentati on3.3.1ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEI. Two Source Range 1.1 Open Reactor Trip ImmediatelyNeutron Flux channels Breakers (RTBs).inoperable.J. One Source Range J.1 Restore channel to 48 hoursNeutron Flux channel OPERABLE status.inoperable.ORJ.2.1 Initiate action to 48 hoursfully insert allrods.ANDJ.2.2 Place the Rod Control 49 hoursSystem in a conditionincapable of rodwithdrawal.K. One channelinoperable.-------------- NOTE_:-U-jThe inoeperable J hann, l mLay bebypa z5od for up to 12 heursfor surveillanoce test~ing oflo-ther ehannc!5.Replace withINSERT 1K.1ORK. 2Place channel intrip.72 hoursReduce THERMAL POWERto < P-7.78 hours.1. _____________________________________ 1 ________________________(continued)BYRON -UNITS 1 & 23.3.1 -4Amendment 154 lAdministrative Clean-up of Technical Specifications Pages for Byron Station, Units 1 and 2IESFAS Instrumentation3.3.2ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEC. One train inoperable. C.1 --------NOTE------One train may bebypassed for up to4 hours forsurveillance testingprovided the othertrain is OPERABLE.Restore train to 24 hoursOPERABLE status.ORC.2.1 Be in MODE 3. 30 hoursANDC.2.2 Be in MODE 5. 60 hoursD. One channel D.1 --------NOTE------inoperable. Th ii...... bleehannelmfay bebypassed for p t12-heups f-fe-lance tetifngOne channel may be -f--t-r--------bypassed for up to12 hours for Place channel in 72 hourssurveillance testing. trip.ORD.2.1 Be in MODE 3. 78 hoursANDD.2.2 Be in MODE 4. 84 hours(continued)iBYRON -UNITS 1 & 23.3.2 -2Amendment 4&#xfd;54 lAdministrative Clean-up of Technical Specifications Pages for Byron Station, Units I and 2IESFAS Instrumentation3.3.2ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEI. One channel 1.1 --------NOTE------inoperable. The inoperablechannel may bebypassed for up to12 hours forsurveill ance testingof other channels.Place channel in 72 hourstrip.OR1.2 Be in MODE 3. 78 hoursJ. One or more trains J.1 Declare associated Immediatelyinoperable. auxiliary feedwaterpump inoperable.K. One channel K.1 --------NOTE------inoperable. eehanle!flany bebypass ed.c for up tosurveil lanee testingOne channel may be of -other -hannelo.bypassed for up to12 hours for Place channel in 72 hourssurveillance testing, trip.K.2.1 Be in MODE 3. 78 hoursANDK.2.? Be in MODE 5. 108 hours(continued)BYRON -UNITS 1 & 23.3.2 -5Amendment 4&3 Byron Station, Units 1 and 2Facility Operating License Nos. NPF-37 and NPF-66NRC Docket Nos. STN 50-454 and STN 50-455INSERT 11. For Functions with installed bypass test capability (Functions 8a, 9, 10), onechannel may be bypassed for up to 12 hours for surveillance testing.2. For Functions with no installed bypass test capability (Functions 12 and 13), theinoperable channel may be bypassed for up to 12 hours for surveillance testingof other channels.Page 1 of 1 ATTACHMENT 6Summary of Regulatory CommitmentsThe following table identifies the commitment made in this document. (Any other actionsdiscussed in the submittal represent intended or planned actions. They are described to theNRC for the NRC's information and are not regulatory commitments.)COMMITMENT TYPECOMMITMENT COMMITTED DATE ONE-TIME PROGRAMMATICOR "OUTAGE ACTION ACTION(Yes/No) (Yes/No)EGC commits to submit a follow-uplicense amendment request torevise the Required Action Notes inthe Braidwood and ByronTechnical Specifications (TS) 3.3.1, License amendment"Reactor Trip System (RTS) request required toInstrumentation," and TS 3.3.2, be submitted to the"Engineered Safety Feature NRC within one yearActuation System (ESFAS) following completionInstrumentation," to delete Note 2 of implementation of Yes Nofor the Conditions for which all the bypass testapplicable functions have bypass instrumentationtest capability installed and revise modifications at theTS 3.3.1, Condition K, as four Braidwood andappropriate. Byron units.Applicable to Braidwood Station,Units 1 and 2, and Byron Station,Units 1 and 2.
ATTACHMENT 8Westinghouse Affidavit and Non-Proprietary Version of Attachment 7 UI& W sting ouseWestinghouse Electric Company(6)Westinghouse ~~slaiNuclear Services1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 720-075411555 Rockville Pike e-mail: greshaja~westinghouse.comRockville, MD 20852 Proj letter: CAE-11-88, Rev. 1CCE-1 1-83, Rev. 1CAW-1 1-3237August 26, 2011APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: Response to July 22, 2011, "Braidwood Station, Units 1 and 2, Byron Stations, Units 1 and 2-Request for Additional Information Regarding License Amendment Request to ReviseTechnical Specifications with Bypass Test Capability (TAC Nos. ME5836, ME5837,ME5838, and ME5839)" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-1 1-3237 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon GenerationCompany, LLC.Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse affidavit should reference this letter, CAW-1 1-3237, and should be addressed toJ. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428,1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours,J. A. Gresham, ManagerRegulatory ComplianceEnclosures CAW- 11-323 7AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared T. Rodack, who, being by me dulysworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:T. Rodack, DirectorQuality and Licensing ProgramsSworn to and subscribed before methis 26th day of August 2011NotaryCOMMONWEALTH OF pENSLAAI NOTARIAL SEAL.Renee GiamnPole Notary PublicPenn Township, Westmoreland Countylmy commIis......Non Expires Septeber 25, 20131 2CAW-1 1-3237(1) I am Director, Quality and Licensing Programs, in Nuclear Services, Westinghouse ElectricCompany LLC (Westinghouse), and as such, I have been specifically delegated the function ofreviewing the proprietary information sought to be withheld from public disclosure in connectionwith nuclear power plant licensing and rule making proceedings, and am authorized to apply forits withholding on behalf of Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation as a trade secret, privileged or as confidential commercial or financial information.(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations,the following is furnished for consideration by the Commission in determining whether theinformation sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been heldin confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe types of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of information inconfidence. The application of that system and the substance of that system constitutesWestinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, as follows:(a) The information reveals the distinguishing aspects of a process (or component,structure, tool, method, etc.) where prevention of its use by any of 3CAW-1 1-3237Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.There are sound policy reasons behind the Westinghouse system which include thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.
4CAW-1 1-3237(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390; it is to be received in confidence by theCommission.(iv) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in Response to July 22, 2011, "Braidwood Station, Units I and 2,Byron Stations, Units 1 and 2 -Request for Additional Information Regarding LicenseAmendment Request to Revise Technical Specifications with Bypass Test Capability(TAC Nos. ME5836, ME5837, ME5838, and ME5839)" (Proprietary), for submittal tothe Commission, being transmitted by Exelon Generation Company, LLC letter andApplication for Withholding Proprietary Information from Public Disclosure, to theDocument Control Desk. The proprietary information as submitted by Westinghouse isthat associated with license application to implement technical specification changes toallow testing in bypass of selected Nuclear Instrumentation System channels and selected7300 Protection System channels and may be used only for that purpose.
5CAW-1 1-3237This information is part of that which will enable Westinghouse to:(a) Support Exelon Generation Company, LLC in licensing and modification toinstall bypass test capability to the Nuclear Instrumentation System and7300 Process Protection System.(b) Remain competitive in the marketplace.Further this information has substantial commercial value as follows:(a) Westinghouse can sell support and defense of licensing of this product on otherWestinghouse PWRs.(b) The information requested to be withheld reveals the distinguishing aspects of amethodology and hardware which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar products and licensing defense services for commercialpower reactors without commensurate expenses. Also, public disclosure of theinformation would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(iiXa)through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).COPYRIGHT NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal use in connection with generic and plant-specific reviews and approvals as well as the issuance,denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license,permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
Westinghouse Non-Proprietary Class 3CAE- 11-88 Revision 1 NP-AttachmentCCE- 11-83 Revision 1 NP-AttachmentResponse to July 22, 2011, "BRAIDWOOD STATION, UNITS 1 AND 2,BYRON STATIONS, UNIT NOS. 1 AND 2 -REQUEST FOR ADDITIONALINFORMATION REGARDING LICENSE AMENDMENT REQUEST TOREVISE TECHNICAL SPECIFICATIONS WITH BYPASS TESTCAPABILITY (TAC NOS. ME5836, ME5837, ME5838, AND ME5839)"Westinghouse Electric Company LLC1000 Westinghouse DriveCranberry Township, Pennsylvania 16066&#xa9; 2011 Westinghouse Electric Company LLCAll Rights Reserved CAE-I 1-88 Revision I NP-AttachmentCCE- 11-83 Revision I NP-AttachmentPage 1 of 5RAI Question #2The submittal Westinghouse report WCAP-1 7349-P Revision 1, Section 4.2.2, states that a discussionof the Bypass Test Instrument (BTI) adherence to Institute of Electrical and Electronics Engineers(IEEE) Standard 379-1972 is found in Section 4.3. However, no description of analysis is provided.Please provide the analysis conducted in accordance with the IEEE Standard 379-1972.Response for NIS BTIIf the NIS channel is in normal operation, the following events must occur for the channel to inadvertently go intobypass. The safety (XF1) and non-safety (XF2) breakers on the Bypass Panel must fail and allow power to beapplied to the panel. This would be evident when the breaker light turns on. Then the Bypass Enable Key LockSwitch (SWI) on the Bypass Panel must fail shorted to allow power to the individual functions to be bypassed. Thiswould be evident by the BYPASS ENABLE LED (LEI) illuminating on the front of the Bypass Panel. Also,indication that the Bypass Panel has been enabled is provided on the MCB Annunciator. Finally, one of theindividual function bypass toggle switches (SW2 thru SW9) on the Bypass Panel must fail to allow the function tobe in bypass. This would be evident by one of the individual functional bypass LEDs (LE2 thru LE9) illuminatingon the Bypass Panel. Thus no single failure can cause a function to inadvertently be in bypass. Refer to Figure 1 forthe circuit details of the above explanation.Conversely, it is not possible to have an undetected channel in bypass. The individual NIS bistable signals pass thruthe Bypass Panel thru relay contacts K2 thru K9. These contacts are normally closed and thus pass the 118 VACfrom the NIS drawers to the SSPS input relays. If the relay contacts fail and change state to open, the 118 VAC isblocked placing the channel function in a tripped state which is the conservative safe mode. Refer to Figure 1 for thecircuit details. This would also be evident by MCB annunciator action.Response for 7300 BTIThere are two possible operating configurations for the 7300 bypass cards, each configuration established by specificjumper placement on the bypass card:Configuration 1This is the configuration used for normally energized (NE) type comparators. (The NE type comparator normallyprovides a power return path to energize the load and removes the return path when tripped to de-energize the load.)Configuration 2This is the configuration used for normally de-energized (ND) type comparators. (The ND type comparatornormally does not provide a power return path to energize the load but does provide the return path when tripped toenergize the load).There can be up to four separate comparator channel bypass circuits on each bypass card and the followingdiscussions apply to each comparator channel bypass circuit. However, only the channel 1 bypass circuitcomponents shown in Figure 2 will be referenced in the discussion.Failure Causing a Channel To Transfer Into The Bypass Mode (Non-Operator Initiated)Normal transfer into the bypass mode is accomplished by manually placing a two position toggle switch (BP-1) tothe BYPASS position which applies 26VDC power to a control relay (K2). For both configuration (1) and (2)above, the only failure that could cause the bypass circuit to inadvertently go into the bypass mode would be afailure that causes 26 VDC power to be applied to the control relay (K2). Should this highly unlikely failure occur, CAE- 11-88 Revision I NP-AttachmentCCE-I 1-83 Revision 1 NP-AttachmentPage 2 of 5the control room bypass annunciation alarm would be activated which would identify the protection cabinetinitiating the alarm.Failure Causing a Channel to Stay In The Bypass Mode When Transfer Back To Normal Operation Has BeenInitiated By An Operator.Normal transfer back to the normal mode from the bypass mode is accomplished by manually placing the twoposition toggle switch (BP- 1) back to the NORMAL position which removes the 26VDC power to the control relay(K2). An amber status light (BPT-1) is provided for each comparator bypass channel which is illuminated when inthe normal mode and not illuminated when in the bypass mode.For Configuration 1, the control relay (K2) contact providing the load power return path (For this discussion,referred to for this discussion as the Bypass Control Contact) and the contact controlling the amber status indicator(BPT- 1) are both controlled by the same control relay (K2) form C contact set (K2a). This ensures that when theamber indicator (BPT-1) is illuminated with the closed contact of the form C contact set (Indicating the comparatorchannel is not in bypass), the other contact of the form C contact set, the Bypass Control Contact, has to be open(removing the comparator channel from the bypass mode). Thus, for Configuration 1, failure of the channel toreturn to normal (stays in bypass) following manual positioning of the bypass switch (BP-1) to NORMAL cannothappen undetected.However, for Configuration 2, the Bypass Control Contact (K2d) and the contact controlling the amber statusindicator (K2a) are separate contacts and not part of a form C arrangement although both are actuated by the controlrelay (K2). Therefore, a failure of the Bypass Control Contact (K2d) to close when the bypass control switch (BP- 1)is placed in NORMAL to de-energize the control relay (K2) would result in the amber indicator (BPT-1) beingilluminated (indicating the comparator channel is not in the bypass mode) when the channel is still actually in thebypass mode. This failure is detected by a test of the tripping capability of the channel, or continuity checks throughthe SSPS input relay for certain energize to trip functions.
CAE- 11-88 Revision 1 NP-AttachmentCCE- 11-83 Revision 1 NP-AttachmentPage 3 of 5RAI Question #5If the BTI involves only analog systems, supplement the evaluation to describe how the designconforms to the following clauses of the IEEE Standard 279-1971:4.6 Channel Independence4.7.3 Single Random FailureResponse for NIS BTI Channel IndependenceChannel independence is maintained. There is one Bypass Panel per NIS cabinet bay. Thus there is a unique panelfor each of the four NIS channels. The same cable routings are maintained for each of the channels. Thus there areno changes in the cable routings from the NIS cabinet to the SSPS system. Isolation for the control functions is alsomaintained since no changes are made to the control signals or their routing from the NIS drawers.Response for 7300 BTI Channel IndependenceChannel independence is maintained. The 7300 Bypass Testing modification is a one for one Printed Circuit Cardreplacement. The same cable routings are maintained for each of the channels. Thus there are no changes in thecable routings from the 7300 cabinets to the SSPS system. Any control functions that originate in the 7300protection cabinets maintain their isolation and are not affected by this change.Response for NIS BTI and 7300 BTI Single Random FailureThe addition of the Bypass Testing equipment does not introduce any new control functions or change anyprotective functions. The 7300 and NIS Functional System Design has not changed. Therefore, no new singlefailures have been introduced by this change.
ii*j.j CAE-1 1-88 NP-AttachmentCCE-1 1-83 NP-AttachmentPage 5 of 5a, cFigure 27300 Bypass Test ATTACHMENT 10Westinghouse Affidavit for Attachment 9 SW estinghouse Westinghouse Electric CompanyNuclear Services1000 Westinghouse DriveCranberry Township, Pennsylvania16066USAU.S. Nuclear Regulatory Commission Directtel: (412) 374-4643Document Control Desk Direct fax: (724) 720-075411555 Rockville Pike e-mail: greshaja@westinghouse.comRockville, MD 20852 Proj letter: CAE-11-90/CCE-11-84CAW-1 1-3238August 26, 2011APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: Response to RAI #1 of July 22, 2011, "Braidwood Station, Units 1 and 2, Byron Stations, Units1 and 2 -Request For Additional Information Regarding License Amendment Request ToRevise Technical Specifications With Bypass Test Capability (TAC NOS. ME5836, ME5837,ME5838, and ME5839)" (Proprietary)The proprietary information for which withholding is being requested in the above-reference is furtheridentified in Affidavit CAW-1 1-3238 signed by the owner of the proprietary information, WestinghouseElectric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which theinformation may be withheld from public disclosure by the Commission and addresses with specificitythe considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouserequests that the document be considered proprietary in its entirety. As such, a non-proprietary versionwill not be issued.Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon GenerationCompany, LLC.Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse affidavit should reference this letter, CAW-1 1-3238, and should be addressed toJ. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428,1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours,J. A. Gresham, ManagerRegulatory ComplianceEnclosures CAW-1 1-3238AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared T. Rodack, who, being by me dulysworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:T. Rodack, DirectorQuality and Licensing ProgramsSworn to and subscribed before methis 26h day of August 2011Notary PublicCOMMONWEALTH OF P-ENNTSYLVANIAf ~NOtARIAL SEALRomeo, Qlampoie, Notary PublicPin7WnshIP, Westmorelmnd CountyMy Commission EXPires SOPtomber 26, 2013J 2CAW-1 1-3238(1) I am Director, Quality and Licensing Programs, in Nuclear Services, Westinghouse ElectricCompany LLC (Westinghouse), and as such, I have been specifically delegated the function ofreviewing the proprietary information sought to be withheld from public disclosure in connectionwith nuclear power plant licensing and rule making proceedings, and am authorized to apply forits withholding on behalf of Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation as a trade secret, privileged or as confidential commercial or financial information.(4) Pursuant to the provisions of paragraph (bX4) of Section 2.390 of the Commission's regulations,the following is furnished for consideration by the Commission in determining whether theinformation sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been heldin confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe types of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of information inconfidence. The application of that system and the substance of that system constitutesWestinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, as follows:(a) The information reveals the distinguishing aspects of a process (or component,structure, tool, method, etc.) where prevention of its use by any of 3CAW-11-3238Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.There are sound policy reasons behind the Westinghouse system which include thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.
4CAW-11-3238(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390; it is to be received in confidence by theCommission.(iv) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which iscontained in Response to RAI #1 of July 22, 2011, "Braidwood Station, Units 1 And 2,Byron Stations, Unit Nos. 1 And 2 -Request For Additional Information RegardingLicense Amendment Request To Revise Technical Specifications With Bypass TestCapability (TAC NOS. ME5836, ME5837, ME5838, and ME5839)" (Proprietary), forsubmittal to the Commission, being transmitted by Exelon Generation Company, LLCletter and Application for Withholding Proprietary Information from Public Disclosure,to the Document Control Desk. The proprietary information as submitted byWestinghouse is that associated with license application to implement technicalspecification changes to allow testing in bypass of selected Nuclear InstrumentationSystem channels and selected 7300 Protection System channels and may be used only forthat purpose.
5CAW-1 1-3238This information is part of that which will enable Westinghouse to:(a) Support Exelon Generation Company, LLC in licensing and modification toinstall bypass test capability to the Nuclear Instrumentation System and7300 Process Protection System.(b) Remain competitive in the marketplace.Further this information has substantial commercial value as follows:(a) Westinghouse can sell support and defense of licensing of this product on otherWestinghouse PWRs.(b) The information requested to be withheld reveals the distinguishing aspects of amethodology and hardware which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar products and licensing defense services for commercialpower reactors without commensurate expenses. Also, public disclosure of theinformation would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith is the proprietary version of a document furnished to the NRC in connection withrequests for generic and/or plant-specific review and approval. The document is to be consideredproprietary in its entirety.COPYRIGHT NOTICEThe report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to makethe number of copies of the information contained in this report which is necessary for its internal use inconnection with generic and plant-specific reviews and approvals as well as the issuance, denial,amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit,order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. Copies made by the NRC must include the copyright notice in all instancesand the proprietary notice if the original was identified as proprietary.
ATTACHMENT 11Supporting InformationPictures of NIS Bypass Panel and 7300 Bypass Protection System ATTACHMENT 11Supporting Information7300 & NIS Bypass Testing Photos7300 Notes:The 7300 Bypass Test cards are set up with two basic functions. The firstfunction is to place an instrument loop in test. Placing a loop into test removesthe normal field sensing device (transmitter or RTD) from the input to the loop.Instead, test jacks on the Bypass Test card are placed into the input path so asimulated signal can be sent to the remainder of the instrument loop. This allowsfor calibration of the loop.The second function of the Bypass Test card is to allow the individual functionoutput(s) to be bypassed, regardless of loop input status. The bypass functionworks whether the loop is in test or not. Any switch taken to bypass will cause aMain Control Room (MCR) alarm and Bypass Permissive Panel alarm, with theSequence of Events Recorder (SER) utilized to determine which loop hasfunction(s) in bypass. If the associated loop with the bypassed function(s) is notin test, the actual field sensing device will still be supplying the signal to theremainder of the loop, even though the output function(s) will be bypassed.NIS Notes:The Nuclear Instrumentation System (NIS) Bypass Test Panel works somewhatdifferently than the 7300 cards. There is a Bypass Interlock keylock switch,which enables the individual functions to be bypassed. In addition, the BypassInterlock switch in BYPASS also drives the MCR indication for an NI channelbeing bypassed. The NI channel annunciation is not specific as to which, if any,functions are actually bypassed, it only indicates that that channel has its bypasscapability enabled. There are indicating LEDs on the Bypass Test Panel for eachNIS function to show what is actually bypassed.Page 1 of 10 ATTACHMENT 11Supporting InformationNBC G02 Card -Normal OperationThis is an NBC G02 Bypass Test Card as it would appear during normaloperation with the associated instrument loop in service. The Test switch TS-1(Top switch, at top left of photo) is in NORMAL, and all four Bypass switchesBP-1 through BP-4 (left side of photo) are in NORMAL. The yellow LEDs thatare illuminated above each Bypass switch indicate that the associated function isnot bypassed.Page 2 of 10 ATTACHMENT 11Supporting InformationNBC G02 Card -In Test(No functions bypassed)This is an NBC G02 Bypass Test Card as it would appear with the loop in test.The Test switch TS-1 (Top switch) is in TEST with its associated red indicatingLED illuminated, and all four Bypass switches BP-1 through BP-4 are inNORMAL. The yellow LEDs, which are illuminated above each Bypass switch,indicate that the associated function is not bypassed. In this configuration, allloop functions are in a Tripped status.Page 3 of 10 ATTACHMENT 11Supporting InformationNBC G02 Card -In Test(One function bypassed)This is an NBC G02 Bypass Test Card as it would appear with the loop in Testand one function bypassed. The Test switch TS-1 (Top switch) is in TEST withits associated red indicating LED illuminated. The top Bypass switch BP-1 is inBYPASS with its associated yellow LED not illuminated. The same relay thatcontrols this yellow LED also controls a signal to the annunciator system, whichwould result in MCR indication of Bypassed status. The status of the red LEDthat is illuminated above switch BP-1 is dependent on the test signal beingplaced into the loop. The yellow LEDs, which are illuminated above the Bypassswitches, are still in NORMAL, indicating that the associated functions are notbypassed. In this configuration, the second, third and fourth functions are still ina tripped status.Page 4 of 10 ATTACHMENT 11Supporting InformationNBC G02 Card- In Test(All functions bypassed)This is an NBC G02 Bypass Test Card as it would appear with the loop in Testand all functions bypassed. The Test switch TS-1 (Top switch) is in TEST withits associated red indicating LED illuminated. All Bypass switches BP-1 throughBP-4 are in BYPASS, with the associated yellow LEDs not illuminated. Therelays that control these yellow LEDs also each control a signal to theannunciator system, which would result in MCR indication of Bypassed status.The status of the red LED that is illuminated above each Bypass switch BP-1through BP-4 is dependent on the test signal being placed into the loop. In thisconfiguration, no functions are in a tripped status.Page 5 of 10 ATTACHMENT 11Supporting InformationNBT G02 Card -Normal OperationIThis is an NBT G02 Bypass Test Card as it would appear during normaloperation with the associated instrument loop in service. It is similar to the NBCG02 card in terms of switches and indications but is designed for a 3-wire RTDapplication vice a 2-wire transmitter application.Page 6 of 10 ATTACHMENT 11Supporting InformationNBT G02 Card -In Normal(One function bypassed)This is an NBT G02 Bypass Test Card as it would appear with the loop in Normaland one function bypassed. The Test switch TS-1 (Top switch) is in NORMAL.The bottom Bypass switch BP-4 is in BYPASS, with its associated yellow LEDnot illuminated, indicating this function is bypassed. The same relay whichcontrols this yellow LED also controls a signal to the annunciator system whichwould result in MCR indication of Bypassed status. The status of the red LEDabove switch BP-4 is dependent on the actual field signal being placed into theloop. The yellow LEDs which are illuminated above Bypass switches BP-1through BP-3 which are still in NORMAL indicate that the associated functionsare not bypassed. In this configuration, the first, second and third functions arestill in a status dependent on the actual field signal.Page 7 of 10 ATTACHMENT 11Supporting InformationNIS BYPASS TEST PANEL -NormalOperationThis is the N-41 Bypass Test Panel during normal operation. (The circuitbreakers on the upper left and upper right are normally off and the lampextinguished; they were off when this picture was taken.) The Bypass Enablekeylock switch at center bottom is in NORMAL, as are all the upper switches(individual bypass switches for each function).Page 8 of 10 ATTACHMENT 11Supporting InformationNIS BYPASS TEST PANEL -In Test/BypassThis is the N-41 Bypass Test Panel with the Bypass Enable keylock switch in theBYPASS ENABLE position. The BYPASS ENABLE LED is lit, and there wouldbe a MCR alarm and a Bypass Permissive alarm for channel N-41 with thebypass enabled. The BYPASS ENABLE position allows the upper bypassswitches to be used to bypass the NIS functions. In this photo, no functions arebypassed, as all of the Normal/Bypass switches at the top of the panel are in theNORMAL position.Page 9 of 10 ATTACHMENT 11Supporting InformationNIS BYPASS TEST PANEL -In Test/BypassAll Functions BypassedThis is the N-41 Bypass Test Panel with the Bypass Enable keylock switch in theBYPASS ENABLE position and all six NIS functions bypassed. The BYPASSENABLE LED is lit, and there would be a MCR alarm and a Bypass Permissivealarm for channel N-41 with the bypass enabled. The BYPASS ENABLE positionallows the upper bypass switches to be used to bypass the NIS functions. In thisphoto, all six NIS functions are bypassed via the Normal/Bypass switches beingin BYPASS, with the corresponding LEDs lit. The last two Normal/Bypassswitches are not used.Page 10 of 10
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